Escolar Documentos
Profissional Documentos
Cultura Documentos
07-16-00320-CV
COUNSEL
Appellants
Timothy Castleman and
Castleman Consulting, LLC
Appellees
Internet Money Limited and
Kevin OConnor
ii
TABLE OF CONTENTS
IDENTITIES OF PARTIES AND COUNSEL .................................................... ii
I. DESIGNATION OF PARTIES...........................................................................1
II. JURISDICTION AND VENUE ........................................................................2
III. STATEMENT OF THE CASE .......................................................................2
IV. APPLICATION FOR TEMPORARY RESTRAINING ORDER,
TEMPORARY INJUNCTION AND PERMANENT INJUNCTION ........3
V. CONCLUSION ...................................................................................................6
VI. PRAYER FOR RELIEF ..................................................................................6
CERTIFICATE OF COMPLIANCE ....................................................................7
CERTIFICATE OF SERVICE ..............................................................................8
VERIFICATION......................................................................................................9
APPENDIX .............................................................................................................10
Appellees.
AND
KEVIN
AND
CASTLEMAN CONSULTING,
LLC, have made an appearance in this lawsuit by and through their attorney of
record Jared Hall and Lief Olson.
2.
appearance in this action by and through his attorney of record, J. Paul Manning.
1
Jurisdiction and venue are proper in the Court of Appeals for the 7th
District of Texas because at the time of the conduct made the basis of Appellees
Verified Original Application for Temporary Restraining Order and Temporary
Injunction, this Court had jurisdiction over the parties pursuant to TEXAS RULE OF
APPELLATE PROCEDURE 52.1.
III. STATEMENT OF THE CASE
5.
email threatening and attempting to goad Appellants into improper discourse. (Ex.
A-2) On August 11, 2016, Appellants directly contacted counsel for Appellees. (Ex.
A-3) Appellees counsel contacted Appellants counsel, Jared Hall, requesting the
direct contact with Appellees and his counsel stop immediately. (Ex. A-4)
Appellees counsel advised that Appellants had been instructed against direct
contact. (Ex A-4)
9.
the additional threats and intimidating language. (Ex. A-6) Again, on November 8,
2016 Appellant directly contacted Appellee. (Ex. A-7) Appellee, Kevin OConnors
wife is pregnant, and the intimidating and harassing nature of the contact by
Appellants has unnerved both Mr. and Mrs. OConnor. (Ex. A)
IV. APPLICATION FOR TEMPORARY RESTRAINING ORDER,
TEMPORARY INJUNCTION AND PERMANENT INJUNCTION
11.
12.
For the last few months, Appellants have been playing a cat and mouse
game with Appellees, attempting to goad them into an inappropriate online fight. At
every opportunity, Appellees have taken the high road refusing to respond. Despite
repeated requests by Appellees counsel for Appellants to refrain, Appellants
continuously and systematically refuse to stop directly contacting Appellees or
posting items about them online. Appellants actions have caused anxiety, fear, and
harassment to Appellees and Mr. OConnors pregnant wife.
13.
Appellants
actions
leave
no
doubt
they
intentionally
and
imminent, and irreparable harm. Monetary damages alone are not sufficient to
redress the imminent and irreparable harm to Appellees.
15.
merits of their claims and a probable right to relief. The equities in this matter weigh
heavily in favor of Appellees, as Appellees seek only to preserve the status quo
pending trial, appeal, and/or other resolution of the parties dispute.
16.
17.
Appellees are willing to post a bond in the reasonable amount this Court
AND
REMEDIES CODE
65.001, et. seq., and TEXAS RULES OF APPELLATE PROCEDURE Rule 52.1, to prevent
Appellees from suffering the aforementioned non-monetary penalty of fear, anxiety,
and harassment, Appellees ask this Court to preserve the status quo and grant a
temporary restraining order and temporary injunction against Appellants to enjoin
Appellants from contacting, threatening, emailing, posting in social media and
posting any comments, videos, pictures about Appellees by their agents, attorneys,
employees or family and communicating with Appellees or Appellees counsel in
person or in any other manner, including by telephone or another electronic voice
transmission, video chat, in writing, or electronic messaging during the pendency of
this litigation. Appellees further seek a permanent injunction against Appellants
from further engaging in the proscribed activities set forth above.
V. CONCLUSION
For the reasons stated herein, Appellees ask this Court to enter a temporary
restraining order and temporary injunction to allow Appellees to protect themselves
and their rights and to attorney fees.
VI. PRAYER FOR RELIEF
FOR THESE REASONS, the Appellees request and pray that:
1.
The Court enter a temporary restraining order enjoining Appellants, and
any of their agents, servants, or employees,
a.
b.
2.
Appellants be cited to appear and show cause and that upon hearing, a
temporary injunction be issued enjoining Appellants, and any of their agents,
servants, or employees, from directly or indirectly contacting, threatening, emailing,
posting in social media and posting any comments, videos, pictures about Appellees;
and communicating with Appellees or Appellees counsel in person or in any other
manner, including by telephone or another electronic voice transmission, video chat,
in writing, or electronic messaging during the pendency of this litigation;
3.
Attorneys fees expended in this cause in such amount as may be found
reasonable by the Court;
4.
5.
Such other and further relief the court deems appropriate to which
Appellees may show itself justly entitled either at law or in equity.
Respectfully submitted,
FIELD, MANNING, STONE,
HAWTHORNE & AYCOCK, P.C.
A Professional Corporation
2112 Indiana Avenue
Lubbock, Texas 79410-1499
806/792-0810 (Telephone)
806/792-9148 (Facsimile)
Email: jpmanning@lubbocklawfirm.com
BY: /s/J. Paul Manning
J. PAUL MANNING
State Bar No. 24002521
Attorneys for INTERNET MONEY LIMITED
AND KEVIN OCONNOR,
CERTIFICATE OF COMPLIANCE
Pursuant to TEXAS RULES OF APPELLATE PROCEDURE Rule 52.10, counsel for
Appellees has notified counsel for Appellants, Jared Hall, that this application will
be filed.
