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
I. PRELIMINARY STATEMENT
In the course of representing Cellular Sales of Knoxville, Inc. (“CSOKI” or “Cellular Sales”), Counsel Jonah Gavish and lead national counsel C. Larry Carbo, III personally executed and submitted 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, extensions, and counsel retention.
On August 2, 2026, defense counsel officially docketed a Motion to Set Aside Default that re-asserted these same false claims under penalty of perjury.
Concurrently, defense counsel engaged in the continuous subornation of perjury by procuring, submitting, and maintaining the fraudulent sworn declarations of both Jonah Gavish and 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 the Motion to Strike First Amended Complaint (FAC) on August 17, 2026.
II. PROCEDURAL HISTORY
1. Background
Respondents represent 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, defense counsel sought an emergency Order Shortening Time (OST) to set aside the clerk's default.
To induce the Court into granting emergency relief, defense counsel manufactured and attached two fraudulent declarations executed under penalty of perjury: one by Counsel Gavish and one by Counsel Carbo.
In these filings, Respondents 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.
3. Further Subornation of Perjury
Following this notification, Counsel Works assumed lead Nevada 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 of both Gavish and Carbo.
Works initially sought to secure a swift dismissal by falsely characterizing the corporate structure and jurisdictional footprint of CSOKI. In their initial Motion to Dismiss filed on August 2, Defendants asserted that CSOKI was merely a local Tennessee entity with zero operational connections to the State of Nevada.
This core factual claim was directly disproven when Complainant produced official state regulatory filings identifying Pamela White (Chief Financial Officer of CSOKI) and Thomas K. Reeves (Chief Counsel of CSOKI) as designated local managers.
Confronted with undeniable public records demonstrating local management authority, Works suborned perjury of Carbo a second time on August 17, 2026 caliming that CSOKI had no operations or connections to Nevada. However, Works abruptly withdrew the August 17 Motion to Dismiss and refiled a revised motion on August 18. To circumvent the official state filings, Works attached a sworn declaration from Pamela White containing deliberate misrepresentations:
Contradictory Corporate Positioning: While acknowledging CSOKI’s status as a broad corporate enterprise to account for her newly exposed managerial role, White explicitly denied under penalty of perjury that CSOKI maintains any business dealings, operations, or presence in Nevada. Omission of Local Leadership Structure: This denial was executed despite full knowledge that CSOKI maintains regional executive leadership—including regional presidents operating within Nevada—actively managing core elements of the business within the jurisdiction.The tactical withdrawal and immediate refiling of the Motion to Dismiss on August 18—supported by White’s perjurious declaration—demonstrates a deliberate effort to alter factual positions in bad faith when exposed by public records, misleading the tribunal to avoid state court jurisdiction.
4. Pattern of Judicial Misrepresentations and Suborned False Statements
Counsel Works, acting in concert with corporate representatives, has engaged in a calculated pattern of material misrepresentations, suborned perjury, and bad-faith litigation tactics in direct violation of Nevada Rules of Professional Conduct (RPC) 3.3 (Candor Toward the Tribunal), RPC 8.4(c) (Misconduct), and NRS 199.120 (Perjury and Subornation of Perjury). Specifically, counsel knowingly procured, prepared, and submitted four (4) demonstrably false declarations and representations to the Court, knowing full well that the underlying factual assertions were completely fabricated:■ August 2, Affidavit / Submission (Gavish): Suborned and filed a sworn declaration containing false assertions regarding corporate operations and jurisdictional contacts, specifically alleging that CSOKI maintains no business operations or presence in the State of Nevada despite clear records to the contrary.
■ August 2, Submission (Carbo): Made direct affirmative representations to the Court reiterating and endorsing the fabricated factual assertions regarding CSOKI’s Nevada operations and falsely framing jurisdictional boundaries.
■ August 17, Submission (Carbo): Submitted a material misrepresentation to the tribunal falsely claiming that Complainant had entered into or agreed to a binding stipulation, knowing that no such agreement existed and that Complainant had explicitly rejected counsel's demands.
■ August 18, Affidavit / Submission (White): Procured and submitted a false declaration reinforcing the fabricated narrative regarding corporate structure and jurisdictional contacts to mislead the Court on core material issues.
