2024 0503 - LC - Affidavit - Kelly Marier - Primerica - Primerica vs. Marco Moukhaiber - [Always Marco] - 29p

  • 2024 0503 - LC - Affidavit - Kelly Marier - Primerica - Primerica vs. Marco Moukhaiber - [Always Marco]  ---  [BonkNote]   ---   29p
  • 2 - 3. Mr. Moukhaiber has posted to YouTube the following videos, relating to or referencing Primerica and this proceeding (the “New Primerica Videos”).
  • 1-2 - 2. Counsel to the Plaintiffs sent an April 18, 2024, letter to Avnish Nanda, Counsel for the Defendant regarding the New Primerica Videos, as defined below. One of the attachments to the letter contained a screenshot that showed the Discord account handle belonging to an Osler employee (“green_dinosaur15”). Attached as Exhibit A is a copy of the April 18, 2024, correspondence.
    • 3 - 5. I am informed by green_dinosaur15 that when they went to access Multi-Level Marco on April 22, 2024, they had been blocked. Attached as Exhibit C is a screenshot of green_dinosaur15's blocked attempt to access Multi-Level Marco.
      • 5 - Letter - April 18, 2024 - In contravention of the Order, Mr. Moukhaiber has: (i) indirectly referenced Primerica in his YouTube videos by, inter alia, referring to “a company he cannot say”, a company that is “primarily American” or a girl in her “prime” named “Erica”, referenced the litigation, and referenced my team as “assassins”; (ii) directed viewers to his Discord channel so that they may access the reposts of the “Infiltrating a Pyramid Scheme: Primerica” video; (iii) allowed members of his Discord channel to post discussions about this litigation, mentioning Primerica by name; (iv) misled viewers to believe that Primerica is harassing or has harassed Mr. Moukhaiber at his home, gym, and relatives’ homes, particularly in the “I’m Leaving Canada” YouTube video; (v) misled viewers to believe that his personal safety is at risk as a result of the conduct of Primerica or its counsel; and (vi) misled viewers that these proceedings is causing him financial hardship.
  • 6 - Impact of the video, “I’m Leaving Canada”, January 4, 2024 - Reddit Thread
    • User HuntsmansBoss posted: “As someone who worked in Primerica’s home office (the US one, not the Canadian one) I’m not surprised. He probably pissed off someone with a huge base shop (their word for pyramid) so they sent their minions after him. Some of them have literally hundreds of people in their downlines & the downlines are brainwashed enough to do what the upline says.  --- They’re literally a cult. It’s terrifying” • User AudreyFish posted: “Holy shit what?? These Primerica people are NUTS. Time to lawyer up dude.”
    • Further examples are attached.
  • 8 - April 7, 2024: Live Stream “The Time Chris Hansen Exposed Amway”
    • Mr. Moukhaiber then follows with a section titled “MLM Hush Money”, in which he states: • 1:15:33: “I am the first person who… I can’t say too much but let me tell you… this trend of MLM companies just being able to buy peoples silence or hide it under the rug and continue to pay for the privilege of it not being exposed, it’s over. At least its coming to an end.” He then goes on to describe the hypothetical process of negotiating a settlement with an MLM, describing negotiated settlements as “hush money”.
    • 1:23:04: “if a video, hypothetically, were to come out that was made by an individual person who hypothetically worked on it for six months hypothetically, and it came out and became one of the biggest pieces of MLM content in history. And it was only up for let’s say, a little over a week and it got nearly a million views despite the platform it was posted on being a very small platform and it was just an astronomically big video that got an unheard of amount of views for a creator of that size, hypothetically, then they may, hypothetically, take action against that person and that person will have to make a choice eventually, am I going to fight, and prove and pull the mask off of the Scooby doo villain and show the world the truth? Or am I going to be faced with the decision of taking the hush money. We’ll see.”
    • 1:27:34: “nobody has ever done what I’ve done in terms of getting the pressure put on them, getting the harassment, getting the private investigator showing up at my home or whatever, and adapting by going to another part of the world and not folding. No one has every puffed their chest out like me and that’s a fact”.
  • 5 - April 14, 2024, “The Time I Fell for a Kevin O’Leary Scam”
    • At 18:25, Mr. Moukhaiber refers to my team as “assassins.” Then at 26:00, warns his followers that if anything happens to him, it likely has to do with the “situation”, implying that Primerica or my team pose some kind of risk of physical harm to him, which is defamatory, and absurd.
    • [Bonk: Senator Howard Metzenbaum]
    • [Bonk: A.L. Williams - "I wish you were there..."