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1 DILLINGHAM & MURPHY, LLP
2 WILLIAM F. MURPHY, ESQ. (SBN 82482)
CYNTHIA C. CHEUNG, ESQ. (SBN 320767) 6/19/2020
3 601 Montgomery Street, Suite 1900
San Francisco, California 94111
4 Telephone: (415) 397-2700
Facsimile: (415) 397-3300
5 Email: wfm@dillinghammurphy.com
ccc@dillinghammurphy.com
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FROST BROWN TODD LLC
7 ALI RAZZAGHI, ESQ. (Pro Hae Vice Pending)
Great American Tower
8 301 East Fourth Street, Suite 3300
Cincinnati, OH 45202
9 Telephone: (513) 651-6844
Facsimile: (513) 651-6981
10 Email: arazzaghi@fbtlaw.com
11 Attorneys for Defendants
Leamship Corporation and
12 Learnship Networks GmbH
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IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
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COUNTY OF SAN MATEO
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16 SKYLINE VENTURE PARTNERS LLC, a Case No. 19-CIV-07663
Delaware Limited Liability Corporation,
17 DECLARATION OF ALI RAZZAGHI
Plaintiff, IN SUPPORT OF DEFENDANTS
18 LEARNSHIP CORPORATION AND
v. LEARNSHIP NETWORKS GMBH'S
19 APPLICATION FOR ALI RAZZAGHI
LEARNSHIP CORPORATION, a Delaware TO APPEAR AS COUNSEL PRO HAC
20 corporation; LEARNSHIP NETWORKS GmbH, VICE
a foreign corporation; and DOES 1 through 50,
21 inclusive Date: August 20, 2020
Time: 1:30 p.m.
22 Defendants. Dept: Law and Motion
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24 And Related Cross-Action.
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I, ALI RAZZAGHI, declare as follows:
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II
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Page I - Case No. RGl9001719
28 DECLARATION OF ALI RAZZAGHI IN SUPPORT OF DEFENDANTS LEARNSHIP CORPORATION AND
LEARNSHIP NETWORKS GMBH'S APPLICATION FOR ALI RAZZAGHI TO APPEAR AS COUNSEL PRO
HAC VICE
1. Pursuant to Rule 9 .40 of the California Rules of Court, I submit this declaration in
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the above-entitled action, captioned ·'SKYLINE VENTURE PARTNERS LLC, a Delaware
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Limited Liability Corporation, v. LEARNSHIP CORPORATION, a Delaware corporation;
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LEARNSHIP NETWORKS GmbH, a foreign corporation; and DOES 1 through 50, inclusive'',
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in the Superior Court of California for the County of San Mateo, No. l 9-CIV-07663, in support
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7 of Defendants Learnship Corporation's and Learnship Networks GmbH's ("Defendants")
8 Application for me to appear as counsel pro hac vice. I know the following facts to be true of my
9 own knowledge and if called to testify I would and could competently do so.
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2. I am not a member of the State Bar of California and am not a resident of
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California. I am not regularly employed in California, and I am not regularly engaged in
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substantial business, professional, or other activities in California.
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14 3. My residence address is 6082 Christopher Ln, Cincinnati, Ohio 45233 . My
15 business address is 3300 Great American Tower, 301 East Fourth Street, Cincinnati, Ohio 45202.
16 4. I am a licensee in good standing and eligible to practice law before the following
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courts: the Courts of the State of Ohio (admitted November 6, 2006); the United States District
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Court for the Southern District of Ohio (admitted January 18, 2007); and the United States
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District Court for the Northern District of Ohio (admitted January 25, 2010).
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5. I am not currently suspended or disbarred in any court.
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22 6. I have not filed any application to appear as counsel pro hac vice in California
23 within the preceding two years.
24 7. I have been retained by Defendants to represent them in this action. I am a
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member of the law firm of Frost Brown Todd LLC. If granted, I will appear as co-counsel with
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William F. Murphy and Cynthia C. Cheung of Dillingham & Murphy LLP, 601 Montgomery
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Page 2 - Case No. RGI 9001719
28 DECLARATION OF ALI RAZZAGHI IN SUPPORT OF DEFENDANTS LEARNSHIP CORPORATION AND
LEARNSHIP NETWORKS GMBH'S APPLICATION FOR ALI RAZZAGHI TO APPEAR AS COUNSEL PRO
HAC VICE
Street, Suite 1900, San Francisco, California 94111. The telephone number for Ms. Cheung and
2 Mr. Murphy is (415) 397-2700. Both Ms. Cheung and Mr. Murphy are active members, in good
3 standing, of the California State Bar.
