UNITED STATES OF AMERICA v. 8 GILCREASE LANE, QUINCY, FLORIDA 32351 et al

Filing 17

MOTION to Sever, MOTION to Transfer Case by GOLDEN PANDA AD BUILDER, CLARENCE BUSBY, JR (Attachments: # 1 Memorandum in Support, # 2 Exhibit Exhibit 1 - Affidavit of Clarence Busby Jr., # 3 Exhibit Exhibit 2 - Busby Affidavit in Support of Motion to Sever, # 4 Exhibit Exhibit 3 - Affidavit of Dawn Stowers in Support of Motion to Sever, # 5 Text of Proposed Order)(Emord, Jonathan)

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA UNITED STATES OF AMERICA, c/o United States Attorney's Office 555 Fourth St., N.W., Washington, D.C. 20530, Plaintiff, v. ALL FUNDS, INCLUDING APPROXIMATELY $53 MILLION, HELD ON DEPOSIT AT BANK OF AMERICA ACCOUNTS IN THE NAMES (1) THOMAS A. BOWDOIN, JR., SOLE PROPRIETOR, DBA ADSURFDAILY, (2) CLARENCE BUSBY JR. AND DAWN STOWERS, DBA GOLDEN PANDA AD BUILDER, AND (3) GOLDEN PANDA AD BUILDER, Defendants, and GOLDEN PANDA AD BUILDER, AND CLARENCE BUSBY, JR. Claimants. AFFIDAVIT OF DAWN STOWERS IN SUPPORT OF GOLDEN PANDA'S MOTION FOR SEVERANCE AND TRANSFER Civil Action No: 1:08-cv-01345 Hon. Rosemary M. Collyer

AFFIDAVIT OF DAWN STOWERS IN SUPPORT OF GOLDEN PANDA'S MOTION FOR SEVERANCE AND TRANSFER I, Dawn Stowers, declare under penalty of perjury that the following is true and correct to the best of my knowledge, information, and belief:

EXHIBIT 3

1.

I am the Chief Operating Officer of Golden Panda Ad Builder Inc. ("Golden Panda") (www.goldpandaadbuilder.com). As Chief Operating Officer, I assist in the daily operation of Golden Panda. Golden Panda has 2 directors: Clarence Busby Jr. and Dawn Stowers.

2.

I have resided in Georgia my entire life. I have lived in various locations within Georgia, including: Norcross, Dahlonega, Macon, Hartwell, Powder Springs, Marietta, Kennesaw, and Acworth. I have owned four properties in the State of Georgia. Those properties are located in: Kennesaw (owned for 1 year); Kennesaw (owned for 2 years); Acworth (owned for 8 years); and Acworth (owned for 2 years).

3.

I have never held a job outside the State of Georgia, nor have I transacted business outside Georgia.

4.

I am among the third Busby generation to reside in Georgia. My extended family also lives in Georgia, including my children, brother, and parents.

5.

I am aware that Golden Panda does not employ any individual residing outside the State of Georgia.

6.

Golden Panda has never received funding from the District of Columbia. It received its initial startup money from 34 founders, none of whom reside or resided in the District of Columbia.

7.

I am named on Golden Panda's Bank of America accounts. Golden Panda opened each of those accounts at local institutions in Georgia. The address attributed to those accounts is 4900 Ivey Rd., N.W., Suite 820, Acworth, GA 30101-4001. That was the only address ever listed on those accounts.

EXHIBIT 3

EXHIBIT 3