/s/J. Paul Manning
J. PAUL MANNING
CERTIFICATE OF SERVICE
A true and correct copy of the above and foregoing instrument was on this
22 day of November, 2016, served on the attorneys of record as follows:
nd
Email: jhallattorney@gmail.com
Fax: 866-870-2072
JARED B. HALL
THE LAW OFFICE OF JARED B. HALL, PLLC
PO BOX 6982
Lubbock, TX 79493
Email: leif@olsonappeals.com
LEIF A. OLSON
THE OLSON FIRM, PLLC
4830 Wilson Road, Ste. 300
Humble, TX 77396
/s/J. Paul Manning
J. PAUL MANNING
APPENDIX
Exhibit A - Affidavit of Kevin OConnor ...................................................... Tab 1
Exhibit A-1 ........................................................................................................ Tab 2
Exhibit A-2 ........................................................................................................ Tab 3
Exhibit A-3 ........................................................................................................ Tab 4
Exhibit A-4 ........................................................................................................ Tab 5
Exhibit A-5 ........................................................................................................ Tab 6
Exhibit A-6 ........................................................................................................ Tab 7
Exhibit A-7 ........................................................................................................ Tab 8
Exhibit B ........................................................................................................... Tab 9
10
REPUBLIC OF IRELAND
COUNTY OF KILDARE
Page 1
Affidavit
Exhibit "A"
3. The attached Exhibits (A:I-A:7) are true and correct copies of emails I have
received from Tim Castleman directly since the commencement of this
lawsuit and requests sent by Appellees attorneys requesting him not to directly
contact me.
4. In the normal course of business, I received and/or investigated the emails and
status of Castleman and Castleman Consulting, LLC were sending, posting
and blogging and I pulled and copied same. Exhibits A-B are true and correct
copies of these certain copies I found in the normal course of business.
5. My wife is pregnant with our first child and the emails received from
Castleman and Castleman Consulting, LLC have caused increased anxiety,
apprehension and fear to both of us.
.J..~
"-"-
Kevin O'Connor
Notary Public
I
4 lucan lodge,
lucan, Co. Dublin
Ireland
:.1
Page 2
Subject: Kevin O'Connor and The Offline Assistant Response to Your Demand Letter Dated December 14, 2015
Mr. Hall,
I hope that you had a wonderful Christmas holiday and that the weather in Lubbock has been more pleasant
than here in DFW.
Attached, please find a copy of Mr. O'Connor's and The Offline Assistant's response to your demand letter
'ated December 14, 2015. After you have had time to review the letter and speak with your client, I look
forward to discussing with you the facts giving rise to this dispute. In addition to the attached copy, a hard copy
of the response is being mailed to your office.
On a separate note, Mr. O'Connor has relayed to me that Mr. Castleman has emailed him multiple times in the
past few weeks. As my firm and I are representing Mr. O'Connor and The Offline Assistant, I respectfully
request that you tell Mr. Castleman to direct any future inquiries or communications related to this dispute to
me and my firm, not Mr. O'Connor.
Lastly, after this response was drafted, it came to light that Mr. Castleman had "charged back" approximately
<l)2,000.OO worth of work that The Offline Assistant performed, resulting in the deduction of The Offline
Assistant's bank account. In short, The Offline Assistant performed services for Mr. Castleman and Castleman
Consulting, LLC; Mr. Castleman and Castleman Consulting, LLC enjoyed those services; Mr. Castleman and
Castleman Consulting, LLC were enriched by those services, however, The Offline Assistant has not been
compensated for those very services. This issue must be addressed in addition to those discussed in the
attached response.
I look forward to hearing from you. As always, please feel free to call with any questions or concerns.
Sincerely,
Zachary C. Farrar
Exhibit "A-1"
Direct Dial
817.255.9199 - Facsimile
zfarrar@mph-Iaw.com
Primerus
THIS E-MAIL AND ITS ATTACHMENTS MAYBE CONFIDENTIAL AND/OR PRIVILEGED. IF YOU
, ARE NOT AN INTENDED RECIPIENT, PLEASE NOTIFY THE SENDER BY REPLY E-MAIL AND
DESTROY ALL COPIES OF THESE MATERIALS. UNLESS STATED OTHERWISE, NOTHING HEREIN
IS INTENDED TO BE AN ELECTRONIC SIGNATURE.
Kevin Looks like the judge wants this lawsuit of yours to continue.
I hope your lawyer isn't actually charging you for the 3 hours he sat waiting for the case to be heard like he tried
to do to me when he submitted his bill to the court.
Or the fact he's the one who is having to write up the paperwork for the judge.
Guess you have to pay for that as well?
$6500 in attorneys fees for you already according to his filing (I'd check it to be sure)?
He isn't even using paralegals for this case, 100% lawyers only apparently (at least from what I saw on his
billing sheet he submitted).
Ouch, and you owe me what - $8k?
And this is after I offered to settle with you for less than that amount several times to end this mutually way
before we even spent a dime here.
I mean now you have to pay your lawyers fees for the appeal cost, then the trial itself, our lawsuit against you,
appeals from both parties, and more.
1
Exhibit "A-2"
And if you lose, you might not only have to pay the amount you owe me, but possibly also my lawyers fees as
well, and maybe some damages on top of that?
How much do you think this is going to end up costing when we're all done here?
20k+? I don't think the legal system is in any hurry to see us finish this anytime soon.
Why would they right - it's the lawyers who are getting paid so why would they want it to end?
This thing could drag on for a few years before we're done with it.
I don't remember the exact numbers but I thought your guy said he'd be charging like $12,000 to do the appeal
(but I don't have the paperwork in front of me). Then if that doesn't go well, we start all over with your trial, our
lawsuit against you (spoiler alert), and then the appeals from each party.
Now that we're moving forward I guess you'll be coming to Lubbock several times for the trial, deposition,
hearings, and the trial.
I'm sure there are discounted flights from Ireland to Lubbock for to you take advantage of and I can make some
hotel recommendations if you'd like for when you get here.
And I'm also sure your lawyer is going to ask that I don't contact you and speak to him directly so I'll save you
both the trouble:
No.
If either of you have a problem with it you both know my address and you can come talk to me personally, but
we both know that won't happen, right?
Tim
ps: The opinions expressed here are just my thoughts and ideas and not based on any factual information or
statements and for the love of God should not be taken seriously without doing your own due diligence first.
They are the statements of Tim Castleman, President of Castleman Consulting LLC and not that of Tim
Castleman personally.
