Declaration of Applicant Michael David Moore in support of Petition for Reconsideration.

I, Michael David Moore, declare and state as follows:

1. I make this declaration in support of C&R Late Petition for Reconsideration. The facts as set forth herein are true of my own personal knowledge, and if called upon to testify thereto, I could and would competently do so under oath. [Cite: Barttlett Hayrd Co., supra,203 Cal. at pages 532-536, Aliano, supra, 100 Cal.App. 3D at pages 366, 369-370. See also (A Formica Corp. v. Workers Comp. Appeals Bd. (1999) 64 Cal.Comp.Cases 1398), [late petition for reconsideration treated as petition to reopen where good cause shown.]

2. The C&R award was result of fraud. (Cite: A C&R may be set aside on the grounds of fraud. Intrinsic fraud is enough to set aside a C&R if the petition to set aside is filed within 5 years from the date of injury. (Johnson v. WCAB) (1970) 35 CCC 362, 369. Intrinsic fraud is a decept that relates to the original action and includes perjury. (Home Insurance Company v. Zurich Insurance Company (2002) 96 Cal.app. 4Th 17, 26).

3. The evidence does not justify the finding of fact, no evidence presented, no witnesses testified, SPE with held medical records, SPE did not conduct an investigation of Applicant's reported Injury. In fact, SPE Senior Executive Management, several Employees of the SPE HR Department, several Employees of the Spe Security Department Employees, several of Applicants former co-workers, Michael Zona a Doctor of Psychiatric Medicine and the Law Firm ROSEN & SABA, LLP, have been conspiring against Applicant, in an effort to conceal the fact the Senior Executives of SPE have violated numerous Laws and Statutes. [Cite: (Labor Code 5803 only requires good cause to allow the W.C.A.B. to rescind or revise an award.) ..Such cause may consist of newly discovered evidence previously unavailable, a change in the law, or any factor or circumstance unknown at the time the original award or order was made which renders the previous findings and award inequitable. (LeBoeuf v. Workers Comp. Appeals Bd. (1983) 34 Cal.3d 234, 241-242 (LeBoeuf).) More specifically, an award based upon a stipulation may be reopened or rescinded if the stipulation has been entered into through inadvertence, excusable neglect, fraud, mistake of fact or law, . . . or where special circumstances exist rendering it unjust to enforce the stipulation. (Huston v. Workers Comp. Appeals Bd. (1979) 95 Cal.App.3d 856, 865-866 (Huston). 5803 WCAB continuing jurisdiction: The appeals board has continuing jurisdiction over all its orders, decisions, and awards made and entered under the provisions of this division, and the decisions and orders of the rehabilitation unit established under Section 139.5. At any time, upon notice and after an opportunity to be heard is given to the parties in interest, the appeals board may rescind, alter, or amend any order, decision, or award, good cause appearing therefor. This power includes the right to review, grant or regrant, diminish, increase, or terminate, within the limits prescribed by this division, any compensation awarded, upon the grounds that the disability of the person in whose favor the award was made has either recurred, increased, diminished, or terminated.

4. Applicant went to the Executive Director of SPE Medical Department, Nurse Theresa Saporito, and asked her to help him file a Workers Compensation Claim for a Work Related Stress Injury on Monday August 3, 2009. Applicant was on the verge of having a Nervous, Mental and Psychological Breakdown. (Cite: Labor Code 5902) [The petition for reconsideration shall set forth specifically and in full detail the grounds upon which the petitioner considers the final order, decision or award made and filed by the appeals board or a workers' compensation judge to be unjust or unlawful, and every issue to be considered by the appeals board. The petition shall be verified upon oath in the manner required for verified pleadings in courts of record and shall contain a general statement of any evidence or other matters upon which the applicant relies in support thereof.]

5. Nurse Saporito, contacted SPE Human Resources Department Employee Abby Felder, Ms. Felder was the Human Resources Representative for the Telecommunications Department Applicant was a SPE Telephone man. Next Nurse Saporito, called the SPE Medical Doctor, at his private practice office, Dr. Steve Witlin. Saporito told Dr. Witlin, she was very concerned for Applicant due to his fragile Mental & Psychological State of Mind. She informed Dr. Witlin she would accompany Applicant to the SPE Human Resources Department, and would remain with Applicant until he was safely in the care of Dr. Witlin in his private practice office.

6. Applicant with Nurse Saporito at his side met with Felder in her office, Saporito told Felder; she was very concerned there was a possibly Applicant could suffer a Heart Attack or Stroke. Sapoprito while in Felder's office periodically checked his Heart rate and Blood Pressure and recorded his findings on paper, Applicant is in possession of said paper and can should Appeals Board grant his Petition for Reconsideration he will offer in evidence to the Honorable Court.

7. Applicant and Nurse Saporito were in Felder's office for 1 hour and , as Applicant told Felder of the Mental abuse inflicted on him over period of 21 years. He had been singled out by Mr. Jeffery James Grover the Executive Director of his department. Applicant was subjected to the humiliating and deplorable comments, remarks, derogatory comments about gays.

8. Felder about an incident which took place in November of 1994, Applicant had to fly to his home town in the mid-west, after he had received a 2:45 AM telephone call from a family member. He had been informed the younger of his two sister had committed suicide. She put into her mouth a .38 caliber pistol and pulled the trigger, she blew a large portion of her brain out the top of her skull.

9. When he returned to work, less than 5 minutes after he walked into the office. Mr. Grover began telling a story which any normal or rational Human Being could compare to something a sadistic sociopath would do, laughing he humorously told a story to Applicants former co-workers who were unaware and did not know a late co-worker had committed suicide 3 to 4 years earlier suicide by hanging. Hearing and listening to the laughter. Applicant did not loose his temper or say a word , he merely got up out of his chair and walked out of the office clock out and drove home. When Applicant returned to work the next day, Mr. Grover verbally remanded him, for having not asked or received his permission to clock out early and go home.

