2024 0301 - Brief - Primerica - Primerica vs. Marco Moukhaiber - [Always Marco] - 58p
- 2024 0301 - Brief - Primerica - Primerica vs. Marco Mouhkaiber - [Always Marco] --- [BonkNote] --- 58p
- TABLE OF CONTENTS
- PART I - INTRODUCTION ............................................... 1
- PART II - SUMMARY OF FACTS .................................... 2
- PART III - ISSUES ................................................................ 4
- PART IV - LAW .................................................................... 4
- A. THE DEFENDANT MUST ATTEND IN EDMONTON FOR QUESTIONING ..... 4
- B. SCHEDULING ...................................................... 9
- C. THE ADMISSIBILITY OF THE DEFENDANT’S EXPERTS ....... 10
- PART V - CONCLUSION .................................................. 11
- AUTHORITIES ......................................
- 3 - 2. This action was commenced in July 2023, when the Plaintiffs obtained an injunction (the “Injunction Order”) directing the Defendant to take down and remove various defamatory videos and posts he created and posted to his social media accounts (the “Primerica Videos”).
- In the Primerica Videos, the Defendant asserts, among other things, that the Plaintiffs are “illegal”, a “fraud,” “scam,” “con,” “rats”, and “pyramid scheme,” and attacks and harasses some of the Plaintiffs’ sales representatives. The Primerica Videos constitute harassment and defamation, and violate the Trademarks Act, Copyright Act, and Competition Act. Justice Graesser granted the Injunction Order on July 24, 2023 on the basis that the Plaintiffs have a strong prima facie case.
- 3 - [Paid assassins - Left Country - Remote - Conduct Money]
- 9 - 19. Second, the Defendant has a practice of secretly recording video for his social media content to malign Primerica (and others). By way of illustration:
- He states at 1:00:05, “So I’ve done the in-person infiltration I’ve uh spied on several Zoom meetings and recorded those to get more like you know present day, accurate what’s being said in the company how are the leaders presenting it…”;29
- 10 - I did that multiple times and I was able to put put together a picture of what it is Primerica really does…”;30