This email has been scanned for spam and viruses by Proofpoint Essentials. Click here to report this email as
spam.
J. Paul. Manning
Tim Castleman <timothycastleman@gmail.com>
Wednesday, August 10, 2016 6:14 PM
Kevin OConnor; Kevin OConnor; Kevin OConnor; Jared B. Hall; Leif Olson; J. Paul.
Manning
False YouTube Report By Kevin OConnor (Please remove by (8/19)
YouTube.jpg; UnitedStates.jpg
From:
Sent:
To:
Subject:
Attachments:
Mr. Manning:
Your client appears to have filed a false and misleading request to have MY copyright protected content (that
was created here in the United States by my company (a US based company) blocked from Ireland.
The country of this dispute is not Ireland like Mr. OConnor falsely reported, but the United States (where I am
licensed to do business). Again, this appears to be a knowingly false claim by your client in an attempt to
circumvent the US legal system.
As you can see by the attached screenshots (you feel free to do your research as well
https://support.google.com!youtube/answer/6154230?hl=en select the United States), YouTube specifically
states that it will NOT remove content created in the United States without a written court approval.
-
If the content isnt fully restored by the 19th of August, please alert the judge and I would ask that we schedule
an in person hearing (that requires Mr. OConnors in person attendance) to explain this.
Thanks.
1
Exhibit "A-3"
Sandra Meeks
From:
Sent:
To:
Subject:
Ive told Tim he is not to contact either you or Kevin; that all communications are to be to me or Lief only.
Thanks,
Jared
Jared B. Hall
The Law Office of Jared B. Hall, PLLC
P0 Box 6982
Lubbock, TX 79493
(806) 853-7182
(866) 870-2072 fax
This email and all attachments may be covered by attorney client privilege. If you are not the intended recipient, please
delete and notify sender.
On 8/10/2016 8:04 PM, J. Paul. Manning wrote:
> Jared
>
I let the last direct correspondence by your client to mine slide but please have all contact go through the lawyers.
>
> Thanks
>
>J Paul
>
Exhibit "A-4"
1
J. Paul. Manning
From:
Sent:
To:
Subject:
JP
As far as I know, currently there is no request from Kevin or any court order requiring me to not to contact my
friend Kevin.
I also contacted you with the last email (see how it was addressed directly to you just like this one), your client
was sent a copy as a courtesy, since it directly affects him. Just like I am with this email, you know, like a friend
would do.
-
As far as I know, Pm under no legal or ethical restrictions (like I understand lawyers are) not to contact your
client, someone who apparently still considers me a friend (as judged by his current friendship status with me
via Facebook) and that as far I know I still have a personal friendship with (see your clients email from me
about this not being personal) and the fact he was in Lubbock and we hung out shortly before all of this
happened. If Im incorrect in that, and our friendship status has changed, Mr OConnor (and Mr OConnor alone)
can let me know that were no longer friends and I wont contact him again, but as of today, he hasnt done so
and thats why I continue to email him when important things occur.
Im sure you can see how confusing this could be with the mixed signals Im getting here, especially with zero
actual comments from Kevin or legal requirements here and just your request (which again, as far as I know, I
am under no legal obligation to follow).
Im also sure you have better things to do than dealing with this, but if Im incorrect, then please feel free to
have your client contact me and tell me that we are no longer friends and that he doesnt want me contacting
him anymore or file the necessary legal paperwork.
Maybe we can all be there in person and Kevin can explain the YouTube thing to us all at the same time?
That way your client doesnt have to appear in person, in court on at least two different occasions before the
actual legal trial starts.
I have to think those plane tickets from Ireland are pretty expensive and with this, the appeal, the trial, our
lawsuit against him, etc Im sure youll want to keep his out of pocket cost to a minimum and not charge him full
price for things like sitting and waiting 3 hours for a case to heard or something crazy like that.
-
Exhibit "A-5"
I.
Kevin!
Man I haven't heard back from you since my last email - I hope everything is going ok my friend.
Listen, just wanted to let you know I sent off my check to the lawyer for our appeal to go through so the good
news is your lawyer gets to spend some more time in court on your behalf.
The court of appeals is a two hour drive each way from Lubbock (my guy is flying in direct from Houston) so at
your lawyers hourly rate the drive alone is going to cost you $1200.
Not to mention the actual paperwork for this appeal, sitting in court (remember the 3 hours he charged you last
time for just sitting there), and whatever else he has to do (like talk to you about the case, etc).
Think you'll finally break the $10k in lawyers fees with the appeal? Will JP really charge you $12k like he said
in last filing with the court.
My lawyer said he had one case that took 9 months to go in front of the court of appeals after all the paperwork
was filed. That's just crazy but due process is due process I guess.
And just think man, if somehow the appeal court doesn't side with us, then we have the actual trial and our
counter suit against you to go through and unlike this one, you'll actually have to appear in person, here in
Lubbock, several different times for hearings, etc for BOTH cases.
I doubt there are many discounted flights from Ireland to Lubbock Texas, but ifthere are I'll send them your
way.
Also the guy who swore under oath that he didn't do business with you because of my post - make sure he has
his passport ready as well because he'll have to make an appearance or two I suspect.
What do you think your final number is going to be in lawyers fees when this is all done? 15k or 20k??? Then
1
Exhibit "A-6"
This email has been scanned for spam and viruses by Proofpoint Essentials. Click here to report this email as
spam.
Exhibit "A-7"
real possibility that you lose a legal case and have a legal judgement against you and then have to
pay me + a fine for filing the lawsuit, which will all be a matter of public record and anytime
anyone searches for you or your company it will be there.
Not to mention you still have to travel to Lubbock for the deposition, then the trial and explain
why you took down my videos and everything else.
See ya in 2017.
Tim
EXHIBIT B
21st September 2016 - Twitter
https://twitter.com/TimCastleman/status/778673004230258688
21st September
https://www.reddit.com/r/news/comments/53uvrz/the_offline_assistant_million_do
llar_lawsuit/?utm%5C_source=ifttt
11/21/2016 TimCastlemanonTwitter:"Updateonthe$1millawsuitTheOfflineAssistantand@kevinWoconnorhaveagainstme:https://t.co/vAFgtuckIy#TheOfflin...