4 I declare under penalty of perjury under the laws of the United States of America and the
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States of California and Ohio that the foregoing is true and correct and this declaration was
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executed on J "M. . { r. 2020, at Cincinnati, Ohio.
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Page 3 - Case No. RG 19001719
28 DECLARATION OF ALI RAZZAGHI IN SUPPORT OF DEFENDANTS LEARNSHIP CORPORATION AND
LEARNSHIP NETWORKS GMBH'S APPLICATION FOR ALI RAZZAGHI TO APPEAR AS COUNSEL PRO
HAC VICE
PROOF OF SERVICE
[C.C.P. Section 1013, 2015.5]
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In Re: Skyline Venture Partners v. Learnship Corporation, et al.
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San Mateo County Superior Court (Redwood City) Case No.: 19-CIV-07663
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I am a citizen of the United States, a resident of the State of California, and am
5 employed in the County of San Francisco, State of California. I am over eighteen (18) years of
age and not a party to the above-entitled action. My business address is DILLINGHAM
6 MURPHY, LLP, 601 Montgomery Street, Suite 1900, San Francisco, CA 94111. On the date
7 below, I served the following document(s) in the manner indicated below on the person(s) listed
on the attached Service List:
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• DEFENDANTS LEARNSHIP CORPORATION AND LEARNSHIP NETWORKS GMBH'S NOTICE OF
9 APPLICATION AND APPLICATION FOR ALI RAZZAGHI TO APPEAR AS COUNSEL PRO HAC VICE;
MEMORANDUM OF POINTS AND AUTHORITIES
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• DECLARATION OF ALI RAZZAGHI IN SUPPORT OF DEFENDANTS LEARNSHIP CORPORATION
11 AND LEARNSHIP NETWORKS GMBH'S APPLICATION FOR ALI RAZZAGHI TO APPEAR AS
COUNSEL PRO HAC VICE
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13 U.S. Mail: by placing the document(s) listed above in a sealed envelope, with First
Class postage thereon fully prepaid, and deposited same in the United States mail at San
14 Francisco, California, addressed as set forth below. I am readily familiar with this firm's
practice of collection and processing of correspondence for mailing. Under that
15 practice, it would be deposited with the U.S. Postal Service on that same day, with
postage thereon fully prepaid, in the ordinary course of business.
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Allonn E. Levy, Esq. Jason S. Angell, Esq.
17 HOPKINS & CARLEY HOPKINS & CARLEY
The Letitia Building 200 Page Mill Road, Suite 200
18 70 S. First Street Palo Alto, CA 94306
San Jose, CA 95113-2406
19 T: (650) 804-7600
Mailing Address: F: (650) 804-7630
20 P.O. Box 1469 Email: jangell@hopkinscarley.com
San Jose, CA 95109-1469
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Attorneys for Plaintiff
22 T: (408) 286-9800 Skyline Venture Partners LLC
F: (408) 998-4790
23 Email: aleyy@hopkinscarley.com
24 Attorneys for Plaintiff
Sky line Venture Partners LLC
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DEFENDANTS LEARNSHIP CORPORATION AND LEARNSHIP NETWORKS GMBH'S NOTICE OF
APPLICATION AND APPLICATION FOR ALI RAZZAGHI TO APPEAR AS COUNSEL PRO HAC VICE;
MEMORANDUM OF POINTS AND AUTHORITIES
1 Pro Hae Vice Program
Office of Special Admissions
2 The State Bar of California
180 Howard Street
3 San Francisco, California 94105
T: 415-538-2000
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_____________________ _______·----------------------·-·--··----------·------------·----··--'I
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(State) I declare under penalty of perjury under the laws of the State of California that
9 the above is true and correct. Executed on the d below at San Francisco, California.
10 --.......
