Electronically FILED by Superior Court of California, County of Los Angeles on 08/01/2019 04:20 PM Sherri R.

Carter, Executive Officer/Clerk of Court, by E. Gregg,Deputy Clerk

1 AKIN GUMP STRAUSS HAUER & FELD LLP

SUSAN K. LEADER (SBN 216743)
2 sleader@akingump.com
REBECCA A. GIROLAMO (SBN: 293422)
3 bgirolamo@akingump.com
BRETT M. MANISCO (SBN 318351)
4 bmanisco@akingump.com
1999 Avenue of the Stars, Suite 600
5 Los Angeles, CA 90067-6022
Telephone: 310.229.1000
6 Facsimile: 310.229.1001
7 Attorneys for Plaintiff and Cross-Defendant
Playboy Enterprises, Inc.
8

9 SUPERIOR COURT OF THE STATE OF CALIFORNIA

10 FOR THE COUNTY OF LOS ANGELES
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PLAYBOY ENTERPRISES, INC., a Delaware Case No. BC716374
12 Corporation,
[Assigned To The Honorable Elaine Lu For
13 Plaintiff, All Purposes, Dept. 26]
14 v.
15 GLOBAL BLOCKCHAIN TECHNOLOGIES NOTICE OF CONTINUANCE OF
CORPORATION, a Canadian corporation; SHIDAN ORDER TO SHOW CAUSE RE
16 GOURAN, an individual; TOKKEN MSB INC., a BLOCKCHAIN TECHNOLOGIES
Canadian corporation; VICE INDUSTRY TOKEN, CORP.’S REPRESENTATION; AND
17 INC., a California corporation; STUART DUNCAN, DEFENDANT STUART DUNCAN’S
an individual; and DOES 1-10 inclusive, MOTION TO DISMISS
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Defendants.
19

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Motion to Dismiss
21 GLOBAL BLOCKCHAIN TECHNOLOGIES Date: September 9, 2019
CORPORATION, a Canadian corporation Time: 8:30 a.m.
22 Dept.: 26
Cross-Complainant,
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vs. Order to Show Cause
24 Date: September 28, 2019
PLAYBOY ENTERPRISES, INC., a Delaware Time: 8:30 a.m.
25 corporation; TOKKEN MSB INC., a Canadian Dept. 26
corporation; VICE INDUSTRY TOKEN, INC., a
26 California corporation; STUART DUNCAN, an
individual; and ROES 1-10 inclusive,
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Cross-Defendants. Date Action Filed: August 3, 2018
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NOTICE OF CONTINUANCE OF ORDER TO SHOW CAUSE RE BLOCKCHAIN TECHNOLOGIES CORP.’S

REPRESENTATION; AND DEFENDANT STUART DUNCAN’S MOTION TO DISMISS
 1 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
2 PLEASE TAKE NOTICE that on July 30, 2019 the Court issued a continuance of the OSC

3 regarding the status of Global Blockchain Technologies Corporation’s representation. The OSC is

4 continued to August, 28, 2019 at 8:30 am in Department 26 of the Los Angeles Superior Court located

5 at 111 N. Hill Street, Los Angeles, California 90012.

6 PLEASE TAKE NOTICE that on July 30, 2019 the Court also issued a continuance of the

7 Hearing on Stuart Duncan’s Motion to Dismiss. The hearing on Stuart Duncan’s Motion to Dismiss is

8 continued to August 9, 2019 at 8:30 am in Department 26 of the Los Angeles Superior Court located at

9 111 N. Hill Street, Los Angeles, California 90012.

10 A true and correct copy of the Minute Order dated July 30, 2019.

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Dated: August 1, 2019 AKIN GUMP STRAUSS HAUER & FELD LLP
12 SUSAN K. LEADER
BRETT M. MANISCO
13

14 BY
15 Attorneys for Playboy Enterprises, Inc.
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NOTICE OF CONTINUANCE OF ORDER TO SHOW CAUSE RE BLOCKCHAIN TECHNOLOGIES CORP.’S
REPRESENTATION; AND DEFENDANT STUART DUNCAN’S MOTION TO DISMISS
EXHIBIT 1
 SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
Civil Division
Central District, Stanley Mosk Courthouse, Department 26

BC716374 July 30, 2019

PLAYBOY ENTERPRISES INC VS GLOBAL BLOCKCHAIN 8:30 AM
TECHNOLOGIES CO

Judge: Honorable Elaine Lu CSR: None

Judicial Assistant: E. Lopez ERM: None
Courtroom Assistant: B. Ly Deputy Sheriff: None

APPEARANCES:
For Plaintiff(s): Susan Kay Leader; Brett Michael Manisco
For Defendant(s): Tokken MSB, Inc., a Canadian Corporation by Paul Katrinak

NATURE OF PROCEEDINGS: Hearing on Motion to Dismiss; Case Management Conference

& OSC RE PROOF OF SERVICE; Order to Show Cause Re: why sanctions, including
dismissal, should not be imposed; Order to Show Cause Re: why sanctions, including dismissal
should not be imposed; Order to Show Cause Re: status of Global Blockchain Technologies
Corporation’s representation ; Order to Show Cause Re: why Global Blockchain Technologies
Corporation’s answer should not be stricken, why cross-complaint should not be dismissed, and
why a default and default judgment should not be entered

Matter is called for hearing.