Home
SearchTwitter
Moments
Haveanaccount?Login
Follow
TimCastleman
@TimCastleman
Updateonthe$1millawsuitTheOffline
Assistantand@kevinWoconnorhaveagainst
me: timothycastleman.com/theofflineas
#TheOfflineAssistant
RETWEETS
LIKES
12:11PM21Sep2016
TimCastleman
2016Twitter
HourBestseller,TheCreativity
Checklistandthe2kHFormula.
AlsohostoftheTwoDrinkTim
Podcast.
timothycastleman.com
JoinedJuly2009
https://twitter.com/TimCastleman/status/778673004230258688
1/1
11/21/2016
TheOfflineAssistantMillionDollarLawsuitAgainstMe:news
MYSUBREDDITS
FRONT ALL RANDOM | ASKREDDIT FUNNY PICS GAMING TODAYILEARNED GIFS VIDEOS WORLDNEWS AWWMORE
MOVIES
/r/news
Wanttojoin?Loginorsignupinseconds. | English
Postanalysis/opinionarticlesto/r/inthenews
submitanalysis/opinionarticle
/r/worldnews
/r/politics
newcomments
submitnewsarticle
/r/inthenews
TheOfflineAssistantMillionDollar
LawsuitAgainstMe (timothycastleman.com)
NotNews
comments
submitted2monthsagobyLubbockGuy
5comments share
submitsomethingelse
search
all5comments
sortedby:best
[] tomjoads 1points2monthsago
Igiveashitaboutyourlawsuitswhy?
permalink
thispostwassubmittedon21Sep2016
1 point
https://redd.it/53uvrz
embed
[] LubbockGuy [S]1point2monthsago
WellTom,foronethingthisisacompanytrying
tobullyanothercompanytokeepquietbyhaving
theircontentillegallyremovedfromtheinternet&
tryingtosuethemintosilence.
username
password
rememberme
resetpassword
login
Iftheywin,thenyoucouldbelegallysuedand
heldresponsiblefornegativereviewsofbusinesses
thatyou'veusedandhadapoorexperiencewith.
Andifyoudospeakout,youwon'tbelegally
protectedtostateyouropiniononthesituation.
Isthatenoughtogiveashitabout?
permalink
embed
parent
[] tomjoads 1point2monthsago
NoIdon'tgiveashit,yourshittylifecoaching
companyisbeingsued.GoAstroTurf
somewhereelse
permalink
embed
parent
[] LubbockGuy [S]1point1monthago
Tom
Icantellalreadythatyou'reanidiot,but
atleasttrytobeasmartone.Idon'tdo
lifecoaching,Idohoweversellstuffonline
andhavebeenprettysuccessfulwithit.
Igetthatitmightnotbeforyou,most
peoplearen'twillingtodotheworktobe
successful,butI'mproudofwhatwe've
done.
Enjoyyourtrolling!
permalink
embed
parent
/r/news
unsubscribe
11,332,391readers
7,668usersherenow
Wanttotalk?
Follow@rslashnewsonTwitter
Seeapostthatviolatestherulesbelow?Hadyour
poststuckinthespamfilter?Haveaquestion
aboutpolicy?Justwanttogivefeedback?Send
themodteamamessage.
Submitallself&metapoststo/r/inthenews
Yourpostwilllikelyberemovedifit:
isnotnews
isanopinion/analysisoradvocacypiece.
primarilyconcernspolitics.
hasatitlenottakenfromthearticle.
hasapaywallorstealscontent.
coversanalreadysubmittedstory.
https://www.reddit.com/r/news/comments/53uvrz/the_offline_assistant_million_dollar_lawsuit/?utm%5C_source=ifttt
1/3
11/21/2016
TheOfflineAssistantMillionDollarLawsuitAgainstMe:news
violatesreddit'ssitewiderules ,
especiallyregardingpersonalinfo.
Yourcommentwilllikelyberemovedifit:
isracist,sexist,vitriolic,oroverlycrude.
isunnecessarilyrudeorprovocative.
isacheapanddistractingjokeormeme.
isrespondingtospam.
violatesreddit'ssitewiderules .
Extremeorrepeatoffenderswillbebanned.
>>>ExpandedRules <<<
Ifyourpostdoesn'tfit,considerfindingan
appropriatenewsarticleonthatstoryto
submitinstead,orsubmittingyourstolower
moderationsubreddits:
/r/inthenews allnewsrelatedcontent
/r/AnythingGoesNews unrestrictednews
/r/trueredditinsightfularticles
/r/self anyselfpost
/r/misc,/r/redditdotcom anything
orothernewssubreddits:
/r/worldnews fromoutsidetheUSAonly
/r/SyrianCivilWarabouttheconflictinSyria
/r/MidEastRegionalWaronMidEastconflict
/r/UpliftingNews uplifting
/r/SavedYouAClickmakingmediamore
straightforward
orsubredditsforothertopics:
/r/FoodForThoughtdiscussionworthylong
formarticlesaboutinterestingsubjects
/r/politics forshoutingaboutpolitics
/r/moderatepolitics lessshouting
/r/politicaldiscussionevenlessshouting
/r/geopolitics intl.politicsandgeography
/r/entertainmentJustinBieberupdates,etc.
/r/europenewsfromEurope
orcheckoutthe200mostactivesubreddits,
categorizedbycontentandthefulllistof
subredditsbysubscribers .
Recommendations:
/r/full_news
/r/qualitynews
/r/neutralnews
/r/worldevents
acommunityfor8years
https://www.reddit.com/r/news/comments/53uvrz/the_offline_assistant_million_dollar_lawsuit/?utm%5C_source=ifttt
2/3
11/21/2016
TheOfflineAssistantMillionDollarLawsuitAgainstMe:news
moderators
messagethemoderators
douglasmacarthur
TheJanitor
Kylde
CandyManCan
Elderthedog
LuckyBdx4
ani625
pomosexuality
IKingJeremy
luster
RNews_Mod
...and8more
<
>
discussionsin/r/news
7309points8276comments
Police,citingongoingriot,usewatercannons
onDakotaAccessprotestersinfreezing
weather
about
help
apps&tools
<3
blog
about
sourcecode
advertise
jobs
siterules
FAQ
wiki
reddiquette
transparency
contactus
RedditforiPhone
RedditforAndroid
mobilewebsite
buttons
redditgold
redditgifts
UseofthissiteconstitutesacceptanceofourUserAgreementandPrivacyPolicy(updated).2016redditinc.Allrightsreserved.
