Free Declaration in Support - District Court of California - California

Case 5:07-cv-02795-JW

Document 13

Filed 06/29/2007

Page 1 of 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

LAW OFFICES OF BRANDON A. BLOCK Brandon A. Block (State Bar No. 215888) 6535 Wilshire Boulevard Suite 203 Los Angeles, California 90048 Telephone: 310.562.7749 Facsimile: 310.496.1420 Attorneys Appearing Specially for Defendants EDWARD H. OKUN, OKUN HOLDINGS, INC., INVESTMENT PROPERTIES OF AMERICA, LLC, and RICHARD B. SIMRING UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION ANITA HUNTER, Plaintiff, vs. EDWARD H. OKUN, OKUN HOLDINGS, INC., INVESTMENT PROPERTIES OF AMERICA, LCC, RICHARD B. SIMRING, and DOES 1 through DOES 50, inclusive, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

CASE NO. C07 02795 JW DECLARATIO OF SPECIALLYAPPEARI G DEFE DA T RICHARD B. SIMRI G I SUPPORT OF SPECIALLY-APPEARI G DEFE DA TS' MOTIO TO DISMISS FOR LACK OF PERSO AL JURISDICTIO Date: Time: Courtroom: Judge: September 17, 2007 9:00 a.m. 8, 4th Floor Hon. James Ware

[Notice of Motion, Motion to Dismiss, Declaration of Edward H. Okun and [Proposed] Order filed concurrently herewith]

DECLARATION OF SPECIALLY-APPEARING DEFENDANT SIMRING--CASE NO. C07 02795 JW

Case 5:07-cv-02795-JW

Document 13

Filed 06/29/2007

Page 2 of 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14
6535 WILSHIRE BOULEVARD, SUITE 203, LOS ANGELES, CALIFORNIA 90048

DECLARATIO OF SPECIALLY-APPEARI G DEFE DA T RICHARD B. SIMRI G I, Richard B. Simring, hereby declare: 1. I am a Florida-licensed attorney in good standing who has been employed since

January 1, 2007 as General Counsel of Okun Holdings, Inc. Before then, I was a partner in the law firm of Jorden Burt LLP in Miami, Florida. I am specially appearing to submit this declaration in support of the Motion to Dismiss plaintiff Anita Hunter's Complaint for Lack of Personal Jurisdiction filed by myself and the other specially-appearing defendants to this action. I have personal knowledge of the facts set forth herein and, if called as a witness, I could and would testify competently to these facts. 2. 3. I am a resident of Miami-Dade County, State of Florida. I do not have a residence, mailing address, telephone number, bank account,

investment account, office, agents or a place of business in California. 4. 5. 6. 7. 8. I do not operate, conduct, engage in or carry on any business in California. I do not own, lease or possess any real property in California. I do not pay income or property taxes to the State of California. I never have commenced a legal action in a court located in California. I have never been an owner of 1031 Advance, Inc., and have never been involved in

15 16 17 18 19 20 21 22 23 24 25 26 27 28

BRANDON A. BLOCK

its day-to-day operations. I have never even been to Advance's office in California, and I do not even know its address. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed this 29th day of June 2007 at Hialeah, Florida. /s/ Richard B. Simring SIGNATURE ATTESTATION I hereby attest that I have on file all holograph signatures for any signatures indicated by a "conformed" signature (/s/) within this efiled document. /s/ Brandon A. Block -1DECLARATION OF SPECIALLY-APPEARING DEFENDANT SIMRING--CASE NO. C07 02795 JW

LAW OFFICES

OF