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`DECLARATION OF CARLOS A. NEVAREZ
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`I, Carlos A. Nevarez, declare as follows:
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`1.
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`I am an active member of the Bar of the State of California and an associate
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`with Bienert Katzman Littrell Williams LLP, attorneys of record for Defendant
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`Mohammed Abdul Qayyum in this action. I make this declaration in support of
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`Defendants’ Motion In Limine No. 7 to Exclude References to Preclude References to
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`Certain Individuals as “Victims”, except for those matters stated on information and
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`belief, I make this declaration based upon personal knowledge and, if called upon to do
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`so, I could and would so testify.
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`2.
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`Exhibit A hereto are true and correct copies of excerpts from the transcript
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`of the hearing on February 14, 2019.
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`3.
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`Exhibit B hereto are true and correct copies of excerpts from the transcript of
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`SAD’s Rule 15 deposition on September 15, 2021. Portions of the transcript which are
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`subject to the parties’ objections have been redacted.
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`4.
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`Exhibit C hereto are true and correct copies of excerpts from the transcript
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`of LWT’s Rule 15 deposition on September 9, 2021. Portions of the transcript which are
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`subject to the parties’ objections have been redacted.
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`5.
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`Exhibit D hereto are true and correct copies of excerpts from the transcript
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`of the hearing on April 30, 2019.
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`6.
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`Exhibit E hereto is a true and correct copy of a summary of the FBI
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`interview of Thomas Conner on October 27, 2014, which the government produced in
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`discovery.
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`7.
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`Exhibit F hereto is a true and correct copy of a summary of the FBI
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`interview of Mike Durbin on October 29, 2015, which the government produced in
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`discovery.
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`8.
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`Exhibit G hereto is a true and correct copy of a summary of the FBI
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`interview of Rhonda Johnson on February 24, 2012, which the government produced in
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`discovery.
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`1
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`DECLARATION OF CARLOS A. NEVAREZ
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`3:18-cr-04683-GPC
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`Case 3:18-cr-04683-GPC Document 358-2 Filed 03/24/22 PageID.5056 Page 2 of 2
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`9.
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`Exhibit H hereto is a true and correct copy of a summary of the FBI
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`interview of Anne Gideon on February 18, 2021, which the government produced in
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`discovery.
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`I declare under penalty of perjury under the laws of the United States of America
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`that the foregoing is true and correct, and that I executed this declaration on March 24,
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`2022, at Los Angeles, California.
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`/s/ Carlos A. Nevarez
` Carlos A. Nevarez
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`DECLARATION OF CARLOS A. NEVAREZ
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`3:18-cr-04683-GPC
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