REDDITandtheALIENLogoareregisteredtrademarksofredditinc.
Advertiselifestyles
https://www.reddit.com/r/news/comments/53uvrz/the_offline_assistant_million_dollar_lawsuit/?utm%5C_source=ifttt
3/3
11/21/2016
TheOfflineAssistantMillionDollarLawsuitAgainstMe|
http://www.timothycastleman.com/theofflineassistantmilliondollarlawsuitagainstme/
1/6
11/21/2016
TheOfflineAssistantMillionDollarLawsuitAgainstMe|
Not only did he not repay us (even after I oered to settle for $5,000, half the
amount my lawyer was requesting) his lawyer sent me a demand letter asking
for me to pay $315,000 in damages, to remove all of my post, videos, podcasts
and more that shared my experience with The Oine Assistant CompanyAND
wanted me to write an apology (that had to be approved by Kevin prior to
publishing) and post it here (and other locations) for an entire year.
Demand Letter Reply From The Oine Assistant Company
DemandLetterReplyFromtheOfflineAssistantCompanybyTimCastlemanonScribd
http://www.timothycastleman.com/theofflineassistantmilliondollarlawsuitagainstme/
2/6
11/21/2016
TheOfflineAssistantMillionDollarLawsuitAgainstMe|
http://www.timothycastleman.com/theofflineassistantmilliondollarlawsuitagainstme/
3/6
11/21/2016
TheOfflineAssistantMillionDollarLawsuitAgainstMe|
Barbara Sucsy
District Clerk
cdm
OF
AND
KEVIN
I am only sharing this on my company blog here because Kevin and The Oine
Assistant Company keep attempting to have me silenced and my videos blocked
in Ireland.
My personal experience with The Oine Assistant company has been as follows:
Hired them to fulll our eCom store orders for our dropshipping store.
During a monthly review of my books, my accountant and I noticed close to
$8,000 in double orders by The Oine Assistant company on our behalf.
http://www.timothycastleman.com/theofflineassistantmilliondollarlawsuitagainstme/
4/6
11/21/2016
TheOfflineAssistantMillionDollarLawsuitAgainstMe|
When we confronted Kevin OConnor, the CEO of the company about this he
not only refused to accept responsibility, he stopped responding to my emails
once I started demanding repayment.
Left with no other options I retained a lawyer to ask for repayment via our
legal demand letter.
Kevin then hired not one, but two lawyers. The rst one wanted me to pay him
$315,000, give up my rst amendment rights (my opinion) and issue a public
apology (that had to be approved personally by Kevin) and his new lawyer now
wants me to pay up to $1,000,000 to Kevin and The Oine Assistant company.
This is my experience as President of Castleman Consulting LLC and should only
be considered my opinion until proven in a court of law. Do you own research
and due diligence prior to making any decision on doing business with The
Oine Assistant Company. I just wanted to share my experience with them.
These documents are a matter of public record and an ongoing legal case
against me and I am within my rights to publish them here.
Here is the video Kevin and The Oine Assistant Company are blocking from
Ireland viewers:
http://www.timothycastleman.com/theofflineassistantmilliondollarlawsuitagainstme/
5/6
11/21/2016
TheOfflineAssistantMillionDollarLawsuitAgainstMe|
00:00
44:33
Comments
comments
PR EV IO U S PO ST
2016
PROUDLY POWERED BY WORDPRESS
THEME: MEOLA BY ELMASTUDIO
TOP
6/6
11/21/2016
Warning:StayAwayFromTheOfflineAssistantCompany&KevinOConnorUpdated9.6.16
About
Timeline
Discover
My subscriptions
TIMOTHYCASTLEMAN.COM
Feed
2016-09-06
Like 0
Share
Subscribe
Tweet
Warning: Stay Away From The Ofine Assistant Company & Kevin OConn...
Kevin appears to be intentionally trying to get all of my content blocked in Ireland instead of waiting
for the million dollar lawsuit he brought against us to nish here in the US Court System.
So for anyone who is in Ireland, here is the video unedited (and there is nothing Kevin can do to block
it)
http://newscentral.exsees.com/item/b1560d8881b99144ea1df496d6bd015cf82f0ba38e40c6f66e3f773a1f5f079a
1/7
11/21/2016
Warning:StayAwayFromTheOfflineAssistantCompany&KevinOConnorUpdated9.6.16
00:00 / 44:33
All content contained inside this video is a matter of public record and cause #2016-519, 740 here in
Lubbock Texas and does not violate any privacy or trademark issues.
All parties involved were in the United States at the time of this dispute and as such this content
cannot and should not be removed or restricted (say in Ireland for example) without court paperwork
per YouTube Policy.
All court paperwork should originate from the United States as that is where Kevin has sued my
company.
All statements made in the video are the opinion of Tim Castleman, Castleman Consulting LLC
President and should not be taken as factual without doing your own proper due diligence.
*** Update: Here is a video update of our on going dispute with Kevin OConnor and The Ofine
Assistant Company ***
Spoiler Alert: They are suing US for 1 million dollars and trying to get all of our content removed from
YouTube.
Heres the video update on YouTube: https://youtu.be/-ibf9UgJEUw
For those of you in Ireland (where Kevin is trying to block the content) here is the video:
http://newscentral.exsees.com/item/b1560d8881b99144ea1df496d6bd015cf82f0ba38e40c6f66e3f773a1f5f079a
2/7
11/21/2016
Warning:StayAwayFromTheOfflineAssistantCompany&KevinOConnorUpdated9.6.16
00:00 / 44:33
On November 18th, 2015 during a routine review of our books, our accountant noticed a $7,897.68
error caused by Kevin OConnors Ofine Assistant Company.
We hired Kevin and his company to fulll our physical product store orders and it turns out that they
had been double ordering and shipping our most popular item to customers at our expense for no
understandable reason.
Once the error was discovered, I immediately had the last 100 orders they had placed for us reviewed,
and there was an 85% error rate in those orders so we started to dig deeper.
I immediately let Kevin know about this issue personally and told him I would get him a full report by
the following Monday (this was Friday).
