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1 DECLARATION OF WILLIAM N. GREENE,23

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I William N. Greene, declare:1. I am the President of Cross Complainant California ConsuJting Group dba California

Consulting Group International, a California corporation (hereinafter referred to asCross Complainant ) in the above-captioned matter. I am responsible for the

business affairs of Cali fomi a Consult ing Group and have personal knowledge of allfacts and matters with respect to the loan made to Cross Defendant Karen de laCarriere (hereinafter referred to as ' Carriere ) in the sum of ] 75,000.00. If calledupon to testify in this matter, I could and would competently testify to the factsstated herein.

2. I make and submit this Declaration in suppor t of California Consulting Group sapplication for right to attach orders and orders for issuance of writs of attachment inthis action against Cross Defendant Carriere, an individual.

3. I make and submit this Declaration based upon my personal knowledge and the

information contained in the records maintained by me with relation to the followingtransactions, over which I have maintained custody and control in the ordinarycourse of my business.

4. As payments have been received by me, information regarding transactions andaccounts for which such payments are received is inputted by me or by myemployees who have a duty in the ordinary course and scope of their employment toaccurately record such transactions into the business records of such accounts at ornear the time of their occurrence in the ordinary course of business. The records andother documents in my files relating to the account described be10w, including thedocuments submitted in conjunction with my Declaration, constitute writings made

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and kept in the ordinary and regular course of my business, at or near the time of theevent, act, or occurrence, of which they are a record.

5 1 further state from my own knowledge that each such record or document wasprepared by me or persons employed by me who have persona] knowledge of theevents being recorded and who had a duty in the course and scope of theiremployment to accurately record the events and information contained in suchrecords and documents at or near the time of the occurrence in the ordinary course ofbusiness, and/or are documents received as prepared from third parties andaccurately maintained as received by me in the ordinary course of business, and werereceived and are kept in the ordinary and reguJar course of my business.

6 The authenticity of the Loan is evidenced by the fact that Cross Defendant Carrierehas acted upon it as authentic in that, among other things, Cross Defendant Carrierehas made payments on the loans at issue and/or has not disputed the amountsclaimed as past due and owing.

7 On or June 9, 1998, Cross Defendant Carriere informed me that she would like toborrow money from California Consulting Group as an investment towards thepurchase of commercial real property commonly known as 1935 N. Serrano Ave.,Los Ange]es, C 90027. Carriere further informed me that she intended on carryingout the business of leasing the units of said commercial rea] property to collect rentfrom the prospective tenants. Additionally, Carriere informed me that she intendson operating an art business which will occupy a portion of the commercial rentalproperty. Carriere's art business is estimated to bring in an annual revenue of100,000 to 400,000.

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8. On or about June 9, 1998, Cross Defendant Carriere, for valuable consideration,executed in my presence, a written Promissory Note in the favor of CaliforniaConsulting Group (hereinafter referred to as the Loan Agreement ), a true andcorrect copy of the Loan Agreement is attached hereto as Exhibit 1 and incorporatedherein by reference .

9. Cross Defendant Carriere promised to pay California Consulting Group the principalsum of One Hundred and Seventy Five Thousand and no 00/1 00 ($175,000.00),together with interest at the rate of fourteen and a half percent (14.5%) per annum.

10. The Loan Agreement was secured by a Deed of Trust for the property commonlyknown as 1935 N. Serrano Ave., Los Ange]es, CA 90027 ( subject property ) andlegally described as Lot 45 of Tract No. 3823, as per map recorded in book 41, page78 of maps in the office of the county recorder of Los Angeles County, APN 5587-024020, recorded on December 28, 1998 in the Los Angeles County Recorder'sOffice as Instrument number 982343686.

I ] . The Loan Agreement provides that S years PLUS 30 DAYS after date, for valuereceived, the undersigned maker(s), promise(s) to pay to CALIFORNIACONSULTING GROUP the principal sum of One Hundred and Seventy FiveThousand and noll 00 DOLLARS, with interest from 1 July 1998 on the unpaidprincipal at the rate of 4 ~ percent per annum, payable NOT LESS THANANNUALLY ON OR BEFORE JULY 1.

12. Additionally, pursuant to the Loan Agreement, if interest is not paid when due, itshall thereafter bear like interest as the principal, but such unpaid interest socompounded shall not exceed an amount equal to simple interest on the unpaidprincipal at the maximum rate permitted by law.

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13. Further, should default be made in payment o interest when due, the whole sum oprincipal and accrued interest shall become immediately due, without notice, at theoption o the California Consulting Group.

14. On or about June 9, 1998, in express reliance thereon, California Consulting Groupdisbursed funds to Cross Defendant Carriere for the purchase o commercial realproperty.

