On July 26, 2022 a
Party Statement
was filed
involving a dispute between
Kingdom Of Sweden,
and
Does 1 To 20, Inclusive,
Nosrat, Amir Hossein,
for Other Collections Unlimited
in the District Court of San Bernardino County.
Preview
LAW OFFICES OF ERNEST MOONEY
W. Ernest Mooney (State Bar No. 82416)
23 Corporate Plaza Drive, Suite 150
ELECTRONICALLY FILED
Newport Beach, CA 92660 SUPERIOR COURT OF CALIFORNIA
Telephone: (949) 296-7557 COUNTY OF SAN BERNARDINO
Email: emlaw92657@yahoo.com SAN BERNARDINO DISTRICT
Attorney for Plaintiff
2/1/2024 12:17 PM
\OW‘JOUI-DUJN— KINGDOM OF SWEDEN By: Aradelsi Rizo, DEPUTY
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
— o KINGDOM OF SWEDEN, Case No. CIVSB2216123
a fl
Assigned For All Purposes To:
Plaintiff, The Honorable Jeffrey R. Erickson
H N
Department S 14
nu DJ
n—a
-§ SUPPLEMENTAL DECLARATION OF
LII
AMIR HOSSEIN NOSRAT aka BOEL MAGNUSSON IN SUPPORT OF
CHRISTOPHER AMIR NOSRAT; and DOES REPLY TO OPPOSITION TO
u—n
VVVVVVVVVVVVVVVVVVVV
H
0‘
l to 20, Inclusive, MOTION FOR SUMMARY
JUDGMENT
H V Defendant.
—‘
m
fl \D
No Date: February 8, 2024
Time: 8:30 a.m.
N ""'
Dept: SI4
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N b)
[Q A
N LII
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N \l
NW
SUPPLEMENTAL DECLARATION OF BOEL MAGNUSSON IN SUPPORTOF REPLYTO OPPOSITION 1’0 MOTION FOR
SUMMARY JUDGMENT
SUPPLEMENTAL DECLARATION 0F BOEL MAGNUSSON
I, Boel Magnusson, declare:
l. I have been employed by the Swedish Board of Student Finance (hereinafter “CSN”),
since 1998, and have been responsible for the repayment of student loans since 2007. I have
personal knowledge ofthe facts set forth in this Declaration. If called as a witness, I could
\oooxlcxm-bmu_
competently testify as to the facts herein.
2. [provided this Court with my professional background at CSN and with my background
in this case brought by CSN against Defendant Amir Hossein Nosrat aka Christopher Amir
Nosrat (“Nosrat”) in the Declaration which I signed on August 7, 2023. The Declaration was
submitted to this Court as part of CSN’s Motion For Summary Judgment.
3. Mr. Nosrat commenced his student loans obligations with CSN while he was living in
Sweden, for the stated purpose of attending an institution of higher learning in Sweden, in this
case dental school.
4. All of the loan documents which make up the contract with Nosrat were written in the
Swedish language. All ofthe money the CSN loaned to Nosrat was paid out of Sweden in
wNflOOOO-xleUI-BMN—‘O
Swedish Currency. The documents in the file do not reveal that Nosrat had any connection with
MNNNfl—dH—o—nfl—w——
California during the time that he received student loans from CSN.
5. CSN and its predecessor agency in Sweden have been making student loans since 1919.
CSN has 11 offices in Sweden and has no offices anywhere else, and all of its employees reside in
Sweden.