10. Felder asked, Applicant why did he wait for 21 years, if the mistreatment he alleges has been going on in the telecommunications department. Why did you wait until you were on the verge of having a nervous breakdown. Applicant said to Felder you have got to be kidding me, right after I made the statement, she did not ask what I meant by saying what I had said to her.

11. Instead Felder asked, if he intended to file a Lawsuit against SPE, Applicant assured and made it very clear to Felder that he had no intention what so ever of an Attorney involved. If he did involve an Attorney, he nor anyone could prevent what would be, the ultimate out come. The end of Sony Corporation because of what has been going on inside Sony Pictures Entertainment Inc., Applicant told Felder, he had been terrified for years at the thought of a Lawsuit being filed against SPE, because of what Mr. Grover has been known to do employees in the telecommuncations department.

12. Applicant told Felder, one Lawsuit against SPE because of Mr. Grover would cost Sony Pictures Insurance Company between $400 to $600 Million Dollars. It would be the end Sony Corporation, there would not be an Insurance Company in the World willing to RISK selling Insurence to Sony Corporation.

13. Felder was told, it's common knowledge among the SPE office and back lot workers and employees, if any worker comes to the SPE HR Department, to complain or file a complaint any supervisor, Manager, or department head. The complaining worker will find himself or herself out of a job. Applicant told Felder, he did not know of a one low level employee inside SPE who trusts the SPE Human Resources Department.

14. It's a known fact among the employees if you have got a problem with your supervisor, manager or department head. You had better just put up with it, shut up about it and deal with it in silence, because if you are foolish enough to walk across the street to Human Resources and file a complaint, whether it's complaint about sexual harassment, racial discrimination, hostile work environment, or if you were out right physically assaulted by your supervisor or department manager you are no longer employed at Sony Pictures.

15. Felder was told, in departments employee meetings employees are routinely told, so and so is no longer with the company. If it is found out that you have been talking with him or her, be careful, you may suffer, so and so's fate. The SPE standard warning given every time an employee leaves this company on bad terms. Every time this was said in my department I protested for the time I am on the clock, okay, but when I am not on the clock that is in violation of my 1st Amendment Constitutional Right of Free Speech, and that is a Federal Crime. Applicant told Felder, one day these violations of employees Constitutional Rights if it continues will hurt this company, Ms. Felder looked at Applicant as if he were an alien from another planet. 16. Applicant said to Felder, will you People in the SPE Human Resources Department for the first time since Sony has owned this Studio do your jobas you are suppose too. Your job is not to defend and protect incompetent management your are suppose to be protecting everyone who works for this Company. You are supposed to be protecting this Companies and it's Public Investors from unnessary and needless lawsuits. Just one incompetent department head like Jeff Grover can wipe out their investment and the Sony Corporation.

17. Applicant told Ms. Felder, by you protecting all of us who are employees of Sony Pictures, you are protecting all of the Employees of Sony Corporation. It does not end there Ms. Felder, if you and your co-workers do the Job everyone of you were hired into this company to perform. The you and your HR co-workers are protecting the lively hoods and welfare of employees and their families, people who you will never know nor will never know who you. That is what you are doing when you do the your job, you are protecting the welfare of MILLIONS of people around the World. Applicant told Felder it is beyond time for the SPE HR Department do right, send a message loud and clear to the employees on the back lot, they do not need to fear the SPE HR Department any longer.

18. Thursday August 6, 2009, Felder, asked Applicant to come to HR at 4:00 PM, SPE wanted him to meet with a Psychiatrist, a Dr. Michael Zona. Upon his arrival, Felder took Applicant to a HR conference room, a few minutes later Felder returned with Dr. Zona she introduced us then exited, Zona had in his hand the legal pad Felder wrote down the accusations Applicant had made against Mr. Grover. 19. Dr. Zona said; he had been hired by Sony Pictures as an independent consultant, to determine if the allegations were true or was Applicant an angry disgruntled employee, who was trying to cause trouble for his boss. Dr. Zona said; you have made some very serious allegations against Mr. Grover, any one of which, if proved true could result in his automatic termination, there that serious, he said. Applicant told Zona, he knows there serious and he knows if one of his co-workers confirms just one, he expects SPE to terminate Mr. Grover.

20. After 3 hours and 45 minutes, Applicant told Dr. Zona it was time to end the meeting so we can both go home, Zona agreed. He told Applicant; when he writes his report for SPE. he would state that Applicant is not angry, disgruntled, mentally unstable, threatening to any of SPEs employees. Applicant is however extremely and severely stress to the point of having a Nervous breakdown, and he is genuinely concerned for the mental health of his co-workers, and SPE should be highly concerned with Mr. Grover as a SPE department head.

21. Dr. Zona said; Michael do not under any circumstances wait for your Workers Compensation Medical Benefits, as it could take a week or more before your benefits to begin. He said; In my Professional opinion as a Doctor of Psychiatric Medicine, your Medical condition is so serious and so severe; I believe right now you are one thread away from having a Complete Nervous, Mental & Psychological Breakdown. It is my opinion as a Medical Doctor, if that thread breaks, I do not know if you will ever come back from it. Michael, I strongly urge you, find yourself a Doctor of Psychiatric Medicine tomorrow, so he can begin treating you immediately, that is how serious I believe your condition to be at this moment.

22. Applicant asked Dr. Zona; if he would take Applicant as a patient, he told; no it would be a conflict of interest. He referred Applicant to one of his colleges at his Newport Beach Medical Practice.As we were walking towards the exit, he blocked the doorway then said; I can not let you leave here tonight, until I get you answer two last questions. SPE wants your answer to these two questions. Say your co-workers confirm everything you have alleged against Mr. Grover is true but for some reason Mr. Grover is not terminated his is allowed to keep his job.

