Document for PIER PROPRIETARY FUND, LP VS ALFRED TALAHURON

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 06/15/2020 12:18 PM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Mariscal,Deputy Clerk




                       1 ELKINS KALT WEINTRAUB REUBEN GARTSIDE LLP
                         JOEL J. BERMAN, State Bar No. 89104
                       2  jberman@elkinskalt.com
                         LEANNE 0. VANECEK, State Bar No. 279317
                       3   lvanecek@elkinskalt.com
                         10345 W. Olympic Blvd.
                       4 Los Angeles, California 90064
                         Telephone: 310.746.4400
                       5 Facsimile: 310.746.4499
                       6 Attorneys for Pier Proprietary Fund LP
                        7
                        8                           SUPERIOR COURT OF THE STATE OF CALIFORNIA
                        9                             COUNTY OF LOS ANGELES, WESTERN DISTRICT

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                     11 PIER PROPRIETARY FUND LP, a                                                        CASE No.
                        Cayman Islands Limited Partnership,
                     12                                                                                    ATTORNEY'S DECLARATION IN
                                   Plaintiff,                                                              SUPPORT OF CONFESSION OF
                     13                                                                                    JUDGMENT
                                          V.
                      14                                                                                   (CALIFORNIA CODE OF CIVIL
                             ALFRED TALAHURON, an individual,                                              PROCEDURE SECTION 1132(b))
                      15
                                                     Defendants.
                      16
                      17                  I, George Robinson, declare:
                      18                  1.         I am an attorney at law duly admitted to practice before the courts of
                      19 the State of California. I have provided advice and counsel to Defendant Alfred
                      20 Talahuron ("Defendant") in connection with claims arising from two Bitcoin Purchase
                      21 and Sale Agreements, dated December 3, 2018, and December 17, 2018, as well as a
                      22 Settlement Agreement, dated June 29, 2019, made by and among Pier Proprietary
                      23 Fund LP on the one hand, and WCCI, LLC, Edward C. Reyes, and Alfred Talahuron
                      24 on the other. I have personal knowledge of the following facts and if called upon to
                      25 testify, could testify competently thereto.
                      26                  2.         I have examined the proposed judgment by confession. I have advised
                      27 Defendant with respect to the waiver of rights and defenses under the confession of
                      28 judgment procedure, and have advised Defendant to utilize the confession of

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                                               ATTORNEY DECLARATION IN SUPPORT OF CONFESSION OF JUDGMENT