6. Sweden has a strong interest in having its 25-year statute of limitations apply to student
loan collection actions. When Sweden makes loans to borrowers who move abroad, the
borrowers ofien fail to provide current addresses to CSN or otherwise seek to avoid being located
24 in an effort to escape their repayment obligations. Sweden has determined that, without a time
period of this length in place to recover unpaid loans, many of the student loans will go
uncollected and Sweden’s generous study support system could be placed in jeopardy. I believe
that the United States government shares many of the same concerns in operating its own student
'7
SUPPLEMENTAL DECLARATION 0F BOEL MAGNUSSON IN SUPPORT OF REPLY T0 OPPOSITION TO MOTION FOR
SUMMARY JUDGMENT
Document Filed Date
February 01, 2024
Case Filing Date
July 26, 2022
Category
Other Collections Unlimited
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Preview
LAW OFFICES OF ERNEST MOONEY W. Ernest Mooney (State Bar No. 82416) 23 Corporate Plaza Drive, Suite 150 ELECTRONICALLY FILED Newport Beach, CA 92660 SUPERIOR COURT OF CALIFORNIA Telephone: (949) 296-7557 COUNTY OF SAN BERNARDINO Email: emlaw92657@yahoo.com SAN BERNARDINO DISTRICT Attorney for Plaintiff 2/1/2024 12:17 PM \OW‘JOUI-DUJN— KINGDOM OF SWEDEN By: Aradelsi Rizo, DEPUTY SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO — o KINGDOM OF SWEDEN, Case No. CIVSB2216123 a fl Assigned For All Purposes To: Plaintiff, The Honorable Jeffrey R. Erickson H N Department S 14 nu DJ n—a -§ SUPPLEMENTAL DECLARATION OF LII AMIR HOSSEIN NOSRAT aka BOEL MAGNUSSON IN SUPPORT OF CHRISTOPHER AMIR NOSRAT; and DOES REPLY TO OPPOSITION TO u—n VVVVVVVVVVVVVVVVVVVV H 0‘ l to 20, Inclusive, MOTION FOR SUMMARY JUDGMENT H V Defendant. —‘ m fl \D No Date: February 8, 2024 Time: 8:30 a.m. N ""' Dept: SI4 NN N b) [Q A N LII Nm N \l NW SUPPLEMENTAL DECLARATION OF BOEL MAGNUSSON IN SUPPORTOF REPLYTO OPPOSITION 1’0 MOTION FOR SUMMARY JUDGMENT SUPPLEMENTAL DECLARATION 0F BOEL MAGNUSSON I, Boel Magnusson, declare: l. I have been employed by the Swedish Board of Student Finance (hereinafter “CSN”), since 1998, and have been responsible for the repayment of student loans since 2007. I have personal knowledge ofthe facts set forth in this Declaration. If called as a witness, I could \oooxlcxm-bmu_ competently testify as to the facts herein. 2. [provided this Court with my professional background at CSN and with my background in this case brought by CSN against Defendant Amir Hossein Nosrat aka Christopher Amir Nosrat (“Nosrat”) in the Declaration which I signed on August 7, 2023. The Declaration was submitted to this Court as part of CSN’s Motion For Summary Judgment. 3. Mr. Nosrat commenced his student loans obligations with CSN while he was living in Sweden, for the stated purpose of attending an institution of higher learning in Sweden, in this case dental school. 4. All of the loan documents which make up the contract with Nosrat were written in the Swedish language. All ofthe money the CSN loaned to Nosrat was paid out of Sweden in wNflOOOO-xleUI-BMN—‘O Swedish Currency. The documents in the file do not reveal that Nosrat had any connection with MNNNfl—dH—o—nfl—w—— California during the time that he received student loans from CSN. 5. CSN and its predecessor agency in Sweden have been making student loans since 1919. CSN has 11 offices in Sweden and has no offices anywhere else, and all of its employees reside in Sweden. 6. Sweden has a strong interest in having its 25-year statute of limitations apply to student loan collection actions. When Sweden makes loans to borrowers who move abroad, the borrowers ofien fail to provide current addresses to CSN or otherwise seek to avoid being located 24 in an effort to escape their repayment obligations. Sweden has determined that, without a time period of this length in place to recover unpaid loans, many of the student loans will go uncollected and Sweden’s generous study support system could be placed in jeopardy. I believe that the United States government shares many of the same concerns in operating its own student '7 SUPPLEMENTAL DECLARATION 0F BOEL MAGNUSSON IN SUPPORT OF REPLY T0 OPPOSITION TO MOTION FOR SUMMARY JUDGMENT