23. Zona said: God I can not imagine how that could happen not with all of these allegations, butsay there is a technicality, and for what ever reason Mr. Grover gets to keep his job. Could you come back and work for Sony Pictures again, and could you work for Jeff Grover again. Applicant looked at Dr. Zona, and could not believe what the man, had just asked. Applicant said; let me think a minute before I give you an answer.

24. Applicant told Dr. Zona; I have had to put up Mr. Grover and his harassment to the point I am about to have Nervous Breakdown and loose my mind for twenty years. I do not how there could be a miraculous technicality which could save him, from loosing his job. If there should be a miracle of some sorts, and he will know for a fact, he could not possibly get a second. Yes I could return to work again and If I had to I could work for Mr. Grover again. But the question Doctor Sony Pictures needs to have answered, can Jeff Grover, after he is made aware. Applicant was the person who went to Human Resources Department and complained about the way he mistreats and abuses his employees. Can Jeff Grover handle Michael David Moore working for his in his Department? On my drive home all I could think about, how in the World, it is possible for the Management of SPE to even remotely consider Insurance Fraud, when it is Sony Pictures Insurance Company will be documenting the Workers Compensation Claim I filed against SPE? [Cite: CIC 1871.4, sec (a), (1), (2), (3), (4), (b),(d)]

25. Applicant suffered a Nervous Mental and Psychological Breakdown on August 8, 2009 and was Hospitalized in the Psychiatric Ward of Long Beach Community Hospital. Applicant was released from the hospital three days later on August 10, 2009 fortunately the Nervous, Mental, and Psychological Breakdown was not as severe as Dr. Zona had predicted.

26. Mr. Robert Thompson, an ESIS Inc., Senior Workers Compensation Claims Administrator scheduled an appointment for a QME with Dr. Ismail Yassai, a Clinical Psychologist, August 18, 2009 Applicant attended his first secession with Dr. Yassai. The medical evidence was withheld from the Workers Compensation Appeals Board the Honorable Judge Janet M. Coulter. Defendant SPE did not conduct an investigation the Injury Applicant continues to suffer. [Cite: Bartlett Hayward Co., supra, 203 Cal. at pages 532-536; Aliano v. Workers Comp. Appeals Bd. (1979)100 Cal.App.3d 341, 366, 369-370 (Aliano) (petition for reconsideration not required where defendants failure to investigate and withholding of medical evidence good cause to reopen)].

27. Mr. Thompson called Applicant between the end of August 2009 and the first week of September 2009, he apologized for calling, as it had not yet 90 days since I had filed the claim against SPE. Thompson said; a situation has come up, he has never experienced with an Employer client. He asked Applicant if he knew or had heard anything about the Investigation, did I have any idea what was going on in that SPE HR Department. Thompson said; he started placing phone calls to SPE, after he receiving and reading Dr. Yassai's medical report, he was shocked, never in his career had he ever read a QME medical report on an Injured Workers, as discussing and vile as the report Dr Yassai had written on Applicant.

28. Thompson said 6 days earlier he wrote a letter to SPE, in that letter, he demanded, SPE send him a detailed written report every 2 days of the investigation SPE was suppose to be conducting on Executive Director Jeffery James Grover. I believe Thompson wrote in the letter that he was terrified as to the amount of money Mr. Grover would ultimately cost ACE American Insurance Company and it's Share Holders.

29. Thompson said; never has he had a situation or experience like this in all his years, as a WorkersCompensation Claims Administrator. He said; SPE owed him three reports, he called SPE three times to ask for the reports, he said; SPE is giving him excuses and each excuse SPE gives him is more lame than the previous excuse.

30. September 23, 2009, Thompson, called about 10:00 AM, he said; Michael, I have been a Workers Compensation Claims Administrator nearly twenty years, and as far as I know nothing like this has ever happened. Thompson said; I am sorry tell but wait any longer, yesterday I notified Risk Management at ACE American. They in turn immediately notified our Parent Company in Zurich, ACE LIMITED, the Chairman & CEO Mr. Evan Greenberg has called an emergency meeting. Mr. Greenberg along with many of the Senior Executives are flying during the night aboard a company aircraft, from Zurich to New York City.

31. There will be people flying from all over the World over night to New York City to attend the Meeting it will convene at 7:00 AM EST. He said; all I can tell you is what I was told to do. I was instructed to call and tell you will be receiving a telephone tomorrow very late in the evening. He said; I can not tell what time you will be called, I was to tell to make sure both you and Dale Swope need to be home when you get the phone call. He said; Mr. Greenberg will want to talk with both you and your partner Dale Swope.

32. The Chairman & CEO of CHUBB Mr. Evan Greenberg, chaired the only Emergency Meeting an Insurance Company has ever had to call or hold because of a claim filed by an injured worker against employer in the History of the Workers Compensation Program. September 24, 2009 in New York City at the ACE GROUP Headquarters two hundred to three hundred people if not more, flew from all over the World to attended the Meeting, the Board of Directors, the investors group, several private Millionaire and Billionaire investors, and Financial Companies who manage pension funds. This meeting was the result of the failure of SPE and it's Senior Executive Management Team obey the Rule of Law and conduct a proper investigation.

33. September 24, 2009 at approximately 8:30 PM PST the telephone rang it was Thompson he saidRobert Cusumano, Esq., the General Council of ACE LIMITED wanted to talk with Applicant. Mr. Cusumano said; Mr. Evan Greenberg will be speaking with Applicant in about 20 minutes, but first there first something that needed to be done. He said; ACE LIMITED was no longer going to wait for their client SPE to accept or deny Applicant's injury, ACE American accepts the injury. Robert Cusumano wanted both Applicant and Dale Swope to both retain to retain Attorneys for themselves the next day and have our Attorneys contact him. The retaining of Attorneys request made by ACE LIMITED was recorded by Robert Thompson and Robert F. Cusumano, Esq.

