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DocuSign Envelope ID: C8463806-F9C7-41E0-880C-D8DDA02D379B
EXHIBIT 1
CAUSE NO. C-1777-23-F
VERONICA BRIONES IN THE 332ND DISTRICT COURT
Plaintiff,
V. OF
LONE STAR SOLAR SERVICES LLC,
FREDDY NIETO, AND GOODLEAP, LLC
Defendants. HIDALGO COUNTY, TEXAS
DECLARATION OF MATT DAWSON
VERIFYING BUSINESS RECORDS AND FACTS
STATE OF CALIFORNIA §
§
COUNTY OF PLACER §
1 “ My name is Matt Dawson. I am over 18 years of age, of sound mind, and
capable of making this affidavit. The facts stated in this affidavit are within my personal
knowledge and are true and correct.
2. I am a custodian of records for GoodLeap, LLC (““GoodLeap”). I also serve as
the Chief Revenue Officer of GoodLeap, and in that capacity, I am familiar with the practices,
procedures, relationships, and operations of GoodLeap. GoodLeap provides financing for
sustainable home solutions.
3 Exhibits A, B, C, and E attached to GoodLeap’s Motion to Compel Arbitration
and Motion to Stay, filed in the above-referenced case, are GoodLeap’ business records. These
records are kept by GoodLeap in the regular course of business, and it was the regular course of
business of GoodLeap for a GoodLeap employee, representative, or agent, with knowledge of
the act, event, condition, opinion, or diagnosis that was recorded, to make this record or to
transmit the information to be included in this record. The record was made at or near the time
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DocuSign Envelope ID: C8463806-F9C7-41E0-880C-D8DDA02D379B
EXHIBIT 1
or reasonably soon after the act, event, condition, opinion, or diagnosis that was recorded. More
specifically, the exhibits attached to GoodLeap’s Motion to Compel Arbitration and Motion to
Stay, are true and correct copies as follows:
a Exhibit A — Loan Agreement for Loan No. 22-05-122680, between
GoodLeap and Veronica Briones (email:
Veronicabriones123456@gmail.com), dated November 14, 2022, for 10607
N 25th Lane, McAllen, TX 78504-6414. This Agreement was also signed
by an authorized representative of GoodLeap.
Exhibit B — DocuSign Certificate of Completion showing completion of
Exhibit A (Loan No. 22-05-122680) by electronic signature “Veronica
Briones” through Veronicabriones123456@gmail.com on November 14,
2022.
Exhibit C — Loan Closing Certificate for Loan No. 22-05-122680 addressed
to Veronica Briones at Veronicabriones123456@gmail.com.
Exhibit E — UCC Financing Statement filed with the Clerk of Hidalgo
County, Texas, reflecting an interest by GoodLeap in the equipment
collateral of debtor Veronica Briones; specifically, “all of the debtor’s right,
title and interest in the Photovoltaic Solar Energy Equipment or Energy
Storage/Battery Equipment (If any), ”
4 No GoodLeap agent or employee ever misrepresented the terms of the Loan
Agreement at Exhibit A. No GoodLeap agent or employee signed any agreement for Ms.
Briones.
5 At all relevant times, no representative of LONE STAR SOLAR SERVICES
LLC (“Lone Star”) who may have visited the home of Veronica Briones was acting as
GoodLeap’s agent, representative, or employee. No representative of Lone Star was employed
or contracted by GoodLeap and no such representative was authorized to act as GoodLeap’s
agent or representative.
6 GoodLeap does not sell solar panels, solar panel systems or solar panel services.
GoodLeap does not install solar panels or enroll people in solar panel programs. GoodLeap did
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EXHIBIT 1
not sell solar panels, solar panel systems or solar panel services to or for Veronica Briones.
GoodLeap did not install or attempt to install, solar panels, nor did it enroll or attempt to enroll
Veronica Briones in solar panel programs.