5. Retaliatory Conduct and Bad-Faith Bad-Faith Tactics
When Complainant refused to capitulate to counsel’s coercive demands to surrender ownership and rights to the domain/website, counsel engaged in direct administrative and procedural retaliation:■ Frivolous Vexatious Litigant Motion: Counsel fabricated procedural grounds to move the Court to declare Complainant a "vexatious litigant" solely as a coercive tool to evade scrutiny on the false filings.
■ Refusal to Conduct Early Case Conference: Counsel deliberately breached mandatory pre-trial obligations by refusing to participate in or conduct an Early Case Conference as required by Nevada Rules of Civil Procedure.
■ Ex Parte Communication Blockade: Counsel unilaterally blocked Complainant’s electronic communications, preventing meet-and-confer attempts while simultaneously misrepresenting to the Court that Complainant was refusing to cooperate.
This systematic submission of known false declarations constitutes a deliberate fraud upon the tribunal, designed to improperly secure a dismissal on fabricated grounds and punish a self-represented party for refusing to submit to extortionate settlement demands.
6. Demands to Withdraw Perjured Statements
To date, Complainant has issued multiple formal demands to all parties—including Respondents Gavish and Carbo—requesting the immediate withdrawal of the perjured submissions, but these demands have been consistently ignored.
7. 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.
III. SUBMITTAL OF PERJURIOUS DECLARATIONS
1. Fabrication, Execution, and Submission of False Declarations Under Penalty of Perjury
■ Respondents Gavish and Carbo, acting as counsel for Cellular Sales, drafted, executed, and submitted sworn written declarations under penalty of perjury containing deliberate material falsehoods regarding corporate presence, service of process, litigation extension agreements, and representation retention.
■ Respondent Pamela White, acting as CFO for Cellular Sales, drafted, executed, and submitted sworn written declaration under penalty of perjury containing deliberate material falsehoods regarding corporate presence and service of process.
■ Respondent Works 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 false declarations under penalty of perjury by officers 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 (Gavish & Carbo) vs. Documented Public Record
Below is a comparative account exposing the direct contradictions between the sworn statements executed under penalty of perjury in the Declarations of Counsel Gavish and Counsel Carbo versus 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:
A. Declaration of Jonah Gavish vs. Objective Evidence
| 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. |
B. Declaration of Larry Carbo vs. Objective Evidence
| FALSE STATEMENT (Carbo Declarations - 7/31/26 & 8/2/26) | DOCUMENTED FACT & PUBLIC RECORD |
|---|---|
| FALSE STATEMENT 1 - ¶ 5): “CSOKI contacted me about assisting it in obtaining local counsel in this matter. On July 28, 2026, I connected CSOKI with McDonald Carano LLP.” |
FACT 1: During the initial teleconference, Complainant was informed that Defendant Cellular Sales had not yet been assigned counsel. This representation was almost immediately contradicted: as soon as Complainant agreed to the requested extension, defense counsel revealed that Counsel Gavish had already been assigned to the case. It is implausible that local counsel was retained within minutes of that phone call. Rather, the extension was deceptively sought to align pleading deadlines with the August 11 TRO hearing. |
| FALSE STATEMENT 2 - ¶ 7: “Plaintiff answered the phone, and during the conversation, I requested a two-week extension to August 11, 2026 to respond to the complaint in this matter. Plaintiff agreed to the extension.” |
FACT 2: Complainant agreed solely to an extension to respond to the FAC. When Defendants refused to accept electronic service of the FAC, the conditional extension was revoked. |
| FALSE STATEMENT 3 - ¶ 9: “Based on these communications, CSOKI understood and reasonably relied on Plaintiff’s agreement that its time to respond was extended... CSOKI was never served and CT Corporation System is not CSOKI’s agent.” |
FACT 3: When executing declarations on July 31 and re-submitting them on August 17, Respondent Carbo acted with actual knowledge that: (1) Complainant explicitly rejected the proposed stipulation; (2) The FAC had been formally served on C T Corporation System; and (3) Official Nevada Secretary of State filings establish C T Corporation System as CSOKI’s registered agent. The August 17 Motion to Dismiss was abruptly withdrawn once these falsehoods were exposed. |
| FALSE STATEMENT (Carbo Declarations 8/2/26) | DOCUMENTED FACT & PUBLIC RECORD |
