Motion-Secondary: DO WOO KIM, ET AL. VS HYUN JONG HAN, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 01/08/2020 03:52 PM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Soto,Deputy Clerk




                   1       Brian F. Buchanan, SBN 086017
                           Jeremy Friedman, SBN 249706
                   2       BUCHANAN & PATTERSON, LLP
                           1000 Wilshire Boulevard, Suite 570
                   3       Los Angeles, California 90017
                           Telephone: (213) 457-7350
                   4       Facsimile: (213) 457-7355
                           E-mail: bbuchanan@bplawllp.com
                   5
                           Attorneys for Defendants in Case No. 19STCV16827
                   6       and for all Plaintiffs in related Case Nos. 19STCP02628
                           and 19STCP04605
                   7
                                                           SUPERIOR COURT OF THE STATE OF CALIFORNIA
                   8
                                                                       FOR THE COUNTY OF LOS ANGELES
                   9
                                                                          UNLIMITED CIVIL JURISDICTION
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                 11         THE WILTON KOREAN PRESBYTERIAN                                                    Case No. 19STCV16827
                            CHURCH IN LOS ANGELES, a Non-Profit                                                        19STCP02628 (Related Case)
                 12         Religious Corporation; DO WOO KIM, an                                                      19STCP04605 (Related Case)
                            individual; DO RIM KIM, an individual;
                 13                                                                                          DECLARATION OF HYUN JONG HAN
                                                              Plaintiffs,                                    IN SUPPORT OF PLAINTIFFS' NOTICE
                 14
                                                                                                             OF MOTION AND MOTION FOR AN
                            vs.
                 15                                                                                          ORDER REGARDING SPECIAL
                            HYUN JONG HAN, an individual; YONG                                               ELECTION PROCEEDINGS TO ELECT
                 16         CHUL CHO, an individual; FRANCIS KIM, an                                         A BOARD OF DIRECTORS (IN CASE
                            individual; NEE DON CHU, an individual; DAE                                      NO. 19STCP04605)
                 17         WON PARK, an individual; & DOES 1
                            through 50, inclusive                                                            Date: January 31, 2020
                 18
                                                                                                             Time: 8:30 a.m.
                                                              Defendants.
                 19                                                                                          Dept.: 17
                            AND RELATED CASES                                                                Hearing Judge: Richard E. Rico
                 20                                                                                          Action Filed: May 14, 2019
                                                                                                             Trial Date: None Set
                 21

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                          I, Hyun Jong Han, declare:
                 23                  1.          I am a member and Senior Pastor of the Wilton Korean Presbyterian Church in Los
                 24       Angeles (herein "Wilton Church" or sometimes "Church"), which is located at 470 N. St. Andrew's
                 25       Place and the Plaintiff in Case Numbers 19STCP02628 and 19STCP04605. I have personal
                 26       knowledge of the facts stated herein, and, if called to testify in regard to those facts, I could and
                 27       would competently do so.
                 28