My name is Matt Dawson, my date of birth is April 16, 1974, and my business address
is 8781 Sierra College Blvd. Roseville, CA 95661. I declare under penalty of perjury that the
10/12/2023
foregoing is true and correct. Executed in Placer County, California, on
DECLARANT:
DocuSigned by:
Malt Dawson,
02881987 08A74EE,
MATT DAWSON
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DocuSign Envelope ID: C8463806-F9C7-41E0-880C-D8DDA02D379B EXHIBIT 1 CAUSE NO. C-1777-23-F VERONICA BRIONES IN THE 332ND DISTRICT COURT Plaintiff, V. OF LONE STAR SOLAR SERVICES LLC, FREDDY NIETO, AND GOODLEAP, LLC Defendants. HIDALGO COUNTY, TEXAS DECLARATION OF MATT DAWSON VERIFYING BUSINESS RECORDS AND FACTS STATE OF CALIFORNIA § § COUNTY OF PLACER § 1 “ My name is Matt Dawson. I am over 18 years of age, of sound mind, and capable of making this affidavit. The facts stated in this affidavit are within my personal knowledge and are true and correct. 2. I am a custodian of records for GoodLeap, LLC (““GoodLeap”). I also serve as the Chief Revenue Officer of GoodLeap, and in that capacity, I am familiar with the practices, procedures, relationships, and operations of GoodLeap. GoodLeap provides financing for sustainable home solutions. 3 Exhibits A, B, C, and E attached to GoodLeap’s Motion to Compel Arbitration and Motion to Stay, filed in the above-referenced case, are GoodLeap’ business records. These records are kept by GoodLeap in the regular course of business, and it was the regular course of business of GoodLeap for a GoodLeap employee, representative, or agent, with knowledge of the act, event, condition, opinion, or diagnosis that was recorded, to make this record or to transmit the information to be included in this record. The record was made at or near the time #9227404v1 Page 1 of 3 DocuSign Envelope ID: C8463806-F9C7-41E0-880C-D8DDA02D379B EXHIBIT 1 or reasonably soon after the act, event, condition, opinion, or diagnosis that was recorded. More specifically, the exhibits attached to GoodLeap’s Motion to Compel Arbitration and Motion to Stay, are true and correct copies as follows: a Exhibit A — Loan Agreement for Loan No. 22-05-122680, between GoodLeap and Veronica Briones (email: Veronicabriones123456@gmail.com), dated November 14, 2022, for 10607 N 25th Lane, McAllen, TX 78504-6414. This Agreement was also signed by an authorized representative of GoodLeap. Exhibit B — DocuSign Certificate of Completion showing completion of Exhibit A (Loan No. 22-05-122680) by electronic signature “Veronica Briones” through Veronicabriones123456@gmail.com on November 14, 2022. Exhibit C — Loan Closing Certificate for Loan No. 22-05-122680 addressed to Veronica Briones at Veronicabriones123456@gmail.com. Exhibit E — UCC Financing Statement filed with the Clerk of Hidalgo County, Texas, reflecting an interest by GoodLeap in the equipment collateral of debtor Veronica Briones; specifically, “all of the debtor’s right, title and interest in the Photovoltaic Solar Energy Equipment or Energy Storage/Battery Equipment (If any), ” 4 No GoodLeap agent or employee ever misrepresented the terms of the Loan Agreement at Exhibit A. No GoodLeap agent or employee signed any agreement for Ms. Briones. 5 At all relevant times, no representative of LONE STAR SOLAR SERVICES LLC (“Lone Star”) who may have visited the home of Veronica Briones was acting as GoodLeap’s agent, representative, or employee. No representative of Lone Star was employed or contracted by GoodLeap and no such representative was authorized to act as GoodLeap’s agent or representative. 6 GoodLeap does not sell solar panels, solar panel systems or solar panel services. GoodLeap does not install solar panels or enroll people in solar panel programs. GoodLeap did #9227404v1 Page 2 of 3 DocuSign Envelope ID: C8463806-F9C7-41E0-880C-D8DDA02D379B EXHIBIT 1 not sell solar panels, solar panel systems or solar panel services to or for Veronica Briones. GoodLeap did not install or attempt to install, solar panels, nor did it enroll or attempt to enroll Veronica Briones in solar panel programs. My name is Matt Dawson, my date of birth is April 16, 1974, and my business address is 8781 Sierra College Blvd. Roseville, CA 95661. I declare under penalty of perjury that the 10/12/2023 foregoing is true and correct. Executed in Placer County, California, on DECLARANT: DocuSigned by: Malt Dawson, 02881987 08A74EE, MATT DAWSON #9227404v1 Page 3 of 3