INVESTIGATION & FORMAL GRIEVANCE
This multi-site platform serves as a public-interest dossier compiling verified evidence of fraudulent and illicit acts involving Verizon Wireless, Cellular Sales, and associated personnel. This repository is maintained to assist law enforcement, regulatory authorities, and investigative media in holding all involved entities accountable. For comprehensive evidentiary logs, court-filed pleadings, and an itemized analysis of indicators of fraud, view the primary repository at crimereports.online and related sites through links below.
COMPLAINT AND GRIEVANCE FOR PROFESSIONAL MISCONDUCT
This evidentiary profile documents deliberate acts of material misrepresentation, subornation of perjured declarations, and abusive litigation tactics executed by defense co-counsel Jonah Gavish. Functioning in tandem with lead counsel, Gavish has repeatedly submitted fraudulent court filings, fabricated factual assertions, and concealed primary transaction evidence to shield corporate respondents from liability. When presented with concrete transactional records disproving defense claims, Gavish continued to advance known false statements to the tribunal, actively engaging in wire fraud and bad-faith procedural delay tactics to obstruct Complainant's statutory right to a merits-based determination.
I. EVIDENTIARY ANALYSIS: SUBORNATION, EXTORTION & PROCEDURAL SABOTAGE
Submission of Known Perjured Declarations:
■ Gavish knowingly drafted and submitted false declarations and unverified court filings to the tribunal—asserting material untruths regarding account histories, promotional eligibility, and customer insurance coverage despite having direct access to records contradicting those claims.
Concealment & Wire Fraud via Electronic Filings:
■ By utilizing electronic court filing systems to transmit knowingly altered financial receipts and fabricated billing statements while withholding mandatory 28-digit transaction audit logs, Gavish actively participated in a scheme of electronic judicial deception and wire fraud.
Abuse of Process & Bad-Faith Delay Tactics:
■ Gavish systematically engaged in procedural abuse—filing frivolous, non-responsive motions to evade mandatory settlement protocols, hiding behind baseless privilege claims to block routine discovery, and intentionally inflating litigation costs to harass a self-represented litigant.
II. PRELIMINARY STATEMENT
In the course of representing Cellular Sales of Knoxville, Inc. “CSOKI” or “Cellular Sales”), Counsel Gavish personally executed and submitted two separate sworn filings containing false material statements to the Eighth Judicial District Court.
On July 31, 2026, Counsel Gavish transmitted an initial ex parte motion to judicial chambers containing known misrepresentations regarding service of process, corporate nexus, and counsel retention.
On August 2, 2026, he officially docketed a second Motion to Set Aside Default that re-asserted these same false claims under penalty of perjury.
Concurrently, Counsel Gavish engaged in the continuous subornation of perjury by procuring, submitting, and maintaining the fraudulent sworn declaration of lead national counsel C. Larry Carbo, III across three distinct procedural instances: (1) During the off-docket transmission to Department 25 chambers on July 31; (2) Upon the formal electronic filing of the motion on August 2; and (3) During motion to Strike First Amended Complaint (FAC) on August 17, 2026.
III. PROCEDURAL HISTORY
1. Background
Respondent represents defendant Cellular Sales of Knoxville, Inc. ("CSOKI" or “Cellular Sales”) which is an authorized retailer of Cellco Partnership dba Verizon Wireless (“Verizon”).
Under Nevada Rule of Civil Procedure (NRCP) 12, Defendant Cellular Sales was required to file an Answer or responsive pleading within 21 days of service.
On July 28, 2026, on the day the answer was due, Complainant was contacted by phone by Counsel Larry Carbo (“Carbo”), who identified himself as national coordinating counsel for Cellular Sales. Counsel Carbo requested a two-week extension to respond to the complaint, claiming Cellular Sales had not yet secured local Nevada representation. This requested two-week extension directly coincided with the hearing scheduled for August 11 regarding Complainant’s Motion for a Temporary Restraining Order and Preliminary Injunction.
Complainant initially assented to an extension in good faith, particularly as a First Amended Complaint (FAC) had been filed the prior day.
Immediately following the phone call, however, Counsel Carbo transmitted an email thanking Complainant for the extension and introducing Counsel Gavish as local Nevada defense counsel, copying Gavish on the communication. This rapid contradiction raised immediate concerns. Complainant promptly replied via email with the FAC attached, asking whether electronic service of the FAC was formally accepted. Neither Counsel Carbo nor Counsel Gavish responded to confirm or deny acceptance of service.
