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"I, Patrick Miletich, declare as follows:

1. I am currently the President of Miletich Fighting Systems Corp., a mixed martial arts ("MMA") training facility, which is based in Iowa. I have personal knowledge of and am competent to testify to the facts set forth in this declaration. I make this Declaration in support of the Defendants' opposition to Plaintiff Zuffa, LLC's ("Zuffa") Motion for Preliminary Injunction in Zuffa, LLC v. International Fight League, Inc., et al., which is pending in the Eight Judicial District Court, Clark County, Nevada, Case No. A516841.

2. Since 1996 I have trained fighters in the world of mixed martial arts. Prior to opening my training facility in Iowa, I participated in many MMA organizational bouts and competitions throughout the world. In fact, in 1996 I became the Welter Weight World Champion and was able to hold that title for about 3 1/2 years.

3. Because of my reputation as a world-class MMA champion and trainer, my training facility currently has an enrollment of about 1,200 members, and I personally train about 40 professional fighters, several of whom are Champions, who fight in MMA organizations around the world, including the Ultimate Fighting Championship ("UFC"), and smaller organizations like PRIDE, Superbrawl, Extreme Challenge and King of the Cage. In addition, I regularly have several professional fighters that participate in almost every UFC event put on by Zuffa in the United States.

4. In or around Junr or July 2005, I recieved a call from Kurt Otlo. Kurt introduced himself to me and proceeded to pitch his (and Gareb Shamus') idea for the International Fight League ("IFL"). I was extremely excited about the IFL and its unique business concept because it would (a) provide a significant avenue for my fighters to fight and earn a living (which isn't easy) and (b) help establish additional notoriety and exposure of the MMA industry in the United States.

5. After numerous discussions with Kurt, I agreed to caoch a team of fighters from my gym who would participate in the IFL. Indeed, I am in the midst of training a team for the IFL's first pre-season event. I also told Kurt that he should call Monte Cox, a manager of prominent fighters in the MMA industry who also might be interested in assisting the IFL get off the ground by supplying additional fighters to the IFL.

6. In or around mid-January 2006 I attended a UFC show at the Hard Rock Cafe and Casino in Las Vegas called "Ultimate Fight Night" which was aired on SPIKE television. At the show I was joking around with Joseph Silva, the "Matchmaker" for the UFC. At one point I jokingly put my foot against his stomach like I was throwing a side-kick in slow motion. Dana White, Zuffa's President, was standing next to Mr. Silva when I did this. Observing my antics, Mr. White turned to me and said in a joking manner "Oooh! An IFL side-kick", which I took to mean that he could care less that I was going to be involved in the IFL and that he didn't think it was a big deal. Apparently, I was wrong.

7. Before the fights started at the Hard Rock Cafe and Casino I asked to speak with Mr. White alone. I said to Mr. White, "you know this [IFL] is going tobe good for the sport", to which he shook his head, smiled and said "yes". I really felt that it was important that he and I saw eye-to-eye on this matter.

8. In or around late Januray 2006, I recieved a call from Mr. White. During the conversation, Mr. White stated that he respected me both as a trainer and fighter, but then proceeded to express in a rather irate manner his feelings about the IFL and abruptly stated that "he was going to ****ing crush these [the IFL] guys". Mr. White further made it clear to me that he was livid about losing Keith Evans to the IFL.

9. During this conversation I expressed to Mr. White my opinion (based on numerous conversations with individuals in the MMA industry) that a lot of people involved in MMA industry didn't very much care for him or the way Zuffa conducted its business and treated the individuals who fought at UFC events. In response, Mr. White stated that it "wasn't his ****ing job to be liked". Mr. White further told me that he had spoken with the Fertittas (who own Zuffa), and they had given their "permission" to go after the IFL.

10. Mr. White further threatened me during the conversation, and implicitly the livelihoods of the fighters I train, stating that "when the dust settles, anyone associated with the IFL would not be associated with the UFC". I took this for what it was -- a threat to me and to my fighters who count on me to represent them and obtain opportunities to for them to fight in the MMA industry. Because of the virtual monopoly that Zuffa has in the MMA industry, Mr. White clearly knew that cutting me and my fighters off from the UFC would have a devastating economic impact.

11. Mr. White further told me during this conversation that he had been on the phone all day calling everyone he dealt with in the MMA industry and told me that, after speaking with all of them, none would be doing business with the IFL. My understanding from his comment was that he had made the same threats to everyone else he knew in the MMA industry that he had just made to me during our conversation. I attempted to tell Mr. White to calm down and tried to be rational with him. I expressed to Mr. White my opinion that the IFL was going to help the MMA industry and ultimately would increase the UFC's presence throughout the world. I further attempted to dissuade Mr. White from doing anything irrational with respect to the IFL (i.e., the lawsuit) and told him that I felt going after the IFL for no reason would be very bad for the entire MMA industry. Clearly, Mr. White could care less what I thought.

12. Following my conversation with Mr. White, Ken Shamrock, another world-renowned MMA fighter, called me and told me that Mr. White had just "raised hell" with him about his being associated with the IFL. As I understand it, Mr. White had made similar threats to Mr. Shamrock whom I believe at the time had an agreement with the IFL to coach one of its teams. I further understand that Mr. White made the same or similar threats to Randy Couture, perhaps one of the most legendary MMA fighters in the world and a former UFC World Champion. I further understand that Mr. White called a current UFC World Champion, Matt Hughes, to inquire of him whether he had any involvement in the IFL.

