1st Technology LLC v. Rational Enterprises Ltda. et al

Filing 45

DECLARATION of ANA VICTORIA MORA FLORES in support of 44 Amended Motion to set aside by Defendants Bodog Entertainment Group S.A., Bodog.net, Bodog.com. (McCrea, Jr., Charles) Modified to add docket relationship on 9/18/2007. (MAJ)

1st Technology LLC v. Rational Enterprises Ltda. et al

Doc. 45

Case 2:06-cv-01110-RLH-GWF

Document 45

Filed 09/10/2007

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Charles McCrea (NV State Bar No. 104) LIONEL SAWYER & COLLINS 2 1700 Bank of America Plaza 300 South Fourth Street 3 Las Vegas, Nevada 89101 Tel [phone] Fax [phone] [e-mail]
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James D. Nguyen (CA State Bar No. 179370) Uleses C. Henderson, Jr. (CA State Bar No. 225246) Pro Hac Vice Applications To Be Submitted 7 FOLEY & LARDNER LLP 2029 Century Park East, 35th Floor 8 Los Angeles, California 90067-3021 Tel: [phone]; Fax: [phone] [e-mail] [e-mail]

Attorneys for Specially Appearing Defendants BODOG ENTERTAINMENT GROUP S.A., and erroneously named Specially Appearing Defendants 12 BODOG.NET and BODOG.COM
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UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 1ST TECHNOLOGY LLC, Plaintiff, vs. Case No: 2:06-cv-1110-RLH-GWF DECLARATION OF ANA VICTORIA MORA FLORES

RATIONAL ENTERPRISES LTDA., RATIONAL POKER SCHOOL 21 LIMITED, BODOG 22 ENTERTAINMENT GROUP S.A., BODOG.NET, BODOG.COM, AND 23 FUTUREBET SYSTEMS LTD.,
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MORA DECLARATION 2:06-cv-11105-RLH-GWF

Defendants.

LACA_869504.2

Dockets.Justia.com

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LACA_869504.2

I, Ana Victoria Mora Flores, declare as follows: 1. I am an administrative assistant for Manejo Satelital de vos y datos Mansat S.A. ("Mansat"), in its San Jose, Costa Rica office. I make this declaration in support of Specially Appearing Defendant Bodog Entertainment Group S.A. ("Bodog Entertainment") and erroneously named Specially Appearing Defendants Bodog.net and Bodog.com's Amended Motion to Set Aside Default Judgment. The matters referred to in this declaration are based upon my personal knowledge, and if called as a witness I could testify competently to those matters. 2. Prior to joining Mansat, I was employed by Bodog Entertainment Group S.A., in its San Jose, Costa Rica office, where I held the title of administrative assistant. I was not an owner, officer or director of the company. As far as I know, Bodog Entertainment ceased its operations in Costa Rica in or about October 2006. 3. During my employment with Bodog Entertainment, the company policy was that administrative staff was not allowed to accept any packages or documents on behalf of the Bodog Entertainment without the prior approval of an office manager. I do not recall being served with any complaint filed in the United States or with the summons and complaint to this action; I have received other packages on behalf of Bodog Entertainment and I would have remembered if I was served with the complaint in this action because I would have been required to obtain management approval before accepting service. 4. I am a 28-year-old Hispanic female that stands 5 feet, 4 inches tall. In or about November 2006, my hair color was red and I weighed 68 kilograms (approximately 150 lbs).

MORA DECLARATION 2:06-cv-11105-RLH-GWF

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LACA_869504.2

I declare under the penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on September 10, 2007, at San Jose, Costa Rica. /s/ Ana Victoria Mora Flores Ana Victoria Mora Flores

MORA DECLARATION 2:06-cv-11105-RLH-GWF

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CERTIFICATE OF SERVICE

I hereby certify that on September 10, 2007, I caused the following 3 document: DECLARATION OF ANA VICTORIA MORA FLORES to be filed electronically with the Clerk of Court through ECF, and that ECF will send an 4 e-notice of the electronic filing to the following:
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L. Kristopher Rah 6 HUTCHINSON & STEFFEN, LLC Peccole Professional Park 7 10080 West Alta Drive, Suite 200 Las Vegas, Nevada 89145
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MORA DECLARATION 2:06-cv-11105-RLH-GWF

Dated:

September 10, 2007

/s/ Charles McCrea Charles McCrea

LACA_869504.2