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Case 17-05016-btb Doc
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Matthew D. Francis
Nevada Bar No. 6978
Nevada Bar No. 6978
mfrancis@bhfs.com
Arthur A. Zorio
Nevada Bar No. 6547
azorio@bhfs.com
BROWNSTEIN HYATT FARBER SCHRECK, LLP
Telephone: 775.324.4100
Facsimile: 775.333.8171
Attorneys for JED MARGOLIN
IN THE UNITED STATES
BANKRUPTCY COURT
FOR THE DISTRICT OF
NEVADA
BK-N-16-50644-BTB
Chapter 15
Adversary Proceeding: 17-05016-BTB
DECLARATION OF ADAM P. MCMILLEN IN SUPPORT OF DEFENDANT JED MARGOLIN’S MOTION FOR SUMMARY JUDGMENT AGAINST CROSS CLAIMANT PATRICK CANET
Hearing Date: May 24, 2018
Hearing Time: 10 a.m.
Estimated Time: 1-2 hours
In Re JAZI GHOLAMREZA ZANDIAN,
Debtor.
__________________________________/
FRED
SADRI, AS TRUSTEE FOR THE STAR LIVING TRUST, DATED APRIL 14, 1997; RAY KOROGHLI
AND SATHSOWI T. KOROGHLI, AS MANAGING TRUSTEES FOR KOROGHLI MANAGEMENT TRUST,
Plaintiffs,
v.
JED MARGOLIN; JAZI GHOLAM REZA ZANDIAN; and all other parties claimingan interest in real properties described in this action,
Defendants.
__________________________________/
PATRICK CANET,
Counterclaimant,
v.
FRED SADRI, INDIVIDUALLY AND AS TRUSTEE FOR THE STAR LIVING TRUST; RAY KOROGHLI, INDIVIDUALLY; RAY KOROGHLI AND SATHSOWI T. KOROGHLI, AS MANAGING TRUSTEES FOR
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KOROGHLI MANAGEMENT TRUST,
Counter-Defendants.
__________________________________/
PATRICK CANET,
Cross-Claimant,
v.
JED MARGOLIN,
Cross-Defendant.
I, Adam P. McMillen do hereby declare and state as follows:
1. I am an attorney at the Law Offices of Karl H. Smith. Prior to joining the Smith law firm, I was an attorney at the law firm of Brownstein Hyatt Farber Schreck, LLP (“BHFS”), where I was counsel of record for Mr. Margolin in this action. Prior to my tenure at BHFS, I was an attorney at the law firm of Watson Rounds. I have personal knowledge of the facts which are hereinafter related and make this Declaration on the basis of such personal knowledge. If called to testify at any hearing or trial regarding the above-matter, I swear I could testify competently to the matters stated herein. This Declaration is made in support of Defendant Jed Margolin’s Statement of Undisputed Facts in Support of Defendant Jed Margolin’s Motion for Summary Judgment Against Cross Claimant Patrick Canet and Jed Margolin’s Motion for Summary Judgment Against Cross Claimant Patrick Canet.
2.
On December 9, 2014, I attended a public auction at the
3.
On April 3, 2015, I attended a public auction at the Second Judicial
District Court at 75 Court Street,
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$3,000. Attached hereto as Exhibit B is a true and correct copy of a
Sheriff’s Certificate of Sale of Property for APN 084-130-07 in
4.
On April 3, 2015, I attended a public auction at the Second Judicial
District Court at 75 Court Street,
5.
On April 3, 2015, I attended a public auction at the Second Judicial
District Court at 75 Court Street,
6.
On April 3, 2015, I attended a public auction at the Second Judicial
District Court at 75 Court Street,
I declare under penalty of perjury that the foregoing is true and correct.
DATED: This 20th day of March, 2018.
By:
__________________
Adam P. McMillen
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CERTIFICATE OF SERVICE
Pursuant to Fed. R. Civ. P. 5(b), I certify that I am an employee of BROWNSTEIN HYATT FARBER SCHRECK, LLP, and on this day of March, 2018, I served the document entitled DECLARATION OF ADAM MCMILLEN IN SUPPORT OF DEFENDANT JED MARGOLIN’S MOTION FOR SUMMARY JUDGMENT AGAINST CROSS CLAIMANT PATRICK CANET on the parties listed below via the following:
[
] VIA FIRST CLASS
Dana Jonathon Nitz, Esq.
Yanxiong Li, Esq.
Wright, Finlay & Zak, LLP
7785
W.
yli@wrightlegal.net
Jeffrey L. Harman, Esq.
HARMAN & HARTMAN
notices@bankruptcyreno.com
[ ] BY PERSONAL SERVICE: by personally hand-delivering or causing to be hand delivered by such designated individual whose particular duties include delivery of such on behalf of the firm, addressed to the individual(s) listed, signed by such individual or his/her representative accepting on his/her behalf. A receipt of copy signed and dated by such an individual confirming delivery of the document will be maintained with the document and is attached.
[ ] VIA COURIER: by delivering a copy of the document to a courier service for over-night delivery to the foregoing parties.
[X
] VIA ELECTRONIC SERVICE: by
electronically filing the document with the Clerk of the Court using the ECF
system which served the following parties electronically:
Nancy
Lindsley
Employee of Brownstein Hyatt Farber Schreck, LLP
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