Shortly thereafter, Counsel Gavish served a written stipulation that disclaimed substantive responsibility while seeking to delay proceedings based on misrepresentations.
Recognizing the deceptive nature of the request, Complainant refused to execute the proposed stipulation. Complainant, who had published public-awareness websites documenting evidentiary accounts of the frivolous and criminal acts of Verizon and Cellular Sales employees, such as www.verizon.vegas and www.cellularsales.store, expanded public interest coverage by establishing www.jonahgavish.com, and formally served the FAC on Cellular Sales' counsel and designated Nevada registered agent that same day.
Because Defendant Cellular Sales failed to file a timely Answer or responsive pleading within the statutory period, Complainant applied for an Entry of Default, which was formally entered against Cellular Sales by the Clerk of Court on July 29, 2026.
2. Submission of Two Perjured Declarations
On July 31, 2026, Counsel Gavish bypassed the official Court Electronic Filing (e-filing) system and directly emailed an unfiled document titled "Defendant Cellular Sales of Knoxville, Inc.’s Motion to Set Aside Default on Order Shortening Time" to Department 25 judicial chambers.
In this off-docket, ex parte transmission, Respondent Gavish sought an emergency Order Shortening Time (OST) to set aside the clerk's default.
To induce the Court into granting emergency relief, Counsel Gavish manufactured and attached two fraudulent declarations executed under penalty of perjury: one by Counsel Gavish and one by Counsel Carbo.
In these filings, Respondent intentionally concealed material facts from the tribunal—specifically omitting any mention that Counsel Gavish had already been served the FAC on July 29, 2026, and that the parties had engaged in discussions wherein Complainant rejected Defendants' proposed stipulation.
Complainant immediately objected to the improper electronic filing of the motion, transmitting a follow-up communication that detailed the extensive factual misrepresentations and perjury contained within the submitted papers.
Following this notification, Counsel Works assumed lead defense representation, replacing Counsel Gavish. However, on August 2, 2026, Counsel Works filed an identical, frivolous motion containing those same false allegations—willfully disregarding Complainant’s explicit, written warnings against relying on or submitting the perjurious declarations.
3. Demands to Withdraw Perjured Statements
To date, Complainant has issued multiple formal demands to all parties—including Respondent Gavish—requesting the immediate withdrawal of the perjured submissions, but these demands have been consistently ignored.
4. Partners in Crime
Parallel regulatory and criminal complaints against Counsel Gavish and Counsel Carbo are being lodged concurrently across state and federal jurisdictions for identical statutory and administrative violations.
IV. SUBMITTAL OF PERJURIOUS DECLARATION
1. Fabrication, Execution, and Submission of False Declarations Under Penalty of Perjury
■ Respondent Gavish, acting as local Nevada defense counsel, drafted, executed, and submitted a sworn written declaration under penalty of perjury containing deliberate material falsehoods regarding litigation extension agreements, pending service, and scheduling negotiations.
■ Respondent Gavish submitted these false statements to the Eighth Judicial District Court to improperly obtain procedural extensions, obstruct Complainant’s pending injunctive relief, and conceal the fact that Complainant had already formally served the FAC.
■ The deliberate execution and docketing of a false declaration under penalty of perjury by an officer of the court constitutes active fraud on the court, direct perjury, and an intentional subversion of the judicial process.
2. Evidentiary Audit: Comparison of Sworn Declarations of Counsel Gavish vs. Documented Public Record
Below is a comparative account exposing the direct contradictions between the sworn statements executed under penalty of perjury in the Declaration of Counsel Gavish and the actual, timestamped objective evidence on record.
KEY EVIDENTIARY FILINGS
Click on the links below to access the specific court filings, declarations, and official records:
FALSE STATEMENT (Gavish Declaration)
DOCUMENTED FACT & PUBLIC RECORD
FALSE STATEMENT 1 (¶ 4):
“CSOKI [Cellular Sales of Knoxville, Inc.] does not transact business in Nevada and has no contacts of any kind with this State.”
FACT 1:
Public records maintained by the Nevada Secretary of State establish that Cellular Sales operates and manages retail locations in Nevada. Cellular Sales executives, including Pamela White (CFO) and Thomas K. Reeves (General Counsel), manage all Cellular Sales stores directly, as these locations are not independently owned.