11 Dated: June 19, 2020
Debra A. Ardissone
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DEFENDANTS LEARNSHIP CORPORATION AND LEARNSHIP NETWORKS GMBH'S NOTICE OF
APPLICATION AND APPLICATION FOR ALI RAZZAGHI TO APPEAR AS COUNSEL PRO HAC VICE;
MEMORANDUM OF POINTS AND AUTHORITIES
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1 DILLINGHAM & MURPHY, LLP 2 WILLIAM F. MURPHY, ESQ. (SBN 82482) CYNTHIA C. CHEUNG, ESQ. (SBN 320767) 6/19/2020 3 601 Montgomery Street, Suite 1900 San Francisco, California 94111 4 Telephone: (415) 397-2700 Facsimile: (415) 397-3300 5 Email: wfm@dillinghammurphy.com ccc@dillinghammurphy.com 6 FROST BROWN TODD LLC 7 ALI RAZZAGHI, ESQ. (Pro Hae Vice Pending) Great American Tower 8 301 East Fourth Street, Suite 3300 Cincinnati, OH 45202 9 Telephone: (513) 651-6844 Facsimile: (513) 651-6981 10 Email: arazzaghi@fbtlaw.com 11 Attorneys for Defendants Leamship Corporation and 12 Learnship Networks GmbH 13 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 14 COUNTY OF SAN MATEO 15 16 SKYLINE VENTURE PARTNERS LLC, a Case No. 19-CIV-07663 Delaware Limited Liability Corporation, 17 DECLARATION OF ALI RAZZAGHI Plaintiff, IN SUPPORT OF DEFENDANTS 18 LEARNSHIP CORPORATION AND v. LEARNSHIP NETWORKS GMBH'S 19 APPLICATION FOR ALI RAZZAGHI LEARNSHIP CORPORATION, a Delaware TO APPEAR AS COUNSEL PRO HAC 20 corporation; LEARNSHIP NETWORKS GmbH, VICE a foreign corporation; and DOES 1 through 50, 21 inclusive Date: August 20, 2020 Time: 1:30 p.m. 22 Defendants. Dept: Law and Motion 23 24 And Related Cross-Action. 25 I, ALI RAZZAGHI, declare as follows: 26 II 27 Page I - Case No. RGl9001719 28 DECLARATION OF ALI RAZZAGHI IN SUPPORT OF DEFENDANTS LEARNSHIP CORPORATION AND LEARNSHIP NETWORKS GMBH'S APPLICATION FOR ALI RAZZAGHI TO APPEAR AS COUNSEL PRO HAC VICE 1. Pursuant to Rule 9 .40 of the California Rules of Court, I submit this declaration in 2 the above-entitled action, captioned ·'SKYLINE VENTURE PARTNERS LLC, a Delaware 3 Limited Liability Corporation, v. LEARNSHIP CORPORATION, a Delaware corporation; 4 LEARNSHIP NETWORKS GmbH, a foreign corporation; and DOES 1 through 50, inclusive'', 5 in the Superior Court of California for the County of San Mateo, No. l 9-CIV-07663, in support 6 7 of Defendants Learnship Corporation's and Learnship Networks GmbH's ("Defendants") 8 Application for me to appear as counsel pro hac vice. I know the following facts to be true of my 9 own knowledge and if called to testify I would and could competently do so. 10 2. I am not a member of the State Bar of California and am not a resident of 11 California. I am not regularly employed in California, and I am not regularly engaged in 12 substantial business, professional, or other activities in California. 13 14 3. My residence address is 6082 Christopher Ln, Cincinnati, Ohio 45233 . My 15 business address is 3300 Great American Tower, 301 East Fourth Street, Cincinnati, Ohio 45202. 16 4. I am a licensee in good standing and eligible to practice law before the following 17 courts: the Courts of the State of Ohio (admitted November 6, 2006); the United States District 18 Court for the Southern District of Ohio (admitted January 18, 2007); and the United States 19 District Court for the Northern District of Ohio (admitted January 25, 2010). 20 5. I am not currently suspended or disbarred in any court. 21 22 6. I have not filed any application to appear as counsel pro hac vice in California 23 within the preceding two years. 