Free Affidavit in Opposition to Motion - District Court of Arizona - Arizona

ALIG-UT-DE lZl4:24Pl·l FROM- T-lall P.UUl/DB2 F-EEE
l Don P. Williams (AZ State Bar No. 002978)
LAW OFFICE DF DON P. WILLIAMS
2 P. O. Box 5308
Goodyear, AZ 85338-0605
3 .
Phone: 623.297.42I I
4 Fax: l,623.321.8026
Email: Donalcl.Willianis@azbar.¤tg
5
Attorney for Defendatltfal
6
- 7 UNITED STATES DISTRICT COURT
3 DISTRICT OF ARIZONA
9
lll Century 21 Real Estate Corporation, No. CIV 03 2353-PHX-DGC
ll Plaintiff} UNSWORN DECLARATION
` UNDER PENALTY OF PERJURY
I2 vs. OF
I3 Daryush B. Motlagh and Jennifer SCOT A. MARTIN
14 Motlagh, husband and wife; Integrity
Assurance, Inc., an Arizona corporation, Him- David Gl Campbell
I 5 Defendant
I6
17 I, Scot A. Martin, make this declaration under the authority of 23 U.S.C. § 1746,
is and declare as fellows: .
lg l. My name and address are: Scot A. Martin, 902 W. Portland, Phoenix, AZ
gn 35007.
2] 2. I a.m a licensed real estate Salesperson [AZ SA537609Dfl0]. I ani -
gg associated with Brand l Realty as a sales agent. My supervising broke is D..I. Motlagh.
gg 3. I have been asked to make this declaration in support of Daryush B.
24 Motlagh, and I do so without compulsion, fear, or threat of retaliation.
25 4. I understand that this statement is made just as ifi were testifying in a
gg. court of law from the Witness stand.
27 5. I have personal knowledge ofthe facts set forth in this declaration.
gg 6. My Original License Date is ll/18/2002. After working for John Hall and
Associates, Inc., I have been associated with Brand l Realty [formerly CENTURY 2l
ase 2:O3—cv—O2353-DGC Document 82 Filed O8/O7/2006 Page 1 of 2
Declaration ofScot A. Martin

AUG-EIT-UB |Z|4=24PM FROM- T-lQ|ZI P.|ZID2/|Z||Z|2 F-EUQ
I Assurance Realty] from 9/3/2003 to the present. Daryush Motlagh is my supervising
5 broker.
5 7. My personal opinion of D..I. is that he is a great person, very fair. I've had
4 other offers for a higher commission, and I have turned them down because of DJ.
5 8. When I looked up D.J.'s office on the internet to apply for ajob there was
6 no number listed. I called the main Century 21 number and still couldn't get a phone
7 number. I had to come to the office and get the number to set an appointment. The
5 Century 2l website directed me to CENTURY 2l Metro Alliance.
9 9. During my association with D,]. as CENTURY 2l Assurance Realty, I did
*0 have clients say they could not End us in the computer, or through the locater system.
' ' l0. D.J. always paid my commissions on time. I am not aware of any time
*5 when he did not pay a Salesperson's commission on time.
I5 l 1. I believe that since our di sassociation from Century 2l and the change to
M Brand I Realty, our business has improved because D..l. has given us a lot more freedom
I5 to grow,.
1*5 I2. Iwould describe the service of Century 2l Corporation to CENTURY 2l
W Assurance Realty as poor.
'5 I3. I would describe the professional image and standards ofthe office as
'9 managed by D..I., compared to other offices I have worked in or observed, as very good.
20
El I declare under penalty of perjury that the foregoing is true and correct.
22
35 Executed on this day of August, 2006.
24 _ .. rf r. y ?
25 , Y n /4 T-ry
26 can _$cot`A. Martin =`_r_-I---E
27
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ase 2:O3—cv—O2353-DGC DocggmgpgniiggcullAlfiiildrirt)8/O7/2006 Page 2 of 2

Case 2:03-cv-02353-DGC

Document 82

Filed 08/07/2006

Page 1 of 2

Case 2:03-cv-02353-DGC

Document 82

Filed 08/07/2006

Page 2 of 2