FALSE STATEMENT 2 (¶ 5):
"CSOKI was never served."
FACT 2:
Cellular Sales Service of process was formally completed upon CSOKI’s designated Nevada registered agent, C T Corporation System.
FALSE STATEMENT 3 (¶ 5):
"CT Corporation System is not CSOKI’s registered agent; CSOKI, a Tennessee corporation, has no registered agent in Nevada."
FACT 3:
Official records on the Nevada Secretary of State website confirm that C T Corporation System is the registered agent for Cellular Sales.
FALSE STATEMENT 4 (¶ 5):
"Plaintiff served the Nevada registered agent of a different entity, not CSOKI."
FACT 4:
Service was completed on C T Corporation System as the agent for Cellular Sales.
FALSE STATEMENT 5 (¶ 11):
"The link directs to a website Plaintiff created that publishes false information about me and appears intended to disparage my professional reputation."
FACT 5:
On August 1, 2026, Complainant requested that Counsel Works specify which statements were false. Counsel Works refused to identify any false statements and merely demanded that the site be taken down.
FALSE STATEMENT 6 (¶ 12):
"CSOKI seeks relief on an order shortening time because a default is now on file against a defendant that was never served and over which this Court lacks personal jurisdiction."
FACT 6:
The Court has personal jurisdiction over Cellular Sales because it conducts business in Nevada and was properly served. Counsel Gavish made these false statements for the explicit purpose of absconding Defendant Cellular Sales from legal liability.
V. REGIONAL LEADERSHIP DISCLOSURES
■ Headquarters Guidance: Cellular Sales headquarters in Knoxville, TN directs market leaders and regional presidents across the country.
■ Nevada Management: Public records highlight two key regional leaders for the State of Nevada: Angel Caraballo and Aaron Schmidt.
■ Angel Caraballo: IIdentified via Cellular sales's official web page and RocketReach as Regional Director/President based in Las Vegas, NV, possessing skills in customer retention, recruitment, team leadership, and employee training. Caraballo is located at 6843 Compass Street, North Las Vegas, Nevada. His wife Rose Caraballo, is a Cellular Sales recruiter.
■ Aaron Schmidt: Identified via Cellular Sales's official web page as Regional President. Schmidt is located at 10557 Sariah Skye Avenue, Las Vegas, Nevada.
■ Retail Network: Cellular Sales operates as Verizon's premier retail partner, maintaining nearly 850 stores across 45 states.
■ Cellular Sales Platform: View complete list of Regional Mangers of Cellular Sales of Knoxville
Click the image below to visit the official YouTube channel operated by Cellular Sales Management Company
Click the image below to view corporate documentation identifying Cellular Sales as a management company, along with its 'C' rating
VI. CELLULAR SALES EMPLOYEES IN LAS VEGAS
Pictured below, Aaron Schmidt and Angel Caraballo are listed on Cellular Sales' web pages as Nevada Regional Presidents, while Rose Caraballo is listed as a Recruiter.
■ Aaron Schmidt is currently listed as an active Cellular Sales employee. He resides at 10557 Sariah Skye Ave, Las Vegas, NV 89166 with an operational corporate email address at Aaron.Schmidt@cellularsales.com.
■ Angel Caraballo is currently listed as an active employee. He resides at 6843 Compass St North Las Vegas, NV 89084 with an operational corporate email address at Angel.Caraballo@cellularsales.com.
■ Rose Caraballo is currently listed as an active employee. She reside at 6843 Compass St North Las Vegas, NV 89084 with an operational corporate email address at Rose.Caraballo@cellularsales.com.
This evidence directly contradicts the company's sworn testimony asserting that Cellular Sales maintains no corporate or operational connection to Nevada stores.
Cellular Sales Regional President Angel Caraballo and Recruiter Rose Caraballo's Las Vegas Residence
Cellular Sales Regional President Aaron Schmidt's Las Vegas Residence
CORPORATE STRUCTURE
To view Cellular Sales' corporate structure, click
To view AI search results regarding Cellular Sales' modus operandi, click
VII. APPLICABLE STATE, AND PROFESSIONAL VIOLATIONS
A. Nevada Revised Statutes (NRS - Criminal & Civil Misconduct)
- 199.120 (Perjury & Subornation of Perjury): Making a false material statement under oath or under penalty of perjury in a judicial proceeding (Cat. D felony under Nevada law).