There is no appearance by/or for Global Blockchain Technologies.

Upon granting counsel Raines Feldman LLP’s motion to be relieved as counsel for
Defendant/Cross-Complainant Global Blockchain Technologies Corporation on June 26, 2019,
the Court ordered Global Blockchain Technologies Corporation to timely retain new counsel and
to file a substitution of counsel within 21 days of service of the signed order. As noted in the
June 26, 2019 order, a corporation, unlike a natural person, cannot represent itself before courts
of record in propria persona, nor can it represent itself through a corporate officer, director or
other employee who is not an attorney. (CLD Const., Inc. v. City of San Ramon (2004) 120
Cal.App.4th 1141, 1145.) “[A Corporation] must be represented by licensed counsel in
proceedings before courts of record. (Id.) The June 26, 2019 order set an OSC regarding status of
Global Blockchain Technologies Corporation’s representation for July 30, 2019 at 8:30 am in
Department 26. The Court ordered Global Blockchain Technologies Corporation to appear on
July 30, 2019 with its new counsel. The Court advised that if Global Blockchain Technologies
Corporation failed to file a substitution of counsel within 21 days of service of the signed order,
Global Blockchain Technologies Corporation was ordered to appear on July 30, 2019 at 8:30 am
in Department 26 and show cause why Global Blockchain Technologies Corporation’s answer
should not be stricken, why Global Blockchain Technologies Corporation’s cross-complaint
Minute Order Page 1 of 3
 SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
Civil Division
Central District, Stanley Mosk Courthouse, Department 26

BC716374 July 30, 2019

PLAYBOY ENTERPRISES INC VS GLOBAL BLOCKCHAIN 8:30 AM
TECHNOLOGIES CO

Judge: Honorable Elaine Lu CSR: None

Judicial Assistant: E. Lopez ERM: None
Courtroom Assistant: B. Ly Deputy Sheriff: None

should not be dismissed, and why a default and default judgment should not be entered against
Global Blockchain Technologies Corporation on Plaintiff’s First Amended Complaint. The
Court warned that Global Blockchain Technologies Corporation’s failure to appear on July 30,
2019 at 8:30 am in Department 26 would be deemed consent to: striking of Global Blockchain
Technologies Corporation’s answer, dismissal of Global Blockchain Technologies Corporation’s
cross-complaint, and entry of default and default judgment against Global Blockchain
Technologies Corporation on Plaintiff’s First Amended Complaint. Raines Feldman gave notice
of the Court’s June 26, 2019 orders and filed proof of service of such on June 27, 2019.

Global Blockchain Technologies has failed to comply with any aspect of the court‘s June 26,
2019 order. Global Blockchain Technologies has failed to file any substitution of counsel. Global
Blockchain Technologies has also failed to appear for today’s hearing. Global Blockchain
Technologies has failed to identify any reason why its answer should not be stricken, why its
cross-complaint should not be dismissed, and why default and default judgment should not be
entered against Global Blockchain Technologies in light of its failure to timely retain new
counsel.

The OSC regarding status of Global Blockchain Technologies Corporation’s representation is

continued to August 28, 2019 at 8:30 am in Department 26. Global Blockchain Technologies
Corporation is ordered to appear on August 28, 2019 at 8:30 am in Department 26 and show
cause why Global Blockchain Technologies Corporation’s answer should not be stricken, why
Global Blockchain Technologies Corporation’s cross-complaint should not be dismissed, and
why a default and default judgment should not be entered against Global Blockchain
Technologies Corporation on Plaintiff’s First Amended Complaint in light of Global Blockchain
Technologies’ failure to timely retain new counsel and in light of Global Blockchain
Technologies’ failure to comply with the Court’s June 26, 2019 order. Global Blockchain
Technologies Corporation’s failure to appear on August 28, 2019 at 8:30 am in Department 26
shall be deemed consent to: striking of Global Blockchain Technologies Corporation’s answer,
dismissal of Global Blockchain Technologies Corporation’s cross-complaint, and entry of
default and default judgment against Global Blockchain Technologies Corporation on
Plaintiff’s First Amended Complaint.

Court Clerk is ordered to give notice.

