Document for ARNTSEN FAMILY PARTNERSHIP, LP, et al vs. GREGORY J DAVIS, et al

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                                1   Collin J. Vierra (State Bar No. 322720)
     EIMER STAHL LLP
 2   99 Almaden Blvd., Suite 600
     San Jose, CA 95113-1605
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     Telephone: (408) 889-1668
 4   Email: cvierra@eimerstahl.com

 5   Attorney for Plaintiffs Robert Arntsen,
     Mary Lee. Arntsen Family Partnership, LP,
 6   Brian Christopher Dunn Custodianship,
     John Ho, and Jacky Huang
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 8                    SUPERIOR COURT OF THE STATE OF CALIFORNIA
 9                                    COUNTY OF SAN MATEO
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11    Robert Arntsen; Mary Lee; Arntsen Family        Case No. 22-CIV-01148
      Partnership, LP; Brian Christopher Dunn
12    Custodianship, John Ho, and Quanyu Huang;       Dept. 21
13                  Plaintiffs,                       Hon. Robert D. Foiles
14    v.
                                                      DECLARATION OF QUANYU HUANG
15    David M. Bragg; Silicon Valley Real Ventures    IN SUPPORT OF PLAINTIFFS’
      LLC; SVRV 385 Moore, LLC; SVRV 387              OPPOSITION TO DEFENDANTS
16    Moore, LLC; Gregory J. Davis; Kevin Wolfe;      DAVID M. BRAGG’S AND SILICON
      Jason Justesen; Paramont Woodside, LLC;         VALLEY REAL VENTURES, LLC’S
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      Paramont Capital, LLC; Monks Family Trust;      MOTION TO COMPEL ARBITRATION
18    TEH Capital LLC; Caproc III, LLC; WZ
      Partners, LLC; McClan Trust; Wild Rose          Date: September 15, 2023
19    Irrevocable Trust; Black Horse Holdings,        Time: 9:00 a.m.
      LLC; Phil Stoker; Diane Stoker; Scott O’Neil;   Dept.: 21
20    Dale Huish; and DOES 1–20,
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                    Defendants.
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                                   DECLARATION OF QUANYU HUANG
 1           I, Quanyu Huang, attest as follows:

 2           1.       I am over the age of 18, of sound mind, and otherwise competent to make this

 3   affidavit.

 4           2.       True and correct copies of the operating agreements that Bragg drafted and

 5   presented to me in connection with my investment in the Moore Road LLCs are attached hereto

 6   as Exhibits C and D. I signed Investment-Subscription Agreements incorporating those operating

 7   agreements, which are attached hereto as Exhibits A and B. I was not given the opportunity to

 8   make any amendments to these operating agreements prior to making my investment. I was not

 9   presented with any other operating agreements. I was not presented with any other operating

10   agreements, including that I never saw the operating agreements that I understand the Arntsens

11   and John assented to.

12           I declare under penalty of perjury, under the laws of the State of California, that the

13   foregoing is true and correct to the best of my knowledge.

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16           Dated:    September 1, 2023                 ______________________
                                                              Jacky Huang
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                                    DECLARATION OF QUANYU HUANG