- 199.145 (Offering False Evidence): Knowingly offering or introducing into evidence, as genuine or true, any false or fabricated written instrument or sworn statement in court proceedings (Category D felony).
- 199.210 (Offering False Evidence): Offering false statement of facts.
- 199.480 (Criminal Conspiracy): Conspiring between out-of-state lead counsel (Carbo) and local defense counsel (Gavish) to falsely maintain a defense or pervert the due administration of justice.
- 207.190 (Coercion): It is unlawful for a person, with the intent to compel another to do or abstain from doing an act which the other person has a right to do or abstain from doing.
B. Nevada Rules of Professional Conduct (NV RPC)
- 1.2(d) (Scope of Representation): A lawyer shall not counsel a client to engage, or assist a client, in conduct that the lawyer knows is criminal or fraudulent.
- 3.1 (Meritorious Claims and Contentions): A lawyer shall not bring or defend a proceeding, or assert or controvert an issue therein, unless there is a basis in law and fact for doing so that is not frivolous.
- 3.3 (Candor Toward the Tribunal): A lawyer shall not knowingly make a false statement of fact or law to a tribunal or offer evidence that the lawyer knows to be false.
- 3.4(b) (Fairness to Opposing Party and Counsel): A lawyer shall not falsify evidence, counsel or assist a witness to testify falsely, or offer an inducement to a witness that is prohibited by law.
- 8.4(c) (Misconduct - Dishonesty & Deceit): Prohibits engaging in conduct involving dishonesty, deceit, or misrepresentation to manipulate legal outcomes.
- 8.4(d) (Prejudice to the Administration of Justice): Prohibits engaging in tactics designed solely to prejudice the tribunal, delay merits-based determinations, and undermine the integrity of judicial proceedings.
VIII. COMPOUNDING DAMAGE, JUDICIAL COLLUSION, AND PENDING MOTION FOR TERMINATING SANCTIONS
As the result of Respondent’s perjured declarations, the presiding judge granted Defendant Cellular Sales’ Motion for Shortened Time by relying directly on fraudulent evidentiary submissions, including a fabricated transaction receipt and perjured declarations.
Also, Complainant was forced to withdraw and pull the entry of default to avoid wasting scarce judicial resources and expending extensive time litigating a Motion to Set Aside built entirely on perjured statements.
Furthermore, defense counsel's fraudulent filings and bad-faith maneuvers occurred in tandem with obvious judicial favoritism and collusion by the presiding judge. This forced Complainant to file a formal motion to disqualify the judge.
Most critically, Complainant filed an emergency Motion for a Temporary Restraining Order (TRO) on June 23, 2026. Due to the collusive and bad-faith actions of Respondent and co-counsel in manufacturing false extensions and corrupting the record, Complainant has been completely denied a timely hearing on emergency injunctive relief, leaving ongoing irreparable harm unchecked indefinitely.
IX. DEMAND FOR DISCIPLINARY AND CRIMINAL SANCTIONS
Complainant specifically requests that the State Bar investigate Counsel Gavish for perjury, wire fraud, and bad-faith abuse of process, and issue emergency disciplinary suspensions and appropriate criminal indictments.
PENDING PROCEEDINGS: TWO FORMAL MOTIONS FOR TERMINATING AND PUNITIVE SANCTIONS (NRS 7.085)
PLEASE TAKE FORMAL NOTICE that due to the pervasive, continuous, and coordinated subornation of perjury, bad-faith litigation tactics, fraudulent submittals, and procedural extortion executed by defense counsel and corporate respondents, there are currently two separate formal motions for terminating and punitive sanctions pending before the Court:
■ First Motion for Terminating and Punitive Sanctions:
Filed against all named Defendants and defense counsel pursuant to NRS 7.085 (liability of attorney for maintaining frivolous, fraudulent, or bad-faith filings) and the inherent powers of the Court, seeking the immediate strike of defense pleadings, entry of default judgment, and punitive monetary assessments.
Defendants are in procedural default regarding Complainant’s Motion to Strike Baseless Filings and for Sanctions. Pursuant to the Nevada Rules of Civil Procedure and local court rules, Defendants were required to file and serve any opposition within the mandatory statutory timeframe.
