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Case 2:11-cv-01426-GMS Document 47-1 Filed 12/03/11 Page 1 of 3

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Iverson, Yoakum, Papiano & Hatch


633 West Fifth Street, Suite 6400 Los Angeles, CA 90071
TELEPHONE: 213.624.7444

Lisa J. Borodkin (CA Bar #196412) lborodkin@iyph.com Admitted Pro Hac Vice
Firm State Bar No. 00443100 Renaissance One, Two North Central Ave. Phoenix, AZ 85004-2391
TELEPHONE 602.229.5200

Quarles & Brady LLP

John S. Craiger (#021731) John.Craiger@quarles.com David E. Funkhouser III (#022449) David.Funkhouser@quarles.com Attorneys for Defendant Lisa Jean Borodkin IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA XCENTRIC VENTURES, LLC, an Arizona limited liability company, Plaintiff, v. LISA JEAN BORODKIN and JOHN DOE BORODKIN, husband and wife; RAMOND MOBREZ and ILIANA LLANERAS, husband and wife; DANIEL BLACKERTS and JANE DOE BLACKERTS, husband and wife; ASIA ECONOMIC INSTITUTE, LLC, a California limited liability company, DOES 1-10, inclusive Defendants. No. 2:11-CV-01426-PHX-GMS DECLARATION OF LISA JEAN BORODKIN IN SUPPORT OF MOTION TO DISMISS FOR LACK FO PERSONAL JURISDICTION AND IN SUPPORT OF MOTION TO DISMISS FOR IMPROPER VENUE (28 U.S.C. 1406(A)) OR IN THE ALTERNATIVE TO TRANSFER FOR CONVENIENCE (28 U.S.C. 1404(A)) (Assigned to the Honorable G. Murray Snow)

Case 2:11-cv-01426-GMS Document 47-1 Filed 12/03/11 Page 2 of 3

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I, Lisa J. Borodkin, declare, I have first-hand, personal knowledge of the facts set forth below and, if called as a witness, I could and would testify competently thereto. 1. 2. 3. 4. I am a resident of the State of California, and am over the age of 18 years. I am named individually as a defendant in this litigation. I have continually resided in California since January 2008. I have never resided in the State of Arizona. I have never owned real

property in Arizona. I have never employed agents or employees in Arizona. I have never conducted any business in Arizona or solicited any business in Arizona. I have never done any business with the Plaintiff, Xcentric Ventures, LLC (Xcentric). I have never registered for the Plaintiffs website, ripoffreport.com. I have no contracts with Plaintiff or with any Arizona companies. Aside from my pro hac vice admission in this Action, I have never practiced law in Arizona. 5. I was co-counsel for the plaintiffs for a portion of the underlying litigation in the Central District of California, Asia Economic Institute LLC et al. v. Xcentric Ventures LLC et al., C.D.Cal. No. 2:10-cv-01360-SVW-PJW (the California Action). 6. As the defendants Xcentric Ventures LLC (Xcentric) and Ed Magedson (Magedson) wished to have their depositions taken at an undisclosed location in Arizona, my co-counsel, Daniel F. Blackert and I traveled to Arizona on June 2, 2010 to take the deposition of Magedson as the Rule 30(b)(6) designee of Xcentric. 7. 8. On June 8, 2010, Blackert and I also traveled to Arizona to take the On July 20, 2010, Blackert, Defendant Raymond Mobrez and I traveled to deposition of Magedson as an individual. Arizona to continue the deposition of Magedson. However, that deposition did not go forward. During that time, my co-counsel and I met and conferred with opposing counsel pursuant to Central District of California Local Civil Rule 7-3 for a motion for reconsideration. On that date, the Plaintiffs in the California Action also made Mobrez

Case 2:11-cv-01426-GMS Document 47-1 Filed 12/03/11 Page 3 of 3

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available for deposition, under oath, at Mobrezs expense, to answer any questions regarding the circumstances of Mobrezs and Llaneras corrected declarations . Xcentrics counsel declined the offer. On that date, we also engaged in informal efforts to discuss settlement with opposing counsel. 9. No compulsory process was issued from the state or federal courts of Arizona in connection with the California Action. No witnesses in Arizona, aside from Party-Defendants Xcentric and Magedson, were subpoenaed or deposed in Arizona by the Plaintiffs in the California Action. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed this 2nd day of December, 2011, in Los Angeles, California. /s/ Lisa J. Borodkin Lisa J. Borodkin