34. Mr. Evan Greenberg Chairman & CEO of ACE LIMITED spoke to me after the recording finished, he told me the recording was made by Insurance Company so his company could prove in Criminal Court ACE LIMITED the insurer did not try to get out of paying Applicant so much as a dime of what he was entitled to receive., for the injuries their client was responsible for inflicting on Applicant.

35. Even Greenberg said; the Senior Executive Management Team of Sony Pictures Entertainment Inc., are the most Despicable, Immoral, Unethical, Filthy, Dirty, Underhanded, Conniving and Pathetic Excuses for Executives. He said, the Crimes the SPE Executives have committed, Sony Corporation demise, rests squarely on the shoulders. Mr. Greenberg said: the Senior Executive Management Team Members, Michael Lynton, Amy Pascal, George Rose, Leah Weil, ESQ., are nothing more than COMMON CRIMINALS. They have run Sony Pictures Entertainment INC., as if they are an Organized Crime Family running the Crime Families Personal Business, they have VIOLATED nearly every one of the Federal & California State Labor Laws and Statutes. They have Violated countless Statues of the Securities and Exchange Act of 1934. Greenberg said; SPE had committed felony Insurance Fraud in violation of Cal Civil Code 1871.4. (Cite: 1871.4 (a), (1), (2), (3), (4).)

CIC 1871.4 (a) It is unlawful to do any of the following: (1) Make or cause to be made a knowingly false or fraudulent material statement or material representation for the purpose of obtaining or denying any compensation, as defined in Section 3207 of the Labor Code. (2) Present or cause to be presented a knowingly false or fraudulent written or oral material statement in support of, or in opposition to, a claim for compensation for the purpose of obtaining or denying any compensation, as defined in Section 3207 of the Labor Code.

(3) Knowingly assist, abet, conspire with, or solicit a person in an unlawful act under this section.

(4) Make or cause to be made a knowingly false or fraudulent statement with regard to entitlement to benefits with the intent to discourage an injured worker from claiming benefits or pursuing a claim.

36. Mr. Greenberg said, as a result of the Numerous Crimes they have committed, Sony Corporation will be out of Business tomorrow morning at 9:00AM EST, September 25, 2009. I with drew the Workers Compensation Claim I Filed on August 3, 2009 to save and protect Sony Corporation. Mr. Greenberg could not believe I stopped them from putting Sony Corporation out of business. and everything that was revealed to ACE LIMITED was in my sealed, I saved SONY from being put out of business on September 24, 2009.

37. October 2009 Applicant began receiving treatment from two Doctors, at Memorial Counseling Associates, in Long Beach. Dr. William Clark, MD, a Doctor of Psychiatric Medicine and Dr. Frank Martinez, LCSW, a Doctor of Psychology. Dr. William Clark retired shortly after and Applicant's treatment was continued by Psychiatrist Dr. Dharmesh Sheth, MD.

38. As of January 10, 2010 Applicant had not yet received a phone call from SPE, Applicant called Felder and ask Felder when the HR Investigation of Grover would be completed? Felder told Applicant, the Investigation of Grover, had ended 3 & 1/2 months earlier. Applicant asked Felder why he had not called and told the Investigation had been completed? Felder said, it had slipped her mind to call Applicant.

39. Felder told Applicant, she was happy to inform Applicant if he wants to return to work for SPE, he has a job to return too. Felder told Applicant, how Fortunate SPE wass to have such a dedicated employee, one who is so Loyal, Faithful, an Employee who had found the courage to have brought the matter of Executive Director Grover, to the attention of HR. Making it possible for HR to rectify the unhealthy work environment in the SPE Telecommunications Department. Felder said SPE was so grateful to Applicant, there would be a job at SPE for Applicant, until the day, he chooses to leave SPE.

40. Applicant said; good my co-workers have confirmed the allegations, I made against Grover, and he has been terminated. Felder, was silent, then said, just what Zona, said what he COULD NOT POSSIBLY IMAGINE, there was a technicality, SPE did not terminate Grover. Felder said; when Grover had been promoted to management, Grover had fallen through the cracks, and had not received, SPE MANAGERIAL TRAINING. Felder said the Legal Department had determined if he were fired, he could turn himself into a victim. Grover could file a Multimillion Dollar Law Suit against SONY PICTURES. The SPE LEGAL DEPARTMENT had made the decision, SPE would rather pay Grover through to his retirement, than to make it possible for Grover to file a lawsuit and become a millionaire at the Expense of SPE's Insurance Company.

41. February 18, 2010, Applicant went to former SPE Co-Chairman Amy Pascal he told her, Ms. Weil had for some reason thought it was in the best interest of the SPE to violate the Law. Applicant told Pascal, Evan Greenberg, had called an emergency meeting because of the Workers Compensation Claim and was going to turn the information the Insurance Compeny had become aware of over to both Federal & State Law enforcement to investigate SPE and Prosecute it's Management. Applicant told Pascal the only reason this did not happen was because Applicant withdrew his Workers Compensation Claim.

42. Applicant asked Pascal to inform Chairman Michael Lynton what Applicant had told her, and for the two of them to rectify the deplorable situations in the SPE Human Resources Department headed by EVP George Rose, the SPE Legal Department headed by Leah Weil, Esq., and for them to terminate Executive Director Jeff Grover.

43. February 23, 2010 Applicant received a phone call from HR Vice-President Gaston Ivan Bitar, who asked Applicant to come to see him and a Psychologist in the HR conference room, because SPE wanted to understand what were the problems Applicant was having with Grover and SPE. Two & one half hours Applicant explained to HR Vice-President Bitar and the Psychologist with him for a second time what he had suffered at the hands of his department head Jeff Grover.