Defendants completely failed to submit an opposition or request an extension of time, allowing the deadline to pass without response. Under local rules, an opposing party's failure to serve and file a written opposition constitutes a consent to the granting of the motion. Consequently, Defendants have conceded the factual and legal grounds set forth in the motion, rendering the requested sanctions and procedural remedies fully ripe for judicial entry by default.
■ Second Motion for Terminating and Punitive Sanctions:
Filed as a standalone, targeted motion directly addressing the subsequent bad-faith maneuvers, continued reliance on known perjured declarations, manufactured procedural delays, and extortionate demands conditioning the withdrawal of moot filings upon the unlawful surrender of private web domains.
PENDING CRIMINAL ACTIONS
In tandem with this complaint, Complainant is seeking criminal prosecution of Respondent in the State of Nevada, the State of Texas, and at the federal level, as detailed herein along with other co-conspirators.
■ Gavish knowingly drafted and submitted false declarations and unverified court filings to the tribunal—asserting material untruths regarding account histories, promotional eligibility, and customer insurance coverage despite having direct access to records contradicting those claims.
Concealment & Wire Fraud via Electronic Filings:■ By utilizing electronic court filing systems to transmit knowingly altered financial receipts and fabricated billing statements while withholding mandatory 28-digit transaction audit logs, Gavish actively participated in a scheme of electronic judicial deception and wire fraud.
Abuse of Process & Bad-Faith Delay Tactics:■ Gavish systematically engaged in procedural abuse—filing frivolous, non-responsive motions to evade mandatory settlement protocols, hiding behind baseless privilege claims to block routine discovery, and intentionally inflating litigation costs to harass a self-represented litigant.
II. PRELIMINARY STATEMENT
In the course of representing Cellular Sales of Knoxville, Inc. “CSOKI” or “Cellular Sales”), Counsel Gavish personally executed and submitted two separate sworn filings containing false material statements to the Eighth Judicial District Court.
On July 31, 2026, Counsel Gavish transmitted an initial ex parte motion to judicial chambers containing known misrepresentations regarding service of process, corporate nexus, and counsel retention.
On August 2, 2026, he officially docketed a second Motion to Set Aside Default that re-asserted these same false claims under penalty of perjury.
Concurrently, Counsel Gavish engaged in the continuous subornation of perjury by procuring, submitting, and maintaining the fraudulent sworn declaration of lead national counsel C. Larry Carbo, III across three distinct procedural instances: (1) During the off-docket transmission to Department 25 chambers on July 31; (2) Upon the formal electronic filing of the motion on August 2; and (3) During motion to Strike First Amended Complaint (FAC) on August 17, 2026.
III. PROCEDURAL HISTORY
1. Background
Respondent represents defendant Cellular Sales of Knoxville, Inc. ("CSOKI" or “Cellular Sales”) which is an authorized retailer of Cellco Partnership dba Verizon Wireless (“Verizon”).
Under Nevada Rule of Civil Procedure (NRCP) 12, Defendant Cellular Sales was required to file an Answer or responsive pleading within 21 days of service.
On July 28, 2026, on the day the answer was due, Complainant was contacted by phone by Counsel Larry Carbo (“Carbo”), who identified himself as national coordinating counsel for Cellular Sales. Counsel Carbo requested a two-week extension to respond to the complaint, claiming Cellular Sales had not yet secured local Nevada representation. This requested two-week extension directly coincided with the hearing scheduled for August 11 regarding Complainant’s Motion for a Temporary Restraining Order and Preliminary Injunction.
Complainant initially assented to an extension in good faith, particularly as a First Amended Complaint (FAC) had been filed the prior day.
Immediately following the phone call, however, Counsel Carbo transmitted an email thanking Complainant for the extension and introducing Counsel Gavish as local Nevada defense counsel, copying Gavish on the communication. This rapid contradiction raised immediate concerns. Complainant promptly replied via email with the FAC attached, asking whether electronic service of the FAC was formally accepted. Neither Counsel Carbo nor Counsel Gavish responded to confirm or deny acceptance of service.
Shortly thereafter, Counsel Gavish served a written stipulation that disclaimed substantive responsibility while seeking to delay proceedings based on misrepresentations.