We pulled our nancial records from the store, the supplier, and matched them to our credit card
statements for them to get a full accounting of just how bad it was.
When all was said in done, Kevins employees had over ordered and shipped products to the tune of a
$14,968.45 almost DOUBLE what the orders should have cost and costing us $7,897.68 in prot.
Armed with this information I sent everything to Kevin and asked him to review everything and if the
numbers were correct explain why none of the orders were checked by his project manager (as
promised when we signed up) or anyone else on is staff for accuracy, how his employees could see us
losing money on ever order and not say anything, and why they hadnt followed the spreadsheet
directions we gave them.
When he nally responded 3 days later, he blamed us for not catching the error and cited a training
example order we included in the training materials (of a totally different product than the one they
misordered above) as a reason why they had doubled ordered everything.
Except they hadnt double ordered every item.
His team managed to order the correct quantities of other items we sold in different amounts (1, 2, 4
etc) with no problem.
When confronted with this, he went radio silent and refused to respond to any more of my emails.
It was only after I demanded repayment for the $7,897.68 error that he nally responded, and only to
tell me that he considered the matter closed on his part and that he and his employees had done
nothing wrong and that he wouldnt be paying for his employees mistake.
http://newscentral.exsees.com/item/b1560d8881b99144ea1df496d6bd015cf82f0ba38e40c6f66e3f773a1f5f079a
3/7
11/21/2016
Warning:StayAwayFromTheOfflineAssistantCompany&KevinOConnorUpdated9.6.16
4/7
11/21/2016
Warning:StayAwayFromTheOfflineAssistantCompany&KevinOConnorUpdated9.6.16
LikePage
SignUp
SEE ALSO
Kevin OConnor Really Doesnt Want You To See This Video
So last night I got this from YouTube It seems Kevin OConnor from The Ofine
Assistant doesnt li...
Ep. 51: Two Drink Tim Podcast Being Sued For A Million Bucks By The Ofine Assistant
Company
Tim talks about being left for dead in Montreal, and how he is being sued for a million bucks by Ke...
Warning: Stay Away From The Ofine Assistant Company & Kevin OConnor
*** Update: Here is a video update of our on going dispute with Kevin OConnor and The Ofine Assi...
Ep. 31: Two Drink Tim Podcast Its 420 and Ill rant if I want to
http://newscentral.exsees.com/item/b1560d8881b99144ea1df496d6bd015cf82f0ba38e40c6f66e3f773a1f5f079a
5/7
11/21/2016
Warning:StayAwayFromTheOfflineAssistantCompany&KevinOConnorUpdated9.6.16
What do you do when someone you knew from 5 years ago suddenly appears back in your life and wants ...
Ep. 30: Two Drink Tim Podcast What To Do When A Dream Turns Into A Nightmare
In this episode Tim talks about the American Dream and how it is turning into a nightmare for those...
What. A. Weekend
Here are a few photos from my crazy weekend along with the important highlights
(if youre in a hur...
Ep. 43: Two Drink Tim Podcast Warning: Stay Away From The Ofine Assistant & Kevin
OConnor
This is a serious warning to stay away from Kevin OConnor and The Ofine Assistant. A recent expe...
http://newscentral.exsees.com/item/b1560d8881b99144ea1df496d6bd015cf82f0ba38e40c6f66e3f773a1f5f079a
6/7
11/21/2016
Warning:StayAwayFromTheOfflineAssistantCompany&KevinOConnorUpdated9.6.16
http://newscentral.exsees.com/item/b1560d8881b99144ea1df496d6bd015cf82f0ba38e40c6f66e3f773a1f5f079a
7/7
11/21/2016
Warning:DoNotUseTheOfflineAssistantCompanyUpdate8.21.16|
http://www.timothycastleman.com/warningdonotusetheofflineassistantcompanyupdate82116/
1/3
11/21/2016
Warning:DoNotUseTheOfflineAssistantCompanyUpdate8.21.16|
00:00
44:33
All content contained inside this video is a matter of public record and cause
#2016-519, 740 here in Lubbock Texas and does not violate any privacy or
trademark issues.
All parties involved were in the United States at the time of this dispute and as
such this content cannot and should not be removed or restricted (say in Ireland
for example) without court paperwork per YouTube Policy.
All court paperwork should originate from the United States as that is where
Kevin has sued my company.
All statements made in the video are the opinion of Tim Castleman, Castleman
Consulting LLC President and should not be taken as factual without doing your
own proper due diligence.
Finally, hug a lawyer, they need it.
Share the joy
Comments
0 comments
http://www.timothycastleman.com/warningdonotusetheofflineassistantcompanyupdate82116/
2/3
11/21/2016
Warning:DoNotUseTheOfflineAssistantCompanyUpdate8.21.16|
0Comments
Sortby Oldest
FacebookCommentsPlugin
PREVIOUS POST
N E X T POST
2016
PROUDLY POWERED BY WORDPRESS
THEME: MEOLA BY ELMASTUDIO
TOP
http://www.timothycastleman.com/warningdonotusetheofflineassistantcompanyupdate82116/
3/3
11/21/2016
Ep.51:TwoDrinkTimPodcastBeingSuedForAMillionBucksByTheOfflineAssistantCompany|
AUGUST 2, 2016
Tim talks about being left for dead in Montreal, and how he is being sued for a
million bucks by Kevin OConnor & The Oine Assistant Company
Share the joy
0
Shares
Comments
0 comments
0Comments
Sortby Oldest
FacebookCommentsPlugin
1/2
11/21/2016
Ep.51:TwoDrinkTimPodcastBeingSuedForAMillionBucksByTheOfflineAssistantCompany|
PR EV IO U S PO ST
N EX T PO S T
2016
PROUDLY POWERED BY WORDPRESS
THEME: MEOLA BY ELMASTUDIO
TOP
http://www.timothycastleman.com/ep51twodrinktimpodcastbeingsuedforamillionbucksbytheofflineassistantcompany/
2/2
11/21/2016
Warning:DoNotUseTheOfflineAssistantCompanybyKevinO'Connor
Feed
Search...