44. Bitar told Applicant he would have Mr. Grover in his office the next day and make it very clear to him, if HR received one more complaint from Applicant about Grover he would be terminated on the spot. Bitar also told Applicant HR would periodically check with him to make sure Mr. Grover did not ever again violate Applicants rights as a SPE employee. There was no HR follow up conducted, and as of September 2010 Applicant was told by HR employee Cathy Marlowe as well as others that Gaston Ivan Bitar and Abby Felder were no longer employed with SPE, they had both left the company. For five and one half more years Mr. Grover continued harassing and mentally abusing Applicant, he complained and his complainants were ignored. Applicant felt totally trapped knowing what would happen to Sony Corporation if he were to file another Workers Compensation Claim against SPE. Applicant knowing the share holders would loose every dollar they have invested as well as every person employed by Sony Corporation and it's Subsidiary Companies would become jobless compounded the stress and mental anguish Applicant already suffered.

45. Applicant's depression had got to the point, he could bare the thought of getting out of bed and going to work. He would stay in bed for days at a time, the loss of his income and mounting debt, caused him to slip into Deeper Depression, and he was forced to short sell his home in June 2012, because he was facing a Foreclosure. Applicant stopped taking the medication to treat his HIV. He prayed nature take it's course and get him the out of this misery.

46. August or September 2012, Sony Pictures issued Apple-I phones, Applicant thought there was a problem with his, as he would often receive a text message, it read: S: UPDATE I.T. Disruption Please Read message then reply with YES and send.. Each time he did as the message instructed, his text messages, emails, and phone call record, would be blown out, of his phone like a factory reset. He would have to get his phone reloaded with the work contacts he needed to preform his job. This happened a dozen or more times, each time, Applicant was told, he must be doing something incorrect for this to happen to his phone. 47. Applicant showed the message to co-workers Mark Pacheco, Patrick Patchen, Michael Groe, he asked if they ever received the message, none of them, had ever seen or received such a message. Applicant realized, anytime he had a conversation or sent a text message about his 2009 Workers Compensation Claim, he received the message, he never again responded to the message. He received the message several times after the November 24, 2014, HACKING of the SPE IT Mainframe. 48. October 2014, Applicant felt as if he was on the verge of having a Second Nervous Break Down, on October 3, 2014 Applicant decided to contact Dr. Zona, he wanted to ask the Doctor of Psychiatric Medicine how it was he could take a bribe, when he knew what Grover had done. Applicant wanted to tell the Doctor, because of what he had done Applicant still continues to suffer Mentally, Emotional, and Psychologically 49. Applicant used Google to get the telephone of Dr. Zona's medical practice in Newport Beach, CA., Applicant discovered Zona closed his Newport Beach Practice, and is Practicing in Boulder, Colorado. Applicant using his Sony Pictures issued Apple-I Phone, sent Dr. Michael Zona a text message on October 3, 2014 at 10:30 PM, it reads: "Hello Dr. Michael this is Michael Moore from Sony was just talking to a friend about the past you doing ok". The text message was read by Dr. Zona on 10/4/14, forty-seven days after Applicant sent the text message to Dr. Zona, he was railroaded out of SPE. Dr. Zona, is the first of many who have been bribed by the Executives of Sony Pictures, in an effort to conceal the multitude crimes they have committed against Applicant. 50. Monday November 10, 2014 Applicant called Amy Pascal, he was crying and could barely talkhe Pascal to help him find a way out of this company SPE. He told her if he remains in the Basement with the people he has to work with, he will end up dying in the basement. He asked her to find him a way for out, because SPE is killing him. Applicant told Pascal, they can have SPE, he just wanted out so he and his partner could save want they had left of their lives. Pascal did not ask Applicant one question, what was wrong with him, or if he needed any medical assistance, not a one question. Pascal said; she would have her assistant call Human Resources, to find out if there was anything HR could do for him, then she hung up the phone. It was the last time, he and Pascal have spoken with one another.

51. Tuesday November 11, 2014, Applicant received a phone call from Zack Hall an SPE HR rep,he asked Applicant to come to his office, on my way to see Zach Hall, Applicant crossed paths with SPE IT department SVP Ferdinand Fattorini and the new head of SPE Telecommunication Department VP Tom Curran. Applicant told them he wanted to give them a heads up. He wanted them to know, he intended to see Amy Pascal, to have a conversation with her concerning a personal problem he was having, which neither were aware in case they got a phone call from Pascal or someone in her office. He said; he did not want them to be caught off guard and blindsided if they did get such a phone call.

52. Applicant had a 10 to 15 minute meeting with Zach Hall in his HR office, Hall told Applicant, he did not know why Amy Pascal thought HR could do anything for because Applicant, who was a Union Member. Hall said; Applicant would have to contact his Union, and find out if the Union could help him.

53. November 13, 2014 Applicant and VP Curran met in his office in the Thalberg Building, he asked Applicant what was wrong with him? He told Mr. Curran, Jeff Grover had been harassing him for over 26 years, that he could not take it anymore, Curran was thoroughly disgusted after learning what had been taking place at SPE. He said; he would talk with Fattorini, he would find out, what could be done to help Applicant retire if he wanted. Applicant told Curran he did not want to retire, but he did not know what else he could do, as SPE had done nothing about Grover and his harassment of Applicant. Curran said; Fattorini would contact Applicant by Friday, if he didn't, he would make sure someone contacted Applicant.

54. Applicant was leaving work Friday, when he received a phone call from Curran and CynthiaHubbard, Applicant was told there was going to a meeting next week, and he would receive an email from Julie, Fattorini's assistant. Tuesday, November 18, 2014, Applicant received a text message from Julie at 10:50 AM it read, A meeting invite had been sent to u, Applicant called Julie, she told him scheduled to attend the meeting were, Hubbard, Fattorini, Curran, and Applicant. Julie said; Applicant could invite anyone to the meeting if he wanted too. Applicant asked Michael Groe his foreman to attend, Groe told him he did not want to get involved. 55. Applicant called Michael Groe later that evening, he asked Groe to attend the meeting so he could hear himself what was said during the meeting, that way Groe would not anything second hand. Groe said, he would only attend if Tom Curran asked him or wanted him to attend. Groe told Applicant he received a telephone call from IBEW Local 40, and he was told Applicant had not been a member of the Union for years. Applicant asked Groe if he found it peculiar or odd Local 40 just informed him of that fact, Applicant stopped paying Union dues after the business agent of his Union refused to file a grievance against SPE on Applicants behave before he filed the Workers Compensation Claim against SPE.