Recognizing the deceptive nature of the request, Complainant refused to execute the proposed stipulation. Complainant, who had published public-awareness websites documenting evidentiary accounts of the frivolous and criminal acts of Verizon and Cellular Sales employees, such as www.verizon.vegas and www.cellularsales.store, expanded public interest coverage by establishing www.jonahgavish.com, and formally served the FAC on Cellular Sales' counsel and designated Nevada registered agent that same day.
Because Defendant Cellular Sales failed to file a timely Answer or responsive pleading within the statutory period, Complainant applied for an Entry of Default, which was formally entered against Cellular Sales by the Clerk of Court on July 29, 2026.
2. Submission of Two Perjured Declarations
On July 31, 2026, Counsel Gavish bypassed the official Court Electronic Filing (e-filing) system and directly emailed an unfiled document titled "Defendant Cellular Sales of Knoxville, Inc.’s Motion to Set Aside Default on Order Shortening Time" to Department 25 judicial chambers.
In this off-docket, ex parte transmission, Respondent Gavish sought an emergency Order Shortening Time (OST) to set aside the clerk's default.
To induce the Court into granting emergency relief, Counsel Gavish manufactured and attached two fraudulent declarations executed under penalty of perjury: one by Counsel Gavish and one by Counsel Carbo.
In these filings, Respondent intentionally concealed material facts from the tribunal—specifically omitting any mention that Counsel Gavish had already been served the FAC on July 29, 2026, and that the parties had engaged in discussions wherein Complainant rejected Defendants' proposed stipulation.
Complainant immediately objected to the improper electronic filing of the motion, transmitting a follow-up communication that detailed the extensive factual misrepresentations and perjury contained within the submitted papers.
Following this notification, Counsel Works assumed lead defense representation, replacing Counsel Gavish. However, on August 2, 2026, Counsel Works filed an identical, frivolous motion containing those same false allegations—willfully disregarding Complainant’s explicit, written warnings against relying on or submitting the perjurious declarations.
3. Demands to Withdraw Perjured Statements
To date, Complainant has issued multiple formal demands to all parties—including Respondent Gavish—requesting the immediate withdrawal of the perjured submissions, but these demands have been consistently ignored.
4. Partners in Crime
Parallel regulatory and criminal complaints against Counsel Gavish and Counsel Carbo are being lodged concurrently across state and federal jurisdictions for identical statutory and administrative violations.
IV. SUBMITTAL OF PERJURIOUS DECLARATION
1. Fabrication, Execution, and Submission of False Declarations Under Penalty of Perjury
■ Respondent Gavish, acting as local Nevada defense counsel, drafted, executed, and submitted a sworn written declaration under penalty of perjury containing deliberate material falsehoods regarding litigation extension agreements, pending service, and scheduling negotiations.
■ Respondent Gavish submitted these false statements to the Eighth Judicial District Court to improperly obtain procedural extensions, obstruct Complainant’s pending injunctive relief, and conceal the fact that Complainant had already formally served the FAC.
■ The deliberate execution and docketing of a false declaration under penalty of perjury by an officer of the court constitutes active fraud on the court, direct perjury, and an intentional subversion of the judicial process. Below is a comparative account exposing the direct contradictions between the sworn statements executed under penalty of perjury in the Declaration of Counsel Gavish and the actual, timestamped objective evidence on record.
Click on the links below to access the specific court filings, declarations, and official records:
■ Headquarters Guidance: Cellular Sales headquarters in Knoxville, TN directs market leaders and regional presidents across the country.
■ Nevada Management: Public records highlight two key regional leaders for the State of Nevada: Angel Caraballo and Aaron Schmidt.
■ Angel Caraballo: IIdentified via Cellular sales's official web page and RocketReach as Regional Director/President based in Las Vegas, NV, possessing skills in customer retention, recruitment, team leadership, and employee training. Caraballo is located at 6843 Compass Street, North Las Vegas, Nevada. His wife Rose Caraballo, is a Cellular Sales recruiter.
■ Aaron Schmidt: Identified via Cellular Sales's official web page as Regional President. Schmidt is located at 10557 Sariah Skye Avenue, Las Vegas, Nevada.
■ Retail Network: Cellular Sales operates as Verizon's premier retail partner, maintaining nearly 850 stores across 45 states.
