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Old September 15th 09, 06:37 PM posted to rec.games.chess.politics,rec.games.chess.misc,alt.chess
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Default Vealrde Declaration

DECLARATION OF KRISTINA VELARDE IN SUPPORT OF COUNTER AND THIRD-PARTY
DEFENDANTS' REPLY IN SUPPORT OF MOTION FOR FAILURE TO STATE A CLAIM

I, KRISTINA L. VEALRDE decla
The following is of my own personal knowledge, unless stated under
information and belief, and if called as a witness I would testify as
follows:
1. I am an attorney duly licensed to practice law in the State of
California. I am an attorney at the law offices of Cesari, Werner and
Moriarty, 360 Post Street, Fifth Floor, San Francisco, CA 94108; (415)
391-1113, counsel of record for counter-defendant and third-party
defendants Randall Hough, Bill Goichberg, Bill Hall, Randy Bauer, Jim
Berry, and Karl Kronenberger in the above referenced matter.
2. Attached hereto as Exhibit "A" is a true and correct copy of Polgar's
proposed Amended Answer and Counter-Claim initially filed with her
Motion for Leave to Amended Answer and Counter Claim, (only alleging the
Abuse of Process claim).
3. Attached hereto as Exhibit "B" is a true and correct copy of Polgar's
proposed Amended Answer and Counter-Claim filed with her Reply in
support of Motion for Leave to Amend Answer and Counter Claim, (adding
the allegation of the Breach of Fiduciary Duty claim).

[Exhibits Omitted]
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