56. November 19, 2014, Applicant called Tom Curran and told him Groe would not attend the meeting unless Curran asked him to attend the meeting. Curran called Groe and told him to attend. The meeting was held in Curran's Thalberg office. VP Ferdinand Fattorini said Cynthia Hubbard would not be attending he then told VP Tom Curran he could not attend the meeting and Fattorini literally shooed him out of his office. Applicant protested he told Fattorini, he wanted VP Tom Curran in the meeting. Fattorini said, it is easier to get things accomplished with fewer people involved, again Applicant told Fatorini, he wanted Curran to attend the meeting, Fatorini said no he. Applicant told Fattorini, he did not like the idea someone he invited was not allowed to attend or hear what was going to be discussed. Fattorini said; to many people in the meeting just complicates what Michael Moore needs so can get on with his life. 57. Fattorini said; this meeting is all about what Michael Moore needs and what Sony Pictureswants to help him, so he can get on with his life. Applicant told Fattorini, Sony Pictures could start by HONORING the commitments Amy Pascal and Gaston Bitar had made to Applicant. He told Fattorini that Amy Pascal made a commitment in February 2010, Pascal told Applicant, he would leave SPE on his terms when he decided he was ready to leave SPE. Pascal told Applicant so long as she was Co-Chairman of SPE he had her word of Honor, Pascal is not living up to that commitment. Applicant told Fattorini; on February 23, 2010, in the presence of a Psychologist SPE hired as a consultant, HR Vice-President Gaston Ivan Bitar told Applicant if he made one more complaint to HR about Jeff Grover harassing him, Grover would be terminated immediately, Sony Pictures has not HONORED one commitment made to Applicant. 58. Applicant told Fattorini, Executive Jeff Grover's contract was not renewed ending his employment at SPE, it upset Applicant Grover was allowed to return to SPE as a Union Technician and work in the telecommunications crew and he continues harassing Applicant. Applicant asked Fattorini if he had facilitated Grover's return to SPE with the Union, as Grover told Groe he had, Fattorini said no he had nothing to do with Grover returning to SPE. Fattorini said; what Jeff Grover had done to Applicant in the past, was just that, in the past. He said; Grover is no longer an employee of Sony Pictures, any injury Applicant may have suffered in the past, is no longer a concern or responsibility of Sony Pictures. Applicant told; Fattorini, if the position of Sony Pictures is Grover is an employee of the Union, then this meeting is over, because Applicant does not want to retire, Michael Groe can deal with Jeff Grover and terminate him. 59. Applicant told Groe, you just heard for yourself Fattorini say; he did not know or have anything to do with Grover returning to SPE. You now know, Jeff Grover invoked Ferd's name when he lied to you. Applicant asked Groe call Jeff Grover into his office and fire him terminate him. Groe looked at Applicant then looked at Fattorini, then just set in his chair and did nothing. Fatorini said this meeting is not about Jeff Grover, it is about what Michael Moore needs to make him happy. He said; Sony Pictures only wants to help Michael Moore so he can get on with his life and be happy. 60. Applicant told Fattorini, he wanted to be able to come to work without being harassed, however since that is not going to be the case, his only option is to retire, but before he retires he needs to file Bankruptcy in order to protect his pension for his partner and himself. He told Fattorini, he also would have to be sure he would qualify for Social Security Disability, that would be the only way he could consider taking an early retirement, if he doesn't he can not retire early.

61. Applicant received a phone call about 6:30 PM that evening from HR employee Cynthia Hubbard and Ferdinand Fattorini, Applicant was told, they had good news for him, a retirement package had been put together. Fattorini said, Donna Miller in payroll had been asked to come up with a figure of how much back pay was owed to Applicant by Sony. Jeff Grover had wrongfully denied Applicant work in 2013 the amount owed was $17,434.34, Fattorini said; Sony Pictures had graciously doubled the amount to $34,868.68 less taxes. Ferdinand Fattorini told Applicant to take the rest of the week off with pay, he did not need to return. 62. Applicant told them, they were moving way to fast, he needs file for bankruptcy, he needs to find out if he will qualify for Social Security Disability. Applicant told them, he wanted some time to make sure he would be financially secure, he was not given any time. He asked Cynthia Hubbard, if he would be allowed to say goodbye to his friends on the Studio Lot Hubbard said he could. He also asked Hubbard if he would be allowed to visit the Studio Lot from time to time, as a retired employee?, Cynthia Hubbard said yes. 63. Cynthia Hubbard called Applicant Friday November 21, 2014 she had to attend a meeting, inthe Thalberg building, she told Applicant to meet her at 4:00 PM to her a text, and let me know when to meet in the Telecommunications Shop in Thalberg basement. She said she had a copy of the separation offer to review that Applicant could make a counter offer if he choose too.

64. At 4:58 PM, November 21, 2014, Applicant called Donna Miller in payroll and had a 60 minuteconversation with Miller who knew about the Workers Compensation Claim Applicant filed and why. Donna said she could not understand or believe what SPE was up too. Applicant told Donna, he called Pascal's office was waiting for a phone call from Pascal. He wanted to talk to her about the offer he received from SPE, Applicant waited for an hour and a half for Amy Pascal to call, she did not call, as he was told she would.