On the Court's own motion, the Order to Show Cause Re: why sanctions, including dismissal,
should not be imposed scheduled for 07/30/2019, Order to Show Cause Re: why sanctions,
including dismissal should not be imposed scheduled for 07/30/2019, Order to Show Cause Re:
Minute Order Page 2 of 3
 SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
Civil Division
Central District, Stanley Mosk Courthouse, Department 26

BC716374 July 30, 2019

PLAYBOY ENTERPRISES INC VS GLOBAL BLOCKCHAIN 8:30 AM
TECHNOLOGIES CO

Judge: Honorable Elaine Lu CSR: None

Judicial Assistant: E. Lopez ERM: None
Courtroom Assistant: B. Ly Deputy Sheriff: None

status of Global Blockchain Technologies Corporation’s representation scheduled for

07/30/2019, and Order to Show Cause Re: why Global Blockchain Technologies Corporation’s
answer should not be stricken, why cross-complaint should not be dismissed, and why a default
and default judgment should not be entered scheduled for 07/30/2019 are continued to 08/28/19
at 08:30 AM in Department 26 at Stanley Mosk Courthouse.

Motion is called for hearing and argued.

On oral stipulation of court and counsel the rules as follows:

Pursuant to oral stipulation, the Hearing on Motion to Dismiss scheduled for 07/30/2019 is
continued to 08/09/19 at 08:30 AM in Department 26 at Stanley Mosk Courthouse.

Plaintiff's supplement briefing, (no more than 10 pages) and evidence to be filed and served by
08/01/19. Defendant's supplemental reply, (no more than 15 pages) to be filed and served by
noon on 08/05/19.

Notice is waived.

Certificate of Mailing is attached.

Minute Order Page 3 of 3

 1 PROOF OF SERVICE
2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
3 I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a
party to the within action; my business address is: 1999 Avenue of the Stars, Suite 600, Los Angeles,
4 CA 90067. On August 1, 2019, I served the foregoing document(s) described as: NOTICE OF
CONTINUANCE OF ORDER TO SHOW CAUSE RE BLOCKCHAIN TECHNOLOGIES
5 CORP.’S REPRESENTATION; AND DEFENDANT STUART DUNCAN’S MOTION TO
DISMISS on the interested party(ies) below, using the following means:
6
SEE ATTACHED SERVICE LIST
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8 BY UNITED STATES MAIL I enclosed the documents in a sealed envelope or package addressed to the
respective address(es) of the party(ies) stated above and placed the envelope(s) for collection and
9 mailing, following our ordinary business practices. I am readily familiar with the firm’s practice of
collection and processing correspondence for mailing. On the same day that correspondence is placed
10 for collection and mailing, it is deposited in the ordinary course of business with the United States
Postal Service, in a sealed envelope with postage fully prepaid at Los Angeles, California.
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BY OVERNIGHT DELIVERY I enclosed the document(s) in an envelope or package provided by an
12 overnight delivery carrier and addressed to the respective address(es) of the party(ies) stated above. I
placed the envelope or package for collection and overnight delivery at an office or a regularly utilized
13 drop box of the overnight delivery carrier.
14 BY ELECTRONIC MAIL OR ELECTRONIC TRANSMISSION. Based on a court order or an agreement of the parties
to accept service by e-mail or electronic transmission (cnaim@naimlegal.com), I caused the
15 document(s) to be sent to the respective e-mail address(es) of the party(ies) as stated above. I did not
receive, within a reasonable time after the transmission, any electronic message or other indication that
16 the transmission was unsuccessful.
17 (STATE) I declare under penalty of perjury under the laws of the State of California that the foregoing
is true and correct.
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Executed on August 1, 2019 at Los Angeles, California.
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20 Hadiss Y. Calderon
[Print Name of Person Executing Proof] [Signature]
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PROOF OF SERVICE
 1 SERVICE LIST
2 VIA U.S. MAIL
Global Blockchain Technologies Corporation
3 89 West Pender Street, Suite 810
Vancouver, BC V6C 2X1
4 Canada
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6 VIA U.S. MAIL

S. Michael Kernan
7 The Kernan Law Firm
9663 Santa Monica Blvd., Suite 450
8 Beverly Hills, CA 90210
Telephone: (310) 490-9777
9 Facsimile: (310) 861-0503
Email: mkernan@kernanlaw.net
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Attorneys for Defendants Vice Industry Token, Inc.; Stuart Duncan
11 and Tokken MSB Inc.
12

13 VIA ELECTRONIC MAIL

Cyrus S. Naim
14 Law Offices of Cyrus S. Naim
9107 Wilshire Blvd., Suite 450
15 Beverly Hills, CA 90210
Telephone: (310) 7773-5490
16 Email: cnaim@naimlegal.com
17 Attorney for Specially Appearing Shidan Gouran
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PROOF OF SERVICE