24 7. I have been retained by Defendants to represent them in this action. I am a 25 member of the law firm of Frost Brown Todd LLC. If granted, I will appear as co-counsel with 26 William F. Murphy and Cynthia C. Cheung of Dillingham & Murphy LLP, 601 Montgomery 27 Page 2 - Case No. RGI 9001719 28 DECLARATION OF ALI RAZZAGHI IN SUPPORT OF DEFENDANTS LEARNSHIP CORPORATION AND LEARNSHIP NETWORKS GMBH'S APPLICATION FOR ALI RAZZAGHI TO APPEAR AS COUNSEL PRO HAC VICE Street, Suite 1900, San Francisco, California 94111. The telephone number for Ms. Cheung and 2 Mr. Murphy is (415) 397-2700. Both Ms. Cheung and Mr. Murphy are active members, in good 3 standing, of the California State Bar. 4 I declare under penalty of perjury under the laws of the United States of America and the 5 States of California and Ohio that the foregoing is true and correct and this declaration was 6 7 executed on J "M. . { r. 2020, at Cincinnati, Ohio. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Page 3 - Case No. RG 19001719 28 DECLARATION OF ALI RAZZAGHI IN SUPPORT OF DEFENDANTS LEARNSHIP CORPORATION AND LEARNSHIP NETWORKS GMBH'S APPLICATION FOR ALI RAZZAGHI TO APPEAR AS COUNSEL PRO HAC VICE PROOF OF SERVICE [C.C.P. Section 1013, 2015.5] 2 In Re: Skyline Venture Partners v. Learnship Corporation, et al. 3 San Mateo County Superior Court (Redwood City) Case No.: 19-CIV-07663 4 I am a citizen of the United States, a resident of the State of California, and am 5 employed in the County of San Francisco, State of California. I am over eighteen (18) years of age and not a party to the above-entitled action. My business address is DILLINGHAM 6 MURPHY, LLP, 601 Montgomery Street, Suite 1900, San Francisco, CA 94111. On the date 7 below, I served the following document(s) in the manner indicated below on the person(s) listed on the attached Service List: 8 • DEFENDANTS LEARNSHIP CORPORATION AND LEARNSHIP NETWORKS GMBH'S NOTICE OF 9 APPLICATION AND APPLICATION FOR ALI RAZZAGHI TO APPEAR AS COUNSEL PRO HAC VICE; MEMORANDUM OF POINTS AND AUTHORITIES 10 • DECLARATION OF ALI RAZZAGHI IN SUPPORT OF DEFENDANTS LEARNSHIP CORPORATION 11 AND LEARNSHIP NETWORKS GMBH'S APPLICATION FOR ALI RAZZAGHI TO APPEAR AS COUNSEL PRO HAC VICE 12 13 U.S. Mail: by placing the document(s) listed above in a sealed envelope, with First Class postage thereon fully prepaid, and deposited same in the United States mail at San 14 Francisco, California, addressed as set forth below. I am readily familiar with this firm's practice of collection and processing of correspondence for mailing. Under that 15 practice, it would be deposited with the U.S. Postal Service on that same day, with postage thereon fully prepaid, in the ordinary course of business. 16 - Allonn E. Levy, Esq. Jason S. Angell, Esq. 17 HOPKINS & CARLEY HOPKINS & CARLEY The Letitia Building 200 Page Mill Road, Suite 200 18 70 S. First Street Palo Alto, CA 94306 San Jose, CA 95113-2406 19 T: (650) 804-7600 Mailing Address: F: (650) 804-7630 20 P.O. Box 1469 Email: jangell@hopkinscarley.com San Jose, CA 95109-1469 21 Attorneys for Plaintiff 22 T: (408) 286-9800 Skyline Venture Partners LLC F: (408) 998-4790 23 Email: aleyy@hopkinscarley.com 24 Attorneys for Plaintiff Sky line Venture Partners LLC 25 26 27 28 -I - DEFENDANTS LEARNSHIP CORPORATION AND LEARNSHIP NETWORKS GMBH'S NOTICE OF APPLICATION AND APPLICATION FOR ALI RAZZAGHI TO APPEAR AS COUNSEL PRO HAC VICE; MEMORANDUM OF POINTS AND AUTHORITIES 1 Pro Hae Vice Program Office of Special Admissions 2 The State Bar of California 180 Howard Street 3 San Francisco, California 94105 T: 415-538-2000 4 5 6 7 I I 8 _____________________ _______·----------------------·-·--··----------·------------·----··--'I [_ (State) I declare under penalty of perjury under the laws of the State of California that 9 the above is true and correct. Executed on the d below at San Francisco, California. 10 --....... 11 Dated: June 19, 2020 Debra A. Ardissone 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -2- DEFENDANTS LEARNSHIP CORPORATION AND LEARNSHIP NETWORKS GMBH'S NOTICE OF APPLICATION AND APPLICATION FOR ALI RAZZAGHI TO APPEAR AS COUNSEL PRO HAC VICE; MEMORANDUM OF POINTS AND AUTHORITIES