■ Cellular Sales Platform: View complete list of Regional Mangers of Cellular Sales of Knoxville
2. Evidentiary Audit: Comparison of Sworn Declarations of Counsel Gavish vs. Documented Public Record
FALSE STATEMENT (Gavish Declaration)
DOCUMENTED FACT & PUBLIC RECORD
FALSE STATEMENT 1 (¶ 4):
“CSOKI [Cellular Sales of Knoxville, Inc.] does not transact business in Nevada and has no contacts of any kind with this State.”FACT 1:
Public records maintained by the Nevada Secretary of State establish that Cellular Sales operates and manages retail locations in Nevada. Cellular Sales executives, including Pamela White (CFO) and Thomas K. Reeves (General Counsel), manage all Cellular Sales stores directly, as these locations are not independently owned.
FALSE STATEMENT 2 (¶ 5):
"CSOKI was never served."FACT 2:
Cellular Sales Service of process was formally completed upon CSOKI’s designated Nevada registered agent, C T Corporation System.
FALSE STATEMENT 3 (¶ 5):
"CT Corporation System is not CSOKI’s registered agent; CSOKI, a Tennessee corporation, has no registered agent in Nevada."FACT 3:
Official records on the Nevada Secretary of State website confirm that C T Corporation System is the registered agent for Cellular Sales.
FALSE STATEMENT 4 (¶ 5):
"Plaintiff served the Nevada registered agent of a different entity, not CSOKI."FACT 4:
Service was completed on C T Corporation System as the agent for Cellular Sales.
FALSE STATEMENT 5 (¶ 11):
"The link directs to a website Plaintiff created that publishes false information about me and appears intended to disparage my professional reputation."FACT 5:
On August 1, 2026, Complainant requested that Counsel Works specify which statements were false. Counsel Works refused to identify any false statements and merely demanded that the site be taken down.
FALSE STATEMENT 6 (¶ 12):
"CSOKI seeks relief on an order shortening time because a default is now on file against a defendant that was never served and over which this Court lacks personal jurisdiction."FACT 6:
The Court has personal jurisdiction over Cellular Sales because it conducts business in Nevada and was properly served. Counsel Gavish made these false statements for the explicit purpose of absconding Defendant Cellular Sales from legal liability.V. REGIONAL LEADERSHIP DISCLOSURES
VI. CELLULAR SALES EMPLOYEES IN LAS VEGAS
Pictured below, Aaron Schmidt and Angel Caraballo are listed on Cellular Sales' web pages as Nevada Regional Presidents, while Rose Caraballo is listed as a Recruiter.■ Aaron Schmidt is currently listed as an active Cellular Sales employee. He resides at 10557 Sariah Skye Ave, Las Vegas, NV 89166 with an operational corporate email address at Aaron.Schmidt@cellularsales.com.
■ Angel Caraballo is currently listed as an active employee. He resides at 6843 Compass St North Las Vegas, NV 89084 with an operational corporate email address at Angel.Caraballo@cellularsales.com.
■ Rose Caraballo is currently listed as an active employee. She reside at 6843 Compass St North Las Vegas, NV 89084 with an operational corporate email address at Rose.Caraballo@cellularsales.com.
This evidence directly contradicts the company's sworn testimony asserting that Cellular Sales maintains no corporate or operational connection to Nevada stores.
CORPORATE STRUCTURE
To view Cellular Sales' corporate structure, click To view AI search results regarding Cellular Sales' modus operandi, clickVII. APPLICABLE STATE, AND PROFESSIONAL VIOLATIONS
A. Nevada Revised Statutes (NRS - Criminal & Civil Misconduct)
- 199.120 (Perjury & Subornation of Perjury): Making a false material statement under oath or under penalty of perjury in a judicial proceeding (Cat. D felony under Nevada law).
- 199.145 (Offering False Evidence): Knowingly offering or introducing into evidence, as genuine or true, any false or fabricated written instrument or sworn statement in court proceedings (Category D felony).
- 199.210 (Offering False Evidence): Offering false statement of facts.
- 199.480 (Criminal Conspiracy): Conspiring between out-of-state lead counsel (Carbo) and local defense counsel (Gavish) to falsely maintain a defense or pervert the due administration of justice.
- 207.190 (Coercion): It is unlawful for a person, with the intent to compel another to do or abstain from doing an act which the other person has a right to do or abstain from doing.
B. Nevada Rules of Professional Conduct (NV RPC)
- 1.2(d) (Scope of Representation): A lawyer shall not counsel a client to engage, or assist a client, in conduct that the lawyer knows is criminal or fraudulent.
