Cellular Sales Misrepresentations Regarding Nevada Operations
While Defendants Cellular Sales and their legal counsel asserted under penalty of perjury that Cellular Sales of Knoxville, Inc. maintains zero contacts with Cellular Sales retail locations in Las Vegas, publicly available records and corporate documentation directly refute these statements.
Specifically, the evidence demonstrates active operational management and recruitment occurring directly within Nevada:
■ Local Recruiter Contact: Rose Caraballo serves as a Nevada-based recruiter tasked with hiring and onboarding staff for local Cellular Sales locations. She carries out these responsibilities using corporate communications infrastructure, including her active corporate email address (rose.caraballo@cellularsales.com) and direct phone contact ((239) 560-2848).
■ Local Physical Presence: Operational control is further evidenced by local residency within Clark County, Nevada. Ms. Caraballo resides alongside Angel Caraballo—President of Cellular Sales' regional operations—at 6843 Compass St, North Las Vegas, NV 89084.
As set forth below, this documentation establishes a direct, continuous operational presence in Nevada, rendering Defendants' jurisdictional declarations factually inaccurate.
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 perjury, material misrepresentation, and bad-faith deceptive submittals executed by Cellular Sales executive Pamela White. Acting in her official administrative capacity while overseeing Nevada retail operations, White submitted false sworn declarations claiming Cellular Sales of Knoxville (CSOKI) maintains no operational footprint in Nevada. This sworn assertion stands directly contradicted by public corporate records, established regional management hierarchies, and active retail store operations in Nevada under her direct managerial oversight. White intentionally weaponized these perjurious statements to deceive the tribunal, obstruct jurisdictional discovery, and shield corporate entities from legal accountability.
I. EXECUTIVE PROFILE & DECLARATION ACCESS
Pamela White serves as Chief Financial Officer (CFO) and executive manager of Cellular Sales. Public records and corporate documentation detail the operational framework, subsidiary control structures, and regional management hierarchy across Cellular Sales entities, including Cellular Sales of Knoxville, Inc. ("CSOKI") and Cellular Sales of Nevada, LLC ("CSON").
Defense counsel 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, Defendants abruptly withdrew their August 17 Motion to Dismiss and refiled a revised motion on August 18. To circumvent the official state filings, Defendants 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.
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. |
II. 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
III. 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, clickIV. APPLICABLE STATE VIOLATIONS
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): Conspiracy to discredit Complainant's claims by way of a perjurious declaration.
V. 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.
VI. 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.
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.
