SLW Holdings v. Freeman IV

Electronically FILED by Superior Court of California, County of Los Angeles on 07/02/2021 11:57 PM Sherri R.
Carter, Executive Officer/Clerk of Court, by J. Lara,Deputy Clerk
1 EMANUEL LAW FIRM

Raphael B. Emanuel, SBN 218755
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remanuel@emanuel. law
3 SACHA V. EMANUEL (SBN 218705)
semanuel@emanuel. law
4 1100 Glendon Ave., Suite 15 th Floor
Los Angeles, California 90024
5 Telephone: (310) 881-6814
Facsimile: (310) 881-6801
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7 Attorneys for Plaintiff SLW HOLDINGS, LLC
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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COUNTY OF LOS ANGELES
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CASE NO.: 2 1STCV20050
12 SLW HOLDINGS LLC, a California limited
liability company, Assigned to the Hon. Mary H. Strobel
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14 Plaintiff, DECLARATION OF JULIO JONES,

MEMBER OF SLW HOLDINGS LLC, IN
15 SUPPORT OF REPLY TO OPPOSITION TO
VS. PRELIMINARY INUNCTION
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17 TYRONE FREEMAN, an individual: Hearing Date: July 8, 2021

WOLFGANG & ASSOCIATES, LLC; Time: 1:30 p.m.
18 DAUDE SHERRILS, an individual;
Dept.: 82
LAMAR HOUSE, an individual; and DOES
19 1 through 30, inclusive,
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Defendants
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DECLARATION OF J ULIO J ONES
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1 DECLARATION OF JULIO JONES
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I, Julio Jones, declare as follows:
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1. I am a member of SLW Holdings LLC, the Plaintiff and Petitioner in the above
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referenced matter, along with Roddy White. I respectfully submit this declaration in support of
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SLW Holdings LLC Reply to the Opposition to the Application for Preliminary Injunction. I have
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7 personal knowledge of the facts set forth herein and if called to testify as a witness, I could and
8 would competently testify as to all the facts stated in this declaration, except as to those matters
9 testified to upon information and belief, and as to those matters, I believe them to be true.
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2. I am a wide receiver for the Tennessee Titans in the National Football League
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(NFL). In my career, I have been selected for seven Pro Bowls, was a first-team All-Pro selection
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in 2015 and 2016 after leading the league in receiving yards and receptions. I was named second-
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14 team All-Pro three times, in 2017 and 2018 after leading the league in receiving yards. Since
15 entering the league, I have amassed more receiving yards than any other player.
16 3. In approximately the summer of 2019, I met Al Harrington (who I understand filed

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a Declaration in support of the Opposition) in Los Angeles. We attended various restaurants and
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clubs, talked over eating, and did things of that nature. In the midst of everything, Al brought up
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with me a proposition on investing in his company called Viola.
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4. I was intrigued but did not know anything about the cannabis space. But I felt like
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22 it was a great opportunity for me to make legal money outside of my profession. After I came
23 back home to Atlanta, Georgia, Al and I keep in touch. Al called and texted asking about me
24 investing. So, I flew back out to Los Angeles and met up with Al at his Viola office. That is
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where I met Defendants Daude Sherrills, Lamarr (aka "Dro") House, and Tyrone Freeman. Al
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told me it was okay to attend a meeting that they were doing for a platform for Los Angeles. He
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told me that Lamarr had a relationship with a social equity group. I sat in on a meeting, which
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DECLARATION OF JULIO JONES
1 went fine.
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5. At that point, Defendant Tyrone Freeman approached me to say that his son was a
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big fan of mine. That was the extent of the conversation that Tyrone and I had.
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6. Little did Al know that Lamarr (who I understand filed a Declaration in support of
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the Opposition) approached me, and informed me that Al does not have his stuff together, and
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7 that it will be a bad investment I should partner up with Al. Lamarr also stated that we can start
8 our own company because of his relationship with social equity. Lamarr and I became involved in
9 the beginning stages of communicating about starting a business. We discussed how if we are
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going to be "partners" in a company, an issue existed, because there was not a grow or a grower.
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7. Lamarr and Daude then showed me a building that they stated had potential to be a
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store in a headquarters off of Victory Road. So following that I reached out to Roddy, who I knew
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14 from the NFL, and told him that we had an opportunity in the cannabis space in Los Angeles, if
15 he wanted to be a part of it. His answer was "yes." In doing all of this, Roddy and I relied on trust
16 and good faith from a former professional athlete, Al. With the relationships we had, we trusted
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that Al was bringing the right people on board, and connecting us with only the right people who
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we could trust, and who were fully authorized to work in the industry, in a law abiding manner.
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8. Weeks went by, and we are looking for a grow. A lot of potential options came
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about, but we were never able to secure a grow. So Lammar told Roddy and I that he had a
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22 grower by the name of "Farmer John" and he was setting up a meeting to go meet with him in
23 Desert Hot Springs.
24 9. Roddy and I were picked up by Lamarr, Barrett and Daude to drive out to the
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desert to meet Farmer John. When we arrived, John informed me that he already had a grow that
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is established in operable and we knew this would be the man for the job. After seeing the grow,
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we all came back into John's office and started to negotiate the percentages and how much it
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1 would cost to build out and for him to grow the product. It was a lot of back-and-forth with
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negotiation we did not get anything set up, but on the ride back in the van with Lamarr, Daude
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BmTett, Roddy and I we made progress. Roddy and I discussed option that we thought would be
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fair to everyone, including John, because he was doing the building, and growing, however,
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Lamarr indicated he thought our proposal was absurd.
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7 10. Eventually SLW Holdings LLC (the only members of which are Roddy and I)
8 invested approximately $3,000,000 in Genetixcs LLC. I am not aware of any monetary
9 investment by Tyrone, Daude and Lamarr. SLW Holdings LLC has had to file this lawsuit
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because Tyrone, Daude and Lamarr's actions, which are the subject of this Court's TRO, are
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immediately and severely, harming SLW Holdings LLC.
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I declare under penalty of perjury under the laws of the State of California that the
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foregoing is true and correct. Executed this 2nd day of July, 2021 in Atlanta Georgia.
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Electronically FILED by Superior Court of California, County of Los Angeles on 07/02/2021 11:57 PM Sherri R.

Carter, Executive Officer/Clerk of Court, by J. Lara,Deputy Clerk

1 EMANUEL LAW FIRM

7 Attorneys for Plaintiff SLW HOLDINGS, LLC

14 Plaintiff, DECLARATION OF JULIO JONES,

17 TYRONE FREEMAN, an individual: Hearing Date: July 8, 2021

16 3. In approximately the summer of 2019, I met Al Harrington (who I understand filed

23 Desert Hot Springs.

DECLARATION OF JULIO JONES

8 invested approximately $3,000,000 in Genetixcs LLC. I am not aware of any monetary

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