13. Knowing Mr. White the way I do, I can honestly say that Zuffa's intent is bringing this litigation has nothing to do with protecting any confidential information. Rather, I believe this litigation is about one thing and one thing only -- stamping out legitimate and, indeed, healthy, competition.

I declare under penalties of perjury that the foregoing is true and correct."



MMA WEEKLY





An interesting read that sheds some light into just how ruthless Dana White is.
 

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F*ck You I Rhyme Better
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good post...

this sint the first time ive heard of Dana White doin somethin like this

i remember Ken Shamrock invited the owner of "WFA" to his Tito vs Ken II fight.. within minuites of the WFA owner sitting in his seat.. security guards came up to him and told him he had to leave... even after pleading with them and telling them.. Ken Shamrock gave him his ticket.. they didnt seem to care.. and when he asked why he is getting kicked out they gave him no answer and just told him he had to go.....and escorted him outside of the building
 

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Good article, very interesting. There does'nt appear to be a good reason for White to getting so worked up about this. Ultimately the IFL will provide talent for the UFC (more than take talent away from it)and will give UFC fighters past their prime and fighters struggling with their careers a place to earn a living.
 

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True Grappler
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Dana's protective of his organization and he really thinks that any form of competition will decrease his profits. He doesn't seem aware that he's projecting a bad image.
 

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I always knew Dana was an ass but wow. He is afraid of competition, but what it comes down to is who can put on the better show. There is nothing wrong with competition, that is what MMA is about.
 

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i wish pat miletich and Mr. White would just settle it in the ring.
 

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well....Dana always comes across hard...it is business....but he is blind if he cant see that other shows will end up helping the entire MMA communitty....
 

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MMA freak said:
Why did they escort the WFA owner out of the building? Dana must be a real hard ass, he always sounds intimidated. Escorting the WFA owner, not allowing his fighters to go to PRIDE, not allowing PRIDE fighters to come here, money deals, always something.

I agree with you except for the fact that Dana White did allow Chuck Liddell to go fight Rampage at a Pride show (he probably regrets doing that). Pride was supposed to recipricate but did not. Maybe that situation has figured into his reasoning here.
 

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canadian champ
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MMA freak said:
Yeah, he let Chuck go over to fight in PRIDE FC. Chuck didn't do all bad, he destroyed Alistair as you can see in one of the clips in my signature. And then he was destroyed by the second best light heavyweight at the time in PRIDE FC. This is a main reason like you said why Dana probably refuses to compete with any other MMA organizations due to the experiences, money, talent, etc.
Alistar almost bqat chuck he rocked him really good and almost beat him. But he was mauled by rampage. It's not like dana sent him to fight just rampage it was a tournament style event. Dana also bet 1 million dollars on chuck.
 

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I never knew he was such a ****! Thats pretty messed up. I think those guys should be able to do what they want and fight where they want.
 

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Organik said:
good post...

this sint the first time ive heard of Dana White doin somethin like this

i remember Ken Shamrock invited the owner of "WFA" to his Tito vs Ken II fight.. within minuites of the WFA owner sitting in his seat.. security guards came up to him and told him he had to leave... even after pleading with them and telling them.. Ken Shamrock gave him his ticket.. they didnt seem to care.. and when he asked why he is getting kicked out they gave him no answer and just told him he had to go.....and escorted him outside of the building
yup herd about that, i hate dana personally LOL
 

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wasnt the guy handing out WFA flyers at the ufc event? i am sure i read it some where on this forum, if not it was another one.
id give him the boot as well....
 

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i dont understand it. dana should be open-minded. i respect everyone but for him to make threats and just to go after $..............damn. kinda seems like he is afraid of competition. he shouldnt put other organizations down. he should welcome them and tell them to enjoy themselves. go ahead dana, make urself look like an ass. fact is all his guys arent just gonna walk through everybody. pride all the way if u ask me, no bs there. y not let pride come fight in the ufc? he should help spread mma no contain it
 

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Amazing that WHite would be like this. Some small org trying to start up, prob only going to help UFC as they develope the talent for them, then white says down with IFL. What a peckerhead.:thumbsdown:
 

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cooley said:
wasnt the guy handing out WFA flyers at the ufc event? i am sure i read it some where on this forum, if not it was another one.
id give him the boot as well....
Thats what i heard too.
 

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The ONLY mistake Dana has made, is that he is always trying to get camera time. He wants to be a celebrity himself. Now when he is a ****head ( and you'd have to be to do that job to its fullest ) it casts a bad light over the UFC. If he just stayed in the shadows, we wouldn't have even heard of this. Dana will be the downfall of the UFC - one just has to look at Suge Knight to figure that one out. Dana, stay in the backround so you can do the job properly without screwing everybody around you
 

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putmeonhold said:
. Now when he is a ****head ( and you'd have to be to do that job to its fullest ) it casts a bad light over the UFC.

. Dana, stay in the backround so you can do the job properly without screwing everybody around you
first of all, every boss i had was and still is a di*ckhead. you cant always be a good guy when you have to help run a business. the only difference between my boss now and Dana is the fact he is on tv, to promote the sport and his fighters

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how is he screwing everyone around him?

not paying his fighter enough? if that is the caser then they DONT have to stay with him.
 
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