- 3.1 (Meritorious Claims and Contentions): A lawyer shall not bring or defend a proceeding, or assert or controvert an issue therein, unless there is a basis in law and fact for doing so that is not frivolous.
- 3.3 (Candor Toward the Tribunal): A lawyer shall not knowingly make a false statement of fact or law to a tribunal or offer evidence that the lawyer knows to be false.
- 3.4(b) (Fairness to Opposing Party and Counsel): A lawyer shall not falsify evidence, counsel or assist a witness to testify falsely, or offer an inducement to a witness that is prohibited by law.
- 8.4(c) (Misconduct - Dishonesty & Deceit): Prohibits engaging in conduct involving dishonesty, deceit, or misrepresentation to manipulate legal outcomes.
- 8.4(d) (Prejudice to the Administration of Justice): Prohibits engaging in tactics designed solely to prejudice the tribunal, delay merits-based determinations, and undermine the integrity of judicial proceedings.
VIII. COMPOUNDING DAMAGE, JUDICIAL COLLUSION, AND PENDING MOTION FOR TERMINATING SANCTIONS
As the result of Respondent’s perjured declarations, the presiding judge granted Defendant Cellular Sales’ Motion for Shortened Time by relying directly on fraudulent evidentiary submissions, including a fabricated transaction receipt and perjured declarations.
Also, Complainant was forced to withdraw and pull the entry of default to avoid wasting scarce judicial resources and expending extensive time litigating a Motion to Set Aside built entirely on perjured statements.
Furthermore, defense counsel's fraudulent filings and bad-faith maneuvers occurred in tandem with obvious judicial favoritism and collusion by the presiding judge. This forced Complainant to file a formal motion to disqualify the judge.
Most critically, Complainant filed an emergency Motion for a Temporary Restraining Order (TRO) on June 23, 2026. Due to the collusive and bad-faith actions of Respondent and co-counsel in manufacturing false extensions and corrupting the record, Complainant has been completely denied a timely hearing on emergency injunctive relief, leaving ongoing irreparable harm unchecked indefinitely.
IX. DEMAND FOR DISCIPLINARY AND CRIMINAL SANCTIONS
Complainant specifically requests that the State Bar investigate Counsel Gavish for perjury, wire fraud, and bad-faith abuse of process, and issue emergency disciplinary suspensions and appropriate criminal indictments.
PENDING PROCEEDINGS: TWO FORMAL MOTIONS FOR TERMINATING AND PUNITIVE SANCTIONS (NRS 7.085)
PLEASE TAKE FORMAL NOTICE that due to the pervasive, continuous, and coordinated subornation of perjury, bad-faith litigation tactics, fraudulent submittals, and procedural extortion executed by defense counsel and corporate respondents, there are currently two separate formal motions for terminating and punitive sanctions pending before the Court:
-
■ First Motion for Terminating and Punitive Sanctions:
Filed against all named Defendants and defense counsel pursuant to NRS 7.085 (liability of attorney for maintaining frivolous, fraudulent, or bad-faith filings) and the inherent powers of the Court, seeking the immediate strike of defense pleadings, entry of default judgment, and punitive monetary assessments.
Defendants are in procedural default regarding Complainant’s Motion to Strike Baseless Filings and for Sanctions. Pursuant to the Nevada Rules of Civil Procedure and local court rules, Defendants were required to file and serve any opposition within the mandatory statutory timeframe.
Defendants completely failed to submit an opposition or request an extension of time, allowing the deadline to pass without response. Under local rules, an opposing party's failure to serve and file a written opposition constitutes a consent to the granting of the motion. Consequently, Defendants have conceded the factual and legal grounds set forth in the motion, rendering the requested sanctions and procedural remedies fully ripe for judicial entry by default.
■ Second Motion for Terminating and Punitive Sanctions: Filed as a standalone, targeted motion directly addressing the subsequent bad-faith maneuvers, continued reliance on known perjured declarations, manufactured procedural delays, and extortionate demands conditioning the withdrawal of moot filings upon the unlawful surrender of private web domains.
PENDING CRIMINAL ACTIONS
In tandem with this complaint, Complainant is seeking criminal prosecution of Respondent in the State of Nevada, the State of Texas, and at the federal level, as detailed herein along with other co-conspirators.