|---|---|
| FALSE STATEMENT 1 - ¶ 7: “CSOKI has no contacts with Nevada.” |
FACT 1: CSOKI manages the Nevada stoores. |
| FALSE STATEMENT 2 - ¶ 11: “Service was directed at CSON. Plaintiff attempted service by delivering process to CT Corporation System, the registered agent of CSON, on or about July 7, 2026. That agent is not CSOKI’s agent and is not authorized to accept service on CSOKI’s behalf.” |
FACT 2: Service was directed at CSOKI and was accepted by CT Corporation and subsequently served on defendant. |
C. Declaration of Pemala White vs. Objective Evidence
| FALSE STATEMENT (White Declaration - 8/18/26) | DOCUMENTED FACT & PUBLIC RECORD | FALSE STATEMENT 1 - ¶ 6: CSOKI has no employees, conducts no operations, and generates no revenue independent of its subsidiaries. |
Corporate Leadership Claim: Cellular Sales' corporate headquarters in Knoxville, TN states that executive management sets mission-guided leadership across nationwide operations. Executive officers, including Pamela White (CFO), manage store operations centrally. |
|---|---|
| FALSE STATEMENT 2 - ¶ 8: Cellular Sales of Nevada, LLC (“CSON”) is a wholly owned subsidiary of CSOKI. CSON does not act as an agent of CSOKI in Nevada and conducts no business on its behalf. |
Regional Nevada Leadership: Cellular Sales lists 34 regional management personnel on its corporate platform. For Nevada, Angel Caraballo (Regional Director/President) and Aaron Schmidt (Regional President) are designated managers directing sales and store operations. |
| FALSE STATEMENT 3 - ¶ 9: CSOKI and CSON maintain separate corporate records, bank accounts, management, and governance. CSOKI does not commingle funds. |
Retail Operations Structure: Cellular Sales operates as Verizon's premier retail partner with nearly 850 stores across 45 states, utilizing unified executive governance from its Knoxville headquarters. |
| FALSE STATEMENT 4 - ¶ 10 & 12: CSOKI does not exercise control or discretion over day-to-day operations, business activities, or policies of CSON, nor sets operational policies. |
National Management Presence: Regional leadership profiles on platforms such as LinkedIn and RocketReach show regional executives oversee employee training, recruitment, retention, and operational management under the corporate umbrella of Cellular Sales. |
| FALSE STATEMENT 5 - ¶ 11: CSOKI has no involvement in the hiring, training, supervision, or management of CSON employees. |
Regional Management Scope: Regional leadership in Las Vegas, NV (e.g., Angel Caraballo) actively maintains operational duties including Employee Training, Recruiting, and Team Leadership for Cellular Sales locations. |
| FALSE STATEMENT 6 - ¶ 13: CSOKI has no possessory interest in property at 3825 S. Maryland Pkwy, Ste. A, and does not operate or control CSON operations at this location. |
Retail Presence: The location operates as an authorized retail storefront within Verizon Wireless's network serviced by Cellular Sales regional leadership. |
| FALSE STATEMENT 7 - ¶ 14: CSOKI was not a party to any transaction with Plaintiff, had no contract or interaction with Plaintiff, and had no involvement in events giving rise to this action. |
Cellular Sales Parties Definition: Encompasses Cellular Sales of Knoxville, Inc., Cellco Partnership d/b/a Verizon Wireless, and their respective subsidiaries, affiliates, members, officers, directors, and agents. |
IV. REGIONAL LEADERSHIP DISCLOSURES
- 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.
- 205.320 (Extortion): Attorneys can be charged directly under this statute for conspiring with co-counsel, court clerks, or judicial officers to obstruct justice, subvert procedural defaults, or violate due process rights.
- 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.
- 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.
■ 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
V. 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, clickVI. APPLICABLE FEDERAL, STATE, AND PROFESSIONAL VIOLATIONS
A. Nevada Revised Statutes (NRS - Criminal & Civil Misconduct)
B. Nevada Rules of Professional Conduct (NV RPC)
VII. 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:
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■ 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.
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.
RELATED SITES
The following independent websites were created and maintained as public-interest consumer advocacy platforms. These specific domains constitute the primary subject matter of this complaint, serving as direct evidence of unauthorized account lockouts, contract concealment, targeted service disruption designed to suppress public consumer verification, perjury, and extortion.
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