65. Applicant called Pascal's office at 6:26 PM, he had a 16 minute conversation with an assistantof Pascal's, he told the assistant to make sure Pascal got his message he wanted to talk with her about the offer he received from SPE. He was not at all happy about the offer SPE had made and he would see her on Monday because he wanted to talk to her about the offer after what he had done for Sony Corporation. He wanted to introduce her to Groe since it was obvious he would retiring whether he wanted to or he did not want to retire.

66. Sunday, November 23, 2014, at 11:16 AM, Applicant received a text message from Cynthia Hubbard, she said: Have a nice day and I will see you two gentlemen tomorrow. I'll call you direct when I find out the checks are ready.. Monday, November 24, 2014, about 7:30 AM give or a few minutes Applicant called and left a voice mail message for Cynthia Hubbard's on her office phone. Applicant said; Cynthia I have changed my mind I am not going to sign a release for $34,753.00 less taxes considering, I have decided to make after all. Here is if SPE releases to me the money on the table and gives me a contract terms of which Amy Pascal and I will negotiate put in writing no later than December 15, 2014, then I will sign a release for everything from that date back. Call me and let me know what you find out.

67. What took place after the voice message to Hubbard, Mike Ornelas called my partner Dale Swope's cell phone and left him voice mail message. Mr. Ornelas told Dale to have Michael Moore call him at 310-384-2814 in the SPE security department. When Applicant called Mike Ornelas, he told Applicant he had his final checks, and he would meet Applicant some where outside the studio once the release is signed he was authorized to release the checks. Applicant asked Mr. Ornelas why did he have the checks, and not Cynthia Hubbard who is handling Applicant's leaving Sony Pictures. Mr. Ornelas said, "Cynthia Hubbard is no longer involved with Applicant's departure from Sony Pictures, Applicant's departure is now a matter for the Security Department to handle. Then he said there will be no new contract negotiated between you and Amy Pascal. Applicant asked Ornelas how did he know about a new contract since the Phone system is down if the network is down, Ornelas did not have an answer.

68. SPE's Conspiring Senior Executives with the aid of their Co-Conspirators took advantage of the fact Applicant was having a Mental, Nervous, and Psychological Breakdown and forced him to retire on November 19, 2014. Applicant called the home of Amy Pascal's parents and spoke with Anthony H. Pascal on Thanksgiving night November 27, 2014. He asked Mr. Pascal to have his daughter Amy call Applicant as soon as possible, it was urgent that Amy call Applicant. Pascal did not call Applicant, SPE instead retained the law firm Rosen & Saba, LLP to write Applicant a cease & desist letter dated December 2, 2014, the letter was hand delivered to Applicant at his home on December 2, 2014 by SPE Security Department Employees.

69. After the cease and desist was delivered, Dale Swope Applicants domestic partner made two telephone calls to Bobby Benson, Benson was Executive Assistant to SPE General Council EVP Leah Weil, Esq., Swope asked Benson if she would tell Weil Applicant thought Cynthia Hubbard an employee in the SPE Human Resources was relatiating against Applicant for having filed a Workers Compensation Claim against SPE in August 2009 and for having made another complaint against Executive Director Grover. He asked Benson to have Weil call Applicant, Weil did not return a phone call.

70. Applicant called Joshua Schein, Esq., between 11:00 AM and 12:00 PM on February 23, 2015 eighteen days after SPE announced Amy Pascal would be stepping down from her position as Chairman of Sony Pictures Entertainment in mid to late May 2015. He told Mr. Schein his clients had forced him into retirement and Applicant would not qualify for Social Security. He told Schein he was afraid if his Workers Compensation Claim was reopened Sony Corporation would be put out of business. Mr. Schein ignored Applicant's warning about the Workers Compensation Claim, he told Applicant his association was over and in the past. Schein warned Applicant not to call anyone at SPE ever again, if he did, SPE would use the Califoria Superior Court to punish Applicant anyway SPE could under the Laws of the State of California.

71. February 23, 2015 Applicant also called General Council EVP Leah Weil's office, the call was answered by an unfamiliar voice not known to Applicant, he asked the person who had answered, if Bobby Benson was off work or out sick that day. He was told Bobby Benson had retired, this came as a surprise to Applicant, as Ms. Benson had told Applicant on Friday November 14, 2014, it would be at least five years before she could think about retiring. Applicant asked the person who answered to give his telephone number to Benson, because Benson was friend and he wanted to call her, she said she would pass Applicant's phone number to Benson. Applicant asked to speak with Weil, he was told Weil was not available and was asked if he wanted to leave a message for Weil which he did. Weil did not return his phone call. Instead Applicant received a second cease and desist letter dated February 23, 2015, it was delivered to him at his home on February 24, 2015 via Fedex.

72. February 24, 2015 SPE announced Pascal stepped down and was replace by Mr. Tom Rothman as Chairman of Sony Pictures Film Division. Pascal stepped down from her position three months earlier than mid to late May date as SPE had announced in a press release February 5, 2015. [Cite: New York Times 5/5/2015 Amy Pascal stepping down. She will leave her positions as co-chairwoman of Sony Pictures Entertainment and chairwoman of Sonys motion picture group in May, the studio said, and accept a four-year production deal that will involve her making some of Sonys biggest planned films.] 73. March 25, 2015 Joshua D. Schein, Esq., appearing on behave SPE in department CE75 before Judge Carol Boas Goodson sought and was granted a Work Place Violence Restraining Order. Mr. Schein has since sought four additional Restraining Orders two of the RO's were granted and two were denied. SPE has been conspiring against Applicant since August 3, 2009 when he filed the Workers Compensation Claim ADJ9935251 against Sony Pictures Entertainment Inc. SPE has paid bribes to a number of individuals since August 6, 2009 when SPE paid a Bribe to Dr. Michael Zona.

