Stan Lee Media CEO Kenneth Williams Accused of Shareholder Fraud and Libel in Court Filing By Former Stan Lee Media Executive

Accusations Against Peter Paul Retracted and Corrected in Court Filing

LOS ANGELES, May 7 A sworn Declaration made by former Stan Lee Media, Inc. (Nasdaq: SLEEQ) Executive Vice President Stephen Gordon in January and reported in the Industry Standard and other media in the US, Europe and Asia, was corrected today in a "Further Declaration'' made by Gordon in a Los Angeles Superior Court action brought against Gordon & Paul by their former attorneys. The declaration contained new information regarding the activities of the current President and CEO of the internet-based public company built around comic book icon Stan Lee.

While Gordon's Declaration retracted and corrected allegations that Stan Lee Media Co-Founder Peter Paul had fled the United States, was the personal target of an informal SEC inquiry, and was hiding assets, Gordon added new information that he had learned from Stan Lee Media executives that the former Sony Digital Studios President, Kenneth Williams, was involved in a plan to "personally destroy'' Co-Founder Peter Paul and to bankrupt Stan Lee Media in order for him to personally acquire Stan Lee Media assets free of existing shareholders and creditors.

Gordon's filing was made just days after Interfase Capital, LP, an Austin- based venture capital firm, announced that it was providing debtor in possession financing for Williams' operations during reorganization of Stan Lee Media, which filed for Chapter 11 bankruptcy protection in February, 2001.

Interfase announced its plans to form a limited partnership that will acquire a substantial equity position in the reorganized company, which will be managed and co-owned by Kenneth Williams, according to insiders.

Following is the declaration of Stephen M. Gordon:

Stephen M. Gordon

14246 Valley Vista

Sherman Oaks, California 91423

In Pro Persona         

Defendant.

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF LOS ANGELES

BUCHALTER, NEMER, FIELDS & YOUNGER a Professional Corporation, Plaintiff,

vs.

STEPHEN GORDON; an individual; PETER PAUL, and individual; EXCELSIOR PRODUCTIONS, INC., a California corporation; WORLD NETWORK, INC., a Delaware corporation; and DOES 1 through 50 inclusive, Defendants.

CASE NO. BC 241984

FURTHER DECLARATION OF STEPHEN M. GORDON TO CORRECT "DECLARATION OF STEPHEN M. GORDON IN SUPPORT OF EX PARTE APPLICATION FOR WRIT OF ATTACHMENT BY BUCHALTER NEMER FIELDS, et al."

I, STEPHEN GORDON DECLARES AS FOLLOWS:

1.   I am over the age of 21 and a resident of the State of California.  I am a named defendant in the above-entitled action.  Accordingly, the following facts are true of my own personal knowledge and/or from my review of the documents I received in connection with that transaction.

2.   On January 21, 2001, I was requested by Jonathan Fink, Esq. to execute a Declaration in support of Ex Parte Application for Writ of Attachment against Peter Paul in connection with a lawsuit filed by BNF to collect disputed legal fees from BNF's clients, Peter Paul and myself.  I executed the declaration prepared by Mr. Fink on behalf of BNF to support his affidavits on file in this action.  I have subsequently learned that some of those facts Mr. Fink had me previously affirm in my declaration of January 21, 2001 to be inaccurate and/or false.

3.   I, therefore, file this affidavit to correct said facts and allegations:

4.   I erred in representing that Peter Paul uses his wife to shield assets and that Peter Paul represented she worked so he could hide income through her.  In fact, I knew that when I was first employed by Paul, his wife had her own personal assets which were used to fund the company I worked for.

5.   I knew that Peter Paul had no personal income to hide and that his services were compensated through a lend out company, Paraversal, Inc., listed in all SEC filings by Stan Lee Media, and that, in fact, Andrea Paul never received income intended for Paul.  In fact, I knew Paul never owned assets in his name the entire time I knew him because of a judgment for $10 million recorded against him in the Southern District of Florida by the Cuban Government under an unprecedented license to sue him given by then President Jimmy Carter to the Cuban Government in 1979 for that purpose, and, therefore, he never had personal assets to transfer or hide.

6.   I erred in assuming that Paul's accountant, John Temple, had "set up companies to help shield assets" for Paul.  All companies which Paul conducted business with in connection with John Temple were companies that existed prior to Paul's dealings and were legitimately established by Temple or his clients for legitimate and independent purposes unrelated to Paul.

7.  I erred in characterizing Paul's change of business address from Los Angeles to Brazil and Argentina as his fleeing the United States.  I subsequently learned that Paul has returned to the United States on more than one occasion and is legitimately engaged in international business while preparing for civil litigation against principals in various companies, including San Lee Media, which he maintains has tortuously terminated his consulting agreement.  I also learned that Stan Lee Media CEO Ken Williams has been the source of many news reports that libel Paul and misrepresent Paul's actions as a Founder and consultant for Stan Lee Media, and that Ken Williams has admitted to former Stan Lee Media executives his objective to "personally destroy Paul, and to tortuously interfere with Paul's relationship with Stan Lee to enable him to own the principal assets of Stan Lee Media by using bankruptcy as a means to eliminate creditors and shareholders of the company."

8.   I erred when I stated that Paul informed me that the SEC was investigating him personally, when in fact he stated that SEC began an informal inquiry directed at Stan Lee Media and he was never presented directly with any questions or subpoenaed by the SEC in connection with his personal actions.

9.   I erred when I represented that Paul and his wife had sold a lot they owned for far less than its fair market value, when in fact said property is and has always been owned exclusively by Mrs. Paul.

I declare under penalty of perjury of the laws of the State of California that the foregoing is true and correct and that this declaration was executed on May 2, 2001, at Beverly Hills, California.

Stephen M. Gordon