15. Thereafter, on or around February 2003, Cross Defendant Carriere executed anddelivered to California Consulting Group a Loan Agreement renewing the 1998 LoanAgreement pursuant to which she promised to pay present and future obligations toCalifornia Consulting Group. ( 2003 Loan Agreement ) A true and correct copy osaid Loan Agreement executed and delivered in 2003 is attached hereto as Exhibitand incorporated herein.

16. The 2003 Loan Agreement was secured by a 2003 Deed o Trust against the propertycommonly known as 1935 N. Serrano Ave., Los Angeles, CA 90027 and legally

described as Lot 45 o Tract No. 3823, as per map recorded in book 41, page 78 omaps in the office o the county recorder o Los Angeles County, APN 5587-024-020, recorded on October 9 2003 in the Los Angeles County Recorder' s Office asInstrument number 033025404.

17. The 2003 Loan Agreement extended the maturity date to 2008. However, when thenote matured in 2008, Cross Defendant Carriere was yet again unable to make thepayments due pursuant to the renewed 2003 Loan Agreement.

18. Cross Defendant Carriere and I on behalf o California Consulting Group, hadextensive discussions with regards to revising the 2003 Loan Agreement to include alower interest rate. Cross Defendant Carriere represented that she is unable to makepayments under the loan agreement due to the economic crisis.

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19. Therefore, on or around October 9, 2008, to assist Carriere with repayment o theloan, California Consulting Group and Cross Defendant Carriere renegotiated theteffils o the Loan Agreement and California Consulting Group agreed to indefinitelyextend the tenns o the loan until Cross Complainant notified Carriere otherwise.

20. Cross Defendant Carriere yet again defaulted under the Loan Agreement by, interalia failing to make the payments under the Loan Agreement that fell due onNovember I, 2008, and by failing to make any subsequent payments that fell dueunder the Loan Agreement.

21. On behalfo California Consulting Group, I ultimate1y notified Carriere that thematurity date under the Loan Agreement shall be extended to April 2012.

22. By reason o Carriere s default) I on behalfo Cross Complainant, exercised theoption to dec1are the entire unpaid balance under the Loan Agreement to beimmediately due and payable.

23. Despite Cross Complainant s demands, Cross Defendant ultimately failed to pay thebalance due under the Loan Agreement. Attached hereto as Exhibit 4 is a true andcorrect copy o the July 22, 2012 demand letter I sent to Defendant.

24. On or around October 5, 2012, Carriere further defaulted under the Loan Agreementby, inl r alia fiJing a Complaint disputing the validity o the 2003 Deed o Trustclaiming that the 2003 Deed o Trust is a forgery, California Consulting Group doesnot have a valid security interest and no monies are owed by Carriere to CrossComplainant.

25. Cross Complainant perfonned all the tenns and conditions on its part to beperformed with relation to the above referenced Loan Agreement, except for suchteffils and conditions as have been excused by the conduct and breaches o CrossDefendant, if any.

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26. As o November I, 2012, under the Loan Agreement, there was due, owing andunpaid by Cross Defendant, the principal sum o 175,000.00 and accrued interest inthe additional sum of 587,060.78, for a total sum o 762,060.78.

27. Cross Complainant is infonned and believes that Cross Defendant owns an interestin the following property that is subject to attachment:

a. 1935 N. Serrano Ave., Los Angeles, CA 90027Legally described as: Lot 45 o Tract No. 3823, as per map recordedin book 41, page 78 o maps in the office o the county recorder oLos Angeles County. Assessor 's Parcel No: 5587-024-020

b. Any other real property, personal property, equipment, motor vehicles,chattel paper, negotiable and other instruments, securities, deposit accounts,safe deposit boxes, accounts receivable, general intangibles, property subjectto pending actions, final money judgments, and personal property in estateso decedents, pursuant to CCP 487.01 O c), and community property that

qualifies under the criteria subject to attachment pursuant to CCP 487.010(d).

28. Cross Complainant has no infonnation or belief that the claim is discharged in a U.S.Code Title 11 bankruptcy proceeding or that the prosecution o the action is stayed ina Title 11 proceeding.

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I 29. Cross Complainant is entitled to a \Vril ofAt1achment against Cross Defendant for2 the ~ u r e debt based upon the Loan Agreements in the folJowing amount3

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PrincipalInterest at the rate o 14.5per annumTOTAL

175,000.00S587,060.78

S 761,060.78I ~ J a r e under penalty of pe jUl)' Wlder the laws o the State o California that the

forgoing is true and correct, except as to such maners as are set forth upon information and10 belief, and as to such matters, I believe them to be true.111213141516111819202122232425262728

Executed this 3 ~ day o December, 2 1 ~ at Los Angeles, California.

WllLIAM. N. OR&'.iE on behalf ofCalifornia. Consulting Group dba ,California Consulting Group Intema.tionaJ