Dayna J. Christian, OSB #97336 

Jeff Demland, OSB #140767 

Immix Law Group PC 

121 SW Salmon Street, Suite 1000 

Portland, Oregon 97204 

Phone: (503) 802-5533 

Fax: (503) 802-5351 

E-Mail: dayna.christianAimmixlaw.corn 

E-Mail: jeffidemland@immixlaw.com 

Attorneys for Defendant Patrick Ezell 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

COPIOUS CREATIVE, INC., an Oregon 

corporation, 

Plaintiff, 

v. 

PATRICK EZELL, an individual, 

Defendant. 

Case No.: 3:16-cv-00427-BR 

DECLARATION OF PATRICK EZELL IN 

SUPPORT OF DEFENDANT'S 

RESPONSE TO MOTION FOR 

TEMPORARY RESTRAINING ORDER 

I, Patrick Ezell, being duly sworn, do hereby depose and say: 

1. I am a shareholder of Copious Creative, Inc. ("Copious"). My employment 

with Copious was terminated by Copious on February 17, 2016. 

2. Subsequent to my departure from Copious, I have made no disclosures of any 

of Copious's confidential information to any third party. Any confidential information that 

Page 1 — DECLARATION OF PATRICK EZELL Immix Law Group PC 

121 SW Salmon Street, Suite 1000 

Portland, OR 97204 

Telephone: 503-802-5533 

Facsimile: 503-802-5351 

Case 3:16-cv-00427-BR Document 10 Filed 03/11/16 Page 1 of 4
remained in my possession following my termination was at all times securely encrypted to 

protect Copious's confidential information. 

3. On February 17, 2016, prior to my termination, my attorney, Jerry Carleton of 

Immix Law Group PC, and I met with Copious President, Timothy Haskins, Copious's 

counsel, Rick Okamura, and Mr. Haskins' personal attorney, Scott Schnuck, to discuss the 

execution of a buyout and exit from the company by either Mr. Haskins or myself 

4. On February 19, 2016, I met with Mr. Carleton's partner, Dayna Christian, and 

Mr. Okamura and provided all company property remaining in my possession that I could 

locate after a careful search. Concurrent with that meeting, I executed a declaration drafted 

and approved by Mr. Okamura. A true copy of that declaration was attached to Mr. Haskins' 

declaration (Doc. No. 6) as Exhibit 8 (Doc. No. 6-8). 

5. On February 22, 2016, Ms. Christian and I met with Mr. Okamura in person 

and with Mr. Haskins by telephone. During that meeting, I spent an additional four hours 

providing Mr. Haskins with the passwords necessary to access Copious accounts and notified 

him of various business matters requiring his attention. 

6. At the end of the February 22, 2016 meeting, Mr. Haskins provided a letter 

demanding that I preserve all evidence and not destroy any evidence. Since that date, I have 

not taken any action that would violate the terms of that letter. 

7. On March 2, 2016, I discovered that still had access to Copious's Lucidchart 

account. I promptly notified Ms. Christian, who relayed that information to Copious's 

counsel. I have no intention to retain any Copious confidential information that I may locate 

in the future and will immediately return any such information that I may find. 

8. I have not returned my smartphone to Copious. It is not a company asset, but 

Page 2 — DECLARATION OF PATRICK EZELL Immix Law Group PC 

121 SW Salmon Street, Suite 1000 

Portland, OR 97204 

Telephone: 503-802-5533 

Facsimile: 503-802-5351 

Case 3:16-cv-00427-BR Document 10 Filed 03/11/16 Page 2 of 4
was provided to me as a shareholder benefit. 

9. Since my termination, I have not used any of Copious's confidential 

info nation for any purpose, including my own personal gain. I have no intention of doing 

so in the future. 

I HEREBY DECLARE THAT THE ABOVE STATEMENT IS TRUE TO THE BEST 

OF MY KNOWLEDGE AND BELIEF, AND THAT I UNDERSTAND IT IS MADE 

FOR USE AS EVIDENCE IN COURT AND IS SUBJECT TO PENALTY FOR 

PERJURY. 

DATED: March 11, 2016. 

Page 3 — DECLARATION OF PATRICK EZELL Immix Law Group PC 

121 SW Salmon Street, Suite 1000 

Portland, OR 97204 

Telephone: 503.802-5533 

Facsimile: 503402-5351 

Case 3:16-cv-00427-BR Document 10 Filed 03/11/16 Page 3 of 4
CERTIFICATE OF SERVICE 

I hereby certify that on March 11, 2016, I served a true copy of the foregoing on the 

parties and/or attorneys listed below by the method(s) indicated below on said day. 

Neil N. Olsen 

Joseph W. Carlisle 

Zupancic Rathbone Law Group, P.C. 

4949 Meadows Road, Suite 600 

Lake Oswego, OR 97035 

nolsen@zrlawgroup.corn 

jcarlisle@zrlawgroup.corn 

Fax: (503) 968-8017 

Via CM/ECF 

D a J. Christian, OSB #973360 

E-Mail: dayna.christian@immixlaw.com 

Jeffery A. Demland, OSB # 140767 

E-Mail: jeff demland@immixlaw.com 

Immix Law Group PC 

Attorneys for Defendant Patrick Ezell 

Page 4 — DECLARATION OF PATRICK EZELL Immix Law Group PC 

121 SW Salmon Street, Suite 1000 

Penland, OR 97204 

Telephone: 503-802-5533 

Facsimile: 503-802-5351 

Case 3:16-cv-00427-BR Document 10 Filed 03/11/16 Page 4 of 4