Case, 2:12-cv-08333-ODW-JC Document 123-1 Filed 04/18/13 Page 1of4 Page ID #:2827

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So So NHN aA SF WH WD

Timothy J. Halloran - 104498

Thomas P. Mazzucco - 139758

MURPHY, PEARSON, BRADLEY & FEENEY 88 Kearny Street, 10th Floor

San Francisco, CA 94108-5530

Tel: (415) 788-1900

Fax: (415) 393-8087

Specially Appearing for

JOHN STEELE UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA INGENUITY 13 LLC, Case No.: CV-12-8333- ODW(JCx) Plaintiff, DECLARATION OF , TIMOTHY HALLORAN V. IN RESPONSE TO PUTATIVE JOHN DOE’S REPLY BRIEF JOHN DOE, Defendants. Judge: Hon. Otis D. Wright, II Courtroom: 11 | Date: Ha 2, 2013 Time: 10:00 A.M. Complaint Filed: September 27, 2012 Trial Date: None I, Timothy J. Halloran, declare that: l, I am an attorney duly licensed to practice in all courts of the State of California, and am

a Senior Shareholder with the law firm of Murphy, Pearson, Bradley & Feeney, PC, attorneys of record for specially appearing John Steele herein. I have personal knowledge of the information set forth herein below, unless noted as based on information and belief, and if called upon to testify, I could and

would competently testify thereto.

2. Upon information and belief, attached as Exhibit “A” is a true and correct copy of a

notarized affidavit by Jacques Nazaire, dated April 18, 2013.

“|.

DECLARATION OF TIMOTHY HALLORAN Case No.: CV-12-8333- ODW(JCx) IN RESPONSE TO PUTATIVE JOHN DOE’S REPLY BRIEF

Case, 2:12-cv-08333-ODW-JC Document 123-1 Filed 04/18/13 Page 2of4 Page ID #:2828

] I declare under penalty of perjury under the laws of the State of California that the foregoing is 2 |} true and correct and that this Declaration was executed on this 18th day of April 2013, in San

3 |] Francisco, California.

4 ll Dated: April 18, 2013

By /s/ Timothy J. Halloran Timothy J. Halloran

28 me ae

DECLARATION OF TIMOTHY HALLORAN Case No.: CV-12-8333- ODW(JCx) IN RESPONSE TO PUTATIVE JOHN DOE’S REPLY BRIEF

Case 2:12-cv-08333-ODW-JC Document 123-1 Filed 04/18/13 Page 30f4 Page ID #:2829

EXHIBIT A

Case 2:12-cv-08333-ODW-JC Document 123-1 Filed 04/18/13 Page 4of4 Page ID #:2830

I, Jacques Nazaire, under the penalty of perjury, declare and state:

1. am over eighteen years of age and am competent to testify as to the matters set forth herein. I make this affidavit on the basis of my personal knowledge and, if called, would be prepared to testify as follows.

2.1 am attorney licensed to practice law in the State of Georgia.

3,1 have represented AF Holdings LLC in several matters in Georgia.

4.Qn the occasion when I needed to speak with a representative for AF Holdings LLC, my point of contact was Brett Gibbs, who I understood to be the lead counsel for all the AF Holdings LLC cases nationwide.

5. The only person at AF Holdings LLC that I have spoken to is Mark Lutz, who | understand is the CEO of AF Holdings LLC.

6.1 have spoken infrequently to Mr. John Steele over the past years. He has never indicated that he has an ownership interest in any of the clients that | have represented in Georgia, including AF Holdings LLC.

7, 1 have no reason to believe that Mr, John Steele has any ownership intcrest in any client I have ever represented.

8. Any statement I may have previously made about John Steele having an interest in AF , Holdings mh) based on my personal knowledge.

. NOTARY PUBLIC

Name of Notary

a : ° i” a ef My commission expires: Jha xs .20 D.

CHRIS VADNAIS NOTARY PUBLIC Cobb County

___ State of Georgia am, Expires Jan. 24, 2016