74. June 2015Applicant had a second Nervous Mental and Psychological, he was released from the Del Amo Mental Health Center he could to pay for Medication or any follow up treatment. Applicant who is a Honorablly Discharged Veteran of the U. S. Navy recently began receiving treatment from a Veterans Administration Doctor of Psychiatric Medicine.

75. At the time Applicant executed the C&R he was under duress and suffering severe emotional distress, Applicant and his Domestic Partner owing four months back rent to their landlord Mr. Mark Foley. He could not afford to carry them any longer was going to have them evicted. Applicant and his partner had been homeless as a result of SPE actions. Applicant and his Domestic Partner Dale Swope are both HIV-Positive and are not in good health. Applicant feared if he did not execute the C&R so he could pay the four months back rent they owed to their landlord, homelessness could easily result in the lose of his or his partners life.

76. Applicant had contacted several Workers Compensation Attorneys, none of the Attorneys would represent Applicant, the Attorneys he had contacted told Applicant he did not have a claim as the Statue of Limitations had long ago expired. In April 2015 Applicant's Workers Compensation Claim was voluntarily reopened by ACE AMERICAN INSURANCE COMPANY and TOKIO MARINE INSURANCE COMPANY. Applicant met Attorney W. Lynne Brown, Esq., at the Long Beach Appeals Board he was a Mental Wreak at the time. Ms. Brown, Esq., agreed to represent Applicant, she had him call her assistant to schedule an appointment.

77. Applicant met with Lynn Brown, Esq., in her Torrance Law Office, when told Ms. Brown his former employer was Sony Pictures. Ms. Brown informed Applicant due to a conflict she could not represent him, her Brother-in-Law is an employee of his former employer Sony Pictures Entertainment. Applicant had a panic attack in Ms. Brown Law office, when she told Applicant she could not represent him.

78. Applicant through no fault of his did not have Legal Representation, at the time he entered into the C&R settlement. He lacked the Mental Capacity to make a reasonable or rational decision for himself and was Ignorant of his Legal Rights as an Injured California Worker.

79. Sony Pictures Entertainment Inc., employees and former employees Chairman Michael Lynton, former Co-Chairman Amy Beth Pascal, Leah Weil, Esq., Abby Felder, EVP George Rose, VP Gaston Ivan Bitar, Joshua D. Schein, Esq., Lissa Freed, Ariya Watty, Chairman Tom Rothman, VP Mike Ornelas, Marcelo Rodriguez, Michael Groe, Cythia Hubbard, Mary Burke, Esq., Jeff Grover, Dr. Michael Zona, Mark Pacheco, Ruth Ollie-Wright, Lucienne Hassler, Peter Jordan, Theresa Saporito, Leonard Venger, Daniel Fisher, David Handler, Doug Belgrad, Dwight caines, Ferdinand Fattorini, June Rosales, Gaudenico Robledo, Carolyn Hardiman, Paula Askansas, Steven Mosko, Stuart Zimmerman, Donnie Harris, Ryan D. Saba, Esq., Momo Takahashi, Esq., Elizabeth Bradley, Esq., Maria Starn, Esq., Amber Scott, Esq., Baeza Mejia, Esq., Noami Pacheco, Nydia Rivera, Krystle Meyer, Esq., Tyler Vanderpoole, Esq., Jonathan Dennis, Esq., Nathalie Rosen, and Hoia Scott have knowningly, willfully and freelly aided and abetted one another in a conspiracy, [Cite: CPC 182(a)] to deny Applicant his Workers Compensation benefits for the Nervous, Mental, and Psychological Stress Injury intentally inflicted on Applicant and he continues to Suffer as a result of this Injustice. [Cite: CIC 1871.4 (a),(3) Knowingly assist, abet, conspire with, or solicit a person in an unlawful act under this section., CAL Penal Code 182(a)]

California Penal Code 182(a) describes conspiracy as two or more people planning to commit any crime. In order to be convicted of conspiracy in California, the prosecutor must show: 1. That you planned to commit a crime with at least one other person 2. That at least one of you committed an overt act to further the crime even if that act isnt a crime

80. Applicant through personal knowledge and evidence is of the believe and therefore alleges Michael Lynton, Amy Beth Pascal, George Rose, Leah Weil, Esq., are personally responsible for the November 24, 2014 Sony Pictures IT Mainframe Hacking the FBI and President Obama blamed on the North Korean Terrorist Group known as the GOP. Applicant is of the believe it was emails the Senior Executives sent to one another when they made their decision to conspire against Applicants Workers Compensation Claim and the manor and details which caused injury to Applicant.

81. Judge Lisa Hart Cole on November 3, 2015 signed Warrants sought by an Investagator of the Los Angeles County District Attorneys Office for a High Profile Criminal Investagation and for a Detective from the Gardena Police Department who Investagated the possible July 4, 2014 attempted murder of Applicant. Judge Carol Boas Goodson also signed Warrants for the same individuals on November 12, 2015.

82. On November 19, 2015 at the Stanley Mosk Courthouse in Department CE 2C, Judge Carol Boas Goodson presiding, Tyler Vanderpoole sought a Work Place Violence Restraining Order against Applicant for Rosen & Saba, LLP and Employees of Rosen & Saba, LLP. Judge Carol Boas Goodson without Applicant making an appearance to show cause, denied the protective order.

83. A Crime report was taken by an FBI Agent on June 25, 2016 during a 1 hour 41 minute telephone conversation Applicant had with the Agent in the FBI's White Collar Crime Section. The Culver City Police Department had refused to take a Crime Report from Applicant on three separate occasions, June 25, 2016 being the third occasion. Applicant has since had a two follow up telephone conversations with two other Agents of the FBI. Applicant also has also had a conversations with Gardena Police Det. Goodpaster and with an Investigator in the Los Angeles County District Attorneys Office.

I declare under penalty of perjury pursuant to the laws of the State of California that the foregoing facts are true and correct. Executed on September 28, 2016 at Gardena, California.

__________________________ Michael D. Moore