Register
Blogs
Community
Forum
Marketplace
Advertisewithus
HelpDesk
Login
Signup
Today'sPosts
Search
AdvertisewithUs
PostReply
Upvote
Subscribe
ViewFirstUnread
LinkBack
ThreadTools
SearchthisThread
9thDec2015,10:48PM
TimCastleman
#1
Warning:DoNotUseTheOfflineAssistantCompanybyKevinO'Connor
Shareon:
Gunslinger
WarRoomMember
JoinDate:2008
Posts:1,688
BlogEntries:34
Thanks:185
Thanked881Timesin333
Posts
OnNovember18th,2015duringaroutinereviewofourbooks,ouraccountantnoticeda$7,897.68errorcausedby
KevinOConnorsOfflineAssistantCompany.
WehiredKevinandhiscompanytofulfillourphysicalproductstoreordersanditturnsoutthattheyhadbeendouble
orderingandshippingourmostpopularitemtocustomersatourexpensefornounderstandablereason.
Oncetheerrorwasdiscovered,Iimmediatelyhadthelast100orderstheyhadplacedforusreviewed,andtherewas
an85%errorrateinthoseorderssowestartedtodigdeeper.
IimmediatelyletKevinknowaboutthisissuepersonallyandtoldhimIwouldgethimafullreportbythefollowing
Monday(thiswasFriday).
Wepulledourfinancialrecordsfromthestore,thesupplier,andmatchedthemtoourcreditcardstatementsforthem
togetafullaccountingofjusthowbaditwas.
Whenallwassaidindone,Kevinsemployeeshadoverorderedandshippedproductstothetuneofa
$14,968.45almostDOUBLEwhattheordersshouldhavecostandcostingus$7,897.68inprofit.
ArmedwiththisinformationIsenteverythingtoKevinandaskedhimtorevieweverythingandifthenumberswere
correctexplainwhynoneoftheorderswerecheckedbyhisprojectmanager(aspromisedwhenwesignedup)or
anyoneelseonisstaffforaccuracy,howhisemployeescouldseeuslosingmoneyoneverorderandnotsay
anything,andwhytheyhadntfollowedthespreadsheetdirectionswegavethem.
Whenhefinallyresponded3dayslater,heblamedusfornotcatchingtheerrorandcitedatrainingexampleorderwe
includedinthetrainingmaterials(ofatotallydifferentproductthantheonetheymisorderedabove)asareasonwhy
theyhaddoubledorderedeverything.
Excepttheyhadntdoubleorderedeveryitem.
Histeammanagedtoorderthecorrectquantitiesofotheritemswesoldindifferentamounts(1,2,4etc)withno
problem.
Whenconfrontedwiththis,hewentradiosilentandrefusedtorespondtoanymoreofmyemails.
ItwasonlyafterIdemandedrepaymentforthe$7,897.68errorthathefinallyresponded,andonlytotellmethathe
consideredthematterclosedonhispartandthatheandhisemployeeshaddonenothingwrongandthathewouldn
tbepayingforhisemployeesmistake.
Sohereswherewestand
Kevinscompanyoverorderedandshippedanadditional$7,897.68worthofproductstomycustomerswhich
Inowhavetopayoutofmyownpocket
Noonefromhiscompany(thatwehiredtomanagethisforus)reviewedanyoftheorderstoensuretheywere
beingdonecorrectlydespitehisassurancestheydoqualitycontrolandprojectmanagementonalljobs.
Therewasan85%errorratebyhisstaffinorderingproductsforus
Whenpresentedwithfacts(creditcardstatements,Shopifyprintouts,andAliExpressorders)Kevinstillrefused
toacceptanyresponsibilityandtothisdayhasrefusedtopaymebackforhiscompanyandemployees
mistakes.
Themoneypartstings,butherestheworstpart.
IfirstmetKevinwhenIandseveralothers(BradGosse,RonDouglas,E.BrianRose,BenLittlefield,BenAdkins,
ColinTheriot,MarkHelton,BrianAnderson,RyanMcKinney)werehismentorattheMarketersMansion.
Weallspenttimewithhimtryingtohelphimgrowhisbusiness.
IpersonallypromotedKevinnotonlytomylistviaawebinar,butalsothroughmypodcast(freeofcharge),andtold
severalbusinessassociatesabouthim(whoendedupsigningupwithhimrightLos).
JustlastmonthIdroppedeverythingwhenhecameintotownandshowedhimaroundLubbockandofferedtohelp
himevenmorewithhiscompany.
http://www.warriorforum.com/internetmarketingproductreviewsratings/1140478warningdonotuseofflineassistantcompanykevinoconnor.html?view=cl
1/4
11/21/2016
Warning:DoNotUseTheOfflineAssistantCompanybyKevinO'Connor
Andthisishowherepaidmeandeveryoneelsewhohelpedhimfordoingso.
Feed
Forum
Marketplace
Search...
Login
Signup
Noapology,noacceptanceofthefacts,andmostofallnotasingleoffertohelpusorcompensateustheseerrors.
IgottaassumethatwholepersonalresponsibilitythingGarretWhitepreachesdidntsinkinwithKevin.
Nowdontworryaboutme.WellbeseeingKevinincourtandwellgeteverycent(plussome)back
fromhim.
ImwritingthisposttowarnothersandsharemypersonalexperiencewithKevinOConnorandhis
company.
Ifyouchoosetousehimafterseeingthathedoesntstandbehindhisemployeeswork,haszeroqualitycontrolor
checkstoensureworkisbeingdonecorrectly,andnomatterhowmuchproofyouhaveoftheirmistakes,hewill
neveradmitwhenhisteamhasmadeamistakeorcompensateyouinanyfashionforthosemistakesgoahead.
Ifyouwanttohostawebinar,podcast,orinvitehimtospeakonstageafterreadingthis,thatsyourchoiceand
speaksmoretoyourcorevaluesthanmine.
Ijustrefusetohavepeoplewhohavehelpedhiminthepasthavetheirnameassociatedwithhimorhiscompany
withoutknowingthefactsaboutwhathedidtooureCombusinessandhisunwillingnesstostandbehindhisword
andhisemployeesmistakes.
Imjustthankfulthatwehavethecashreservestonotonlyabsorbthistemporarylossandbutalsopursueevery
legalrecourseagainsthim.
InclosingIllsharewithyouonelastthought.Sometimesinlifethingslikethishappen.Peopledisappointyou,
friendshipsend,andtruecolorsarerevealed.Whileyoucantcontrolwhenorwhythatstuffhappens,youcan
controlyourresponsetothosesituations.
