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 bad-faith litigation, deceit, and subornation of perjury executed by defense counsel C. Larry Carbo, III. Serving as national defense counsel, Carbo has actively directed and executed a scheme to submit fraudulent sworn declarations, mislead the tribunal, and suppress material facts regarding corporate nexus and service of process. When confronted with conclusive state agency records disproving his assertions, Carbo engaged in bad-faith maneuvers and abrupt procedural withdrawals, choosing to corrupt the judicial record and harass the Complainant rather than adhere to basic duties of candor to the court.
I. PRELIMINARY STATEMENT
In the course of representing Cellular Sales of Knoxville, Inc. (“CSOKI” or “Cellular Sales”), Respondent C. Larry Carbo, III personally executed and submitted three separate sworn declarations containing false material statements under penalty of perjury to the Eighth Judicial District Court.
On July 31, 2026, Respondent Carbo executed an initial perjured declaration transmitted ex parte to judicial chambers regarding service of process, corporate nexus, and local counsel retention.
On August 2, 2026, Respondent Carbo’s perjured declaration was formally docketed in support of a Motion to Set Aside Default.
On August 17, 2026, Respondent Carbo executed and docketed a third fraudulent declaration in support of Defendant Cellular Sales’ Motion to Dismiss, re-asserting identical material falsehoods. However, when confronted with conclusive public records from state agencies establishing the falsity of these claims, defense counsel abruptly withdrew the motion—confirming that Respondent Carbo's sworn statement was knowingly false when submitted.
II. 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 Respondent Carbo, who identified himself as national coordinating counsel for Cellular Sales. Respondent 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, Respondent Carbo transmitted an email thanking Complainant for the extension and introducing Counsel Jonah 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 Respondent 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 Perjured Declarations (July 31 & August 2, 2026)
On July 31, 2026, defense counsel 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 attached two fraudulent declarations executed under penalty of perjury: one by Counsel Gavish and one by Respondent Carbo.
In these filings, Respondent Carbo intentionally concealed material facts from the tribunal—specifically omitting any mention that local counsel 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.
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 Respondent Carbo's perjurious declaration.
3. Third Perjured Declaration & Abrupt Motion Withdrawal (August 17, 2026)
Demonstrating a persistent pattern of bad-faith litigation and deliberate perjury, Respondent Carbo executed and filed a third fraudulent declaration on August 17, 2026. Electronically docketed at 1:53 PM in support of Defendant Cellular Sales’ Motion to Dismiss, Respondent Carbo once again swore under penalty of perjury to identical material falsehoods—specifically claiming that CSOKI has no registered agent in Nevada, was never properly served, and bears no corporate relationship or operational oversight over Nevada retail locations.
Despite defense counsel Larry Carbo’s assertions that Cellular Sales of Knoxville, Inc. (CSOKI) maintains no operational or corporate connection to Nevada, official state records and corporate declarations demonstrate otherwise:
■ Corporate Registration Records: Corporate filings registered with the Nevada Secretary of State explicitly list CSOKI Chief Financial Officer Pamela White and Chief Legal Counsel Thomas K. Reeves as designated managers of Cellular Sales' active Nevada business entities.
■ Operational Leadership in Nevada: Cellular Sales officially assigns two regional Presidents, Angel Caraballo and Aaron Schmidt, to oversee operations directly within Nevada.
■ National Governance & Workforce Oversight: Beyond local management, Caraballo and Schmidt are tasked with executing standardized employee training protocols, corporate compliance, and policy enforcement across Cellular Sales' national footprint of over 850 retail locations spanning 45 states.
4. Demands to Withdraw Perjured Statements
To date, Complainant has issued multiple formal demands to Respondent Carbo requesting the immediate withdrawal of the perjured submissions, but these demands have been consistently ignored.
5. Partners in Crime
Parallel regulatory and criminal complaints against Counsel Gavish, Counsel Works, and Respondent Carbo are being lodged concurrently across state and federal jurisdictions for identical statutory and administrative violations.
III. SUBMITTAL OF PERJURIOUS DECLARATION
1. Fabrication, Execution, and Submission of False Declarations Under Penalty of Perjury
■ Respondent Carbo, acting as lead national coordinating counsel, drafted, executed, and submitted sworn written declarations under penalty of perjury containing deliberate material falsehoods regarding corporate presence, service of process, and extension negotiations.
■ Respondent Carbo 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 on Cellular Sales' registered agent.
■ The deliberate execution and docketing of false declarations under penalty of perjury across multiple filings (July 31, August 2, and August 17) constitutes active fraud on the court, direct perjury, and an intentional subversion of the judicial process.
2. Evidentiary Audit: Comparison of Sworn Declarations of Respondent 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 Respondent Carbo 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 (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 Declaration 8/17/26) | DOCUMENTED FACT & PUBLIC RECORD |
|---|---|
| FALSE STATEMENT 1 - ¶ 7: “CSOKI has no contacts with Nevada.” |
FACT 1: CSOKI manages the Nevada stores. |
| FALSE STATEMENT 2 - ¶ 10: “CSOKI does not operate the 3825 S. Maryland Pkwy, Ste. A location and is not the employer of “Defendant Jackson.” |
FACT 2: CSOKI oversees the Nevada stores and Franklin Jackson was hired by CSOKI. Franklin Jackson is currently listed as an active employee with an operational corporate email address at franklin.jackson@cellularsales.com. |
| FALSE STATEMENT 3 - ¶ 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 3: Service was directed at CSOKI and was accepted by CT Corporation and subsequently served on defendant. Furthermore, the very fact that corporate counsel reached out and contacted Complainant on July 28 directly confirms that defendant received actual notice and was duly served. |
IV. 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
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 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 (Category D felony).
- 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 with local defense counsel to falsely maintain a defense or pervert the due administration of justice.
B. Texas Disciplinary Rules of Professional Conduct (TDRPC)
- 3.03 (Candor Toward the Tribunal): Making false statements of material fact or failing to disclose material facts to third persons.
- 4.01 (Truthfulness in Statements to Others): Making false statements of material fact or failing to disclose material facts to third persons.
- 4.04 (Respect for Rights of Third Persons): Using means that have no substantial purpose other than to embarrass, delay, burden, or violate the constitutional rights of a third person.
- 8.04(a) (Misconduct): Violating disciplinary rules, committing criminal acts reflecting adversely on honesty, engaging in conduct involving dishonesty, fraud, deceit, or misrepresentation, and obstructing justice.
- 8.05 (Jurisdiction): Subjecting an attorney admitted in Texas to discipline for misconduct occurring in another jurisdiction.
VII. 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, filing perjured declarations on three separate occasions, and corrupting the record, Complainant has been completely denied a timely hearing on emergency injunctive relief, leaving ongoing irreparable harm unchecked indefinitely.
VIII. 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.
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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