DECLARATION OF ADDI SOMEKH
I, ADDI SOMEKH, declare:
1. I am a citizen of the United States who resides in the State of California. I am a friend and business associate of Respondent Hopeton Brown’s. I am also an acquaintance of Petitioner Amara Wilson’s. Except as to those matters stated on information and belief, I have personal knowledge of the facts set forth below and could and would testify competently thereto if asked to do so.
2. I am a DJ with 89.7, KFJC at Foothill Junior College. I have a master’s degree in Human Resource Management. I am a musician, corporate team builder, multicultural business consultant, speaker, and balloon artist. I travelled, with a photographer, to over 34 countries and created balloon hats for people. This journey yielded some 12,000 images and a book. The balloon hats break down language and cultural barriers in ways experts could never imagine.
3. I became aware of Hopeton Brown approximately twenty five (25) years ago because of his work in Reggae music. Hopeton Brown is professionally known in Reggae circles as “The Scientist.” He is one of the best known sound/mixing engineers and producers in Reggae. Hopeton Brown is a genius on a musical level and as an electrical engineer. His work is extremely advanced and innovative. Approximately six (6) years ago, I arranged for him to do a live performance at the radio station. Hopeton Brown is a performer as well as a sound engineer and producer.
4. Hopeton Brown and I began working on a video tutorial approximately five (5) years ago. That video tutorial is something Hopeton Brown was developing based on his sound, mixing, and recording techniques. The tutorial documented Hopeton Brown’s sound techniques, which are historically innovative. It is a style of sound engineering created in Jamaica by Hopeton Brown’s mentor, King Tubby, and Hopeton Brown. It is also a style of music in its own right that has gone on to influence a wide variety of music including house, hip hop, drums and bass, techno, and punk. Reggae music has dynamic, large sounds. It uses low end bass and high end guitar. The video tutorial documents the sound techniques developed to capture that sound accurately. The recording/mixing/sound engineer has a very large role in the performance of the piece. There is an “A” side with a band performing. There is a “B” side, which is known as the “dub version.” The dub version incorporates the use of echo and other studio and sound techniques. Hopeton Brown’s video tutorial is an extremely valuable documentary tool.
5. Over the past six (6) years, I have come to know Hopeton Brown quite well and have had business dealings with him. There have never been problems with respect to any issues involving lying or any type of short-sightedness. Hopeton Brown has a work ethic. He is absolutely not a liar. He is capable of apologizing when he is in the wrong. He is a man of integrity.
4. Any woman who is a fan of Reggae is going to be extremely intrigued by Hopeton Brown because he is an international living legend.
5. I was introduced to Amara Wilson by Hopeton Brown at the club Echoplex in Los Angeles where he works as a sound engineer/mixer and performer. I became friendly with Amara Wilson independent of Hopeton Brown. She is a singer and I am a jazz musician. My instrument is a bass made out of balloons. Amara Wilson is bright, energetic, and over her head in that she tries to accomplish too many things at once. She is a single mother who has a used clothing store. All the clothes in the store belonged to Amara Wilson at one time. They are the remnants of her former modeling career. She is a singer who is trying to promote her music. She is interested in meditation and a scattered individual. I vividly recall Hopeton Brown stopping by to visit my wife and me at our home in the summer of 2009. He brought Amara Wilson and her son with him. I was startled by her son’s behavior. The child literally went berserk. He was running around in circles screaming at the top of his lungs in my backyard. I actually became concerned about what my neighbors might think was going on. I have worked with kids, as a balloon artist, for over twenty (20) years. I have never seen a child freak out like this. He was acting out and uncontrollable. He was becoming hyper. I began to question Amara Wilson’s ability to parent because she could not control him. I also wondered if the child had an issue with sugar. Amara Wilson is a frazzled loose canon from my perspective.
6. Hopeton Brown comes from a culture where Bob Marley is an icon. Jamaicans are conservative people. There are many churches in Jamaica and, due to the fact that Bob Marley’s mother was a single mother, they are extremely pro life. Hopeton Brown was raised in a very conservative household in Jamaica. He is a gentleman and has excellent manners.
7. Amara Wilson told me that she worked for a woman who owned a clothing company. They apparently had a falling out and, according to Ms. Wilson, a tremendous amount of drama ensued. Amara Wilson appears to have a pattern of engaging in drama when something goes wrong in a business relationship. Hopeton Brown had produced some songs for Amara Wilson. It is my personal belief that Amara Wilson is engaging in revenge against Hopeton Brown and attempting to humiliate him by making up a bunch of lies. It is one thing to end a relationship, business or otherwise, but it is completely unacceptable to then destroy Hopeton Brown’s video tutorial and impugn his reputation. Amara Wilson apparently thrives on conflict. Hopeton Brown has a reputation to maintain. He is well known and is routinely compensated with royalties related to his body of work and/or songs. Five (5) of his songs were used in the video game and soundtrack known as Grand Theft Auto 3. He has been on approximately two hundred (200) records.
8. I have seen Amara Wilson and Hopeton Brown together at the store and club in August 2009. I last saw them together at the Echo Plex Club on August 14, 2009. Hopeton Brown had a show there. Everything was harmonious between Hopeton Brown and Amara Wilson. They were hanging out and it was super mellow.
9. I am also a friend of Keisha Martin’s. Keisha Martin is a very close friend of Amara Wilson’s. Never once has Keisha Martin raised any issue concerning Hopeton Brown’s behavior or conduct with respect to Amara Wilson.
10. In closing, I would like to address Hopeton Brown’s speech. English is Hopeton Brown’s second language. Jamaican is his first. There can be some confusion with respect to his speech and this is particularly so when he is upset.
I declare under penalty of perjury that the foregoing is true and correct.
Executed this _____ day of March at Los Angeles, California.
____________________________________
ADDI SOMEKH
Signed