Itriedtoresolvethisinprivate,IgaveKevineveryopportunitytomakethisright.Itwasonlyafterherefusedtodoso,
andIsawhowhugeofadisasterthiscouldbeforpeoplewhodonthavethesameresourcesIdo,thatIknewI
hadtogopublicwiththisissue.
TheFollowing8Users
SayThankYouto
TimCastlemanForThis
UsefulPost:
dotslash,EricWPM,Gregguitar,JamesCampbell,JohnRogers,SEOAgent,smilealot,WyteriaJacobo
9thDec2015,10:55PM
TimCastleman
#2
Re:Warning:DoNotUseTheOfflineAssistantCompanybyKevinO'Connor
Shareon:
Gunslinger
WarRoomMember
JoinDate:2008
Posts:1,688
BlogEntries:34
Thanks:185
Thanked881Timesin333
Posts
Alsobeforemodsgetpullhappyonthisthread...
ThisisareviewoftheserviceIpaidfor(Ihaveproofifyouneedit)andtheinteractionsIhadwiththeirowner(that's
whyheisnamed).
Ifthereisaproblemfeelfreetocontactme.Thanks.
TheFollowingUserSays
ThankYouto
TimCastlemanForThis
UsefulPost:
JamesCampbell
21stDec2015,01:38PM
Gregguitar
#3
Re:Warning:DoNotUseTheOfflineAssistantCompanybyKevinO'Connor
Shareon:
Improvementjunkie
WarRoomMember
OriginallyPostedbyTimCastleman
Alsobeforemodsgetpullhappyonthisthread...
JoinDate:2007
Location:Seattle,Wa.
Posts:1,441
Thanks:831
Thanked729Timesin449
Posts
ThisisareviewoftheserviceIpaidfor(Ihaveproofifyouneedit)andtheinteractionsIhadwiththeirowner
(that'swhyheisnamed).
Ifthereisaproblemfeelfreetocontactme.Thanks.
23rdFeb2016,03:00PM
carlstaff
WarriorMember
JoinDate:2012
#4
Re:Warning:DoNotUseTheOfflineAssistantCompanybyKevinO'Connor
Shareon:
http://www.warriorforum.com/internetmarketingproductreviewsratings/1140478warningdonotuseofflineassistantcompanykevinoconnor.html?view=cl 2/4
11/21/2016
Warning:DoNotUseTheOfflineAssistantCompanybyKevinO'Connor
Location:TrophyClub,Texas
zendesksupportforScaleSocialandamazinglythesellerhasdisappeared.Anyoneknowwhathappenedto
Posts:2
1
StrategicallySpilledMilk?AndofcoursemyrefundrequestforScaleSocialisatPaypalbecausethesellerwillnot
Feed
Forum
Marketplace
Search...
Login
Thanks:0
respond.
Thanked0Timesin0Posts
Signup
5thMar2016,09:34PM
atlantarobin
#5
Re:Warning:DoNotUseTheOfflineAssistantCompanybyKevinO'Connor
Shareon:
ReSourceRobin
WarRoomMember
JoinDate:2012
Location:MetroAtlanta
Posts:72
Thanks:178
Thanked142Timesin66Posts
7thMar2016,09:12PM
TimCastleman
#6
Re:Warning:DoNotUseTheOfflineAssistantCompanybyKevinO'Connor
Shareon:
Gunslinger
WarRoomMember
JoinDate:2008
Posts:1,688
BlogEntries:34
Thanks:185
Thanked881Timesin333
Posts
OriginallyPostedbyatlantarobin
ThishasNOTHINGtodowithRyMacsopleasetakeyourpitchforksandmoveonpleasetoyourownthread.
ThisthreadhaseverythingtodowithKevinO'ConnorandTheOfflineAssistantCompanyandthe$7,000theylost
duetopooroversightandinabilitytofollowthedirectionswesentthem.
Thanks.
Tim
23rdJul2016,02:55PM
BrentDotCom
#7
Re:Warning:DoNotUseTheOfflineAssistantCompanybyKevinO'Connor
ActiveWarrior
Shareon:
WarRoomMember
OriginallyPostedbyatlantarobin
JoinDate:2012
Location:Florida
Posts:76
Thanks:4
Thanked19Timesin16Posts
http://www.warriorforum.com/internetmarketingproductreviewsratings/1140478warningdonotuseofflineassistantcompanykevinoconnor.html?view=cl 3/4
11/21/2016
Warning:DoNotUseTheOfflineAssistantCompanybyKevinO'Connor
Search...
updatesonthesituationandwillkeepdoingsoasitunfolds.
1
Feed
Forum
Marketplace
Login
Hopethathelps!AndifyouknowofothersinthesameRyMacboat,pleasesharethiswiththem.It'sthe
leastwecandotohelpeachother.
Signup
PostReply
WarriorForumThe#1DigitalMarketingForum&Marketplace / InternetMarketingProductReviews&Ratings / Warning:DoNotUseTheOffline
AssistantCompanybyKevinO'Connor
Bookmarks
Tags
assistant,company,kevin,oconnor,offline,warning
PreviousThread|Top|NextThread
PostingRules
Youmaynotpostnewthreads
Youmaynotpostreplies
Youmaynotpostattachments
Youmaynotedityourposts
BBcodeisOn
SmiliesareOn
[IMG]codeisOff
HTMLcodeisOff
TrackbacksareOff
PingbacksareOff
RefbacksareOff
ForumRules
AdvertisewithUs
AlltimesareGMT6.Thetimenowis03:30PM.
TermsofUsePrivacyPolicyDMCANotice
WarriorForumisthe
world'slargestInternet
MarketingCommunity
andMarketplace.
S UP P ORT
FAQ
ReportAbuse
PrivacyPolicy
M ARKE TP LACE
WarriorSpecialOffers
TheWarRoom
WarriorForHire
COM M UNI TY
Advertisewithus
BecomeAffiliate
M ORE I NFO
Directory
Terms&Conditions
TheTeam
Contactus
R E L AT E D C O M P A N I E S
Freelancer.com
Escrow.com
http://www.warriorforum.com/internetmarketingproductreviewsratings/1140478warningdonotuseofflineassistantcompanykevinoconnor.html?view=cl 4/4