LOS ANGELES, May 7 /PRNewswire/ -- A sworn Declaration made by former Stan
Lee Media, Inc. (Nasdaq: SLEEQ) Executive Vice President Stephen Gordon in
January and reported in the Industry Standard and other media in the US,
Europe and Asia, was corrected today in a "Further Declaration" made by Gordon
in a Los Angeles Superior Court action brought against Gordon & Paul by their
former attorneys. The declaration contained new information regarding the
activities of the current President and CEO of the internet-based public
company built around comic book icon Stan Lee.
While Gordon's Declaration retracted and corrected allegations that Stan
Lee Media Co-Founder Peter Paul had fled the United States, was the personal
target of an informal SEC inquiry, and was hiding assets, Gordon added new
information that he had learned from Stan Lee Media executives that the former
Sony Digital Studios President, Kenneth Williams, was involved in a plan to
"personally destroy" Co-Founder Peter Paul and to bankrupt Stan Lee Media in
order for him to personally acquire Stan Lee Media assets free of existing
shareholders and creditors.
Gordon's filing was made just days after Interfase Capital, LP, an Austin-
based venture capital firm, announced that it was providing debtor in
possession financing for Williams' operations during reorganization of Stan
Lee Media, which filed for Chapter 11 bankruptcy protection in February, 2001.
Interfase announced its plans to form a limited partnership that will
acquire a substantial equity position in the reorganized company, which will
be managed and co-owned by Kenneth Williams, according to insiders.
Following is the declaration of Stephen M. Gordon:
Stephen M. Gordon
14246 Valley Vista
Sherman Oaks, California 91423
In Pro Persona
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES
BUCHALTER, NEMER, FIELDS & YOUNGER a Professional Corporation,
STEPHEN GORDON; an individual; PETER PAUL, and individual; EXCELSIOR
PRODUCTIONS, INC., a California corporation; WORLD NETWORK, INC., a
Delaware corporation; and DOES 1 through 50 inclusive,
CASE NO. BC 241984
FURTHER DECLARATION OF STEPHEN M. GORDON TO CORRECT "DECLARATION OF
STEPHEN M. GORDON IN SUPPORT OF EX PARTE APPLICATION FOR WRIT OF
ATTACHMENT BY BUCHALTER NEMER FIELDS, et al."
I, STEPHEN GORDON DECLARES AS FOLLOWS:
1. I am over the age of 21 and a resident of the State of California. I
am a named defendant in the above-entitled action. Accordingly, the
following facts are true of my own personal knowledge and/or from my
review of the documents I received in connection with that transaction.
2. On January 21, 2001, I was requested by Jonathan Fink, Esq. to
execute a Declaration in support of Ex Parte Application for Writ of
Attachment against Peter Paul in connection with a lawsuit filed by BNF to
collect disputed legal fees from BNF's clients, Peter Paul and myself. I
executed the declaration prepared by Mr. Fink on behalf of BNF to support
his affidavits on file in this action. I have subsequently learned that
some of those facts Mr. Fink had me previously affirm in my declaration of
January 21, 2001 to be inaccurate and/or false.
3. I, therefore, file this affidavit to correct said facts and
4. I erred in representing that Peter Paul uses his wife to shield
assets and that Peter Paul represented she worked so he could hide income
through her. In fact, I knew that when I was first employed by Paul, his
wife had her own personal assets which were used to fund the company I
5. I knew that Peter Paul had no personal income to hide and that his
services were compensated through a lend out company, Paraversal, Inc.,
listed in all SEC filings by Stan Lee Media, and that, in fact, Andrea
Paul never received income intended for Paul. In fact, I knew Paul never
owned assets in his name the entire time I knew him because of a judgment
for $10 million recorded against him in the Southern District of Florida
by the Cuban Government under an unprecedented license to sue him given by
then President Jimmy Carter to the Cuban Government in 1979 for that
purpose, and, therefore, he never had personal assets to transfer or hide.
6. I erred in assuming that Paul's accountant, John Temple, had "set up
companies to help shield assets" for Paul. All companies which Paul
conducted business with in connection with John Temple were companies that
existed prior to Paul's dealings and were legitimately established by
Temple or his clients for legitimate and independent purposes unrelated to
7. I erred in characterizing Paul's change of business address from Los
Angeles to Brazil and Argentina as his fleeing the United States. I
subsequently learned that Paul has returned to the United States on more
than one occasion and is legitimately engaged in international business
while preparing for civil litigation against principals in various
companies, including San Lee Media, which he maintains has tortuously
terminated his consulting agreement. I also learned that Stan Lee Media
CEO Ken Williams has been the source of many news reports that libel Paul
and misrepresent Paul's actions as a Founder and consultant for Stan Lee
Media, and that Ken Williams has admitted to former Stan Lee Media
executives his objective to "personally destroy Paul, and to tortuously
interfere with Paul's relationship with Stan Lee to enable him to own the
principal assets of Stan Lee Media by using bankruptcy as a means to
eliminate creditors and shareholders of the company."
8. I erred when I stated that Paul informed me that the SEC was
investigating him personally, when in fact he stated that SEC began an
informal inquiry directed at Stan Lee Media and he was never presented
directly with any questions or subpoenaed by the SEC in connection with
his personal actions.
9. I erred when I represented that Paul and his wife had sold a lot they
owned for far less than its fair market value, when in fact said property
is and has always been owned exclusively by Mrs. Paul.
I declare under penalty of perjury of the laws of the State of California
that the foregoing is true and correct and that this declaration was
executed on May 2, 2001, at Beverly Hills, California.
Stephen M. Gordon
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SOURCE Freund & Brackey LLP