Incorp Services, Inc., v. Legalzoom.com, Inc.,

Filing 21

DECLARATION of Tennie Sedlacek re 12 MOTION to Transfer Venue Pursuant to 28 U.S.C 1404(a); Memorandum Of POints and Authorities In Support Thereof; Affidavit of Kathryn Pellman With Exhibit A ; filed by Plaintiff Incorp Services, Inc.,. (DECLARATION OF TENNIE SEDLACEK IN OPPOSITION TO MOTION TO TRANSFER VENUE) (Kronenberger, Karl)

Incorp Services, Inc., v. Legalzoom.com, Inc.,

Doc. 21

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KRONENBERGER BURGOYNE, LLP Karl S. Kronenberger (admitted pro hac vice) 150 Post Street, Suite 520 San Francisco, CA 94108 Telephone: [phone] Facsimile: [phone] [e-mail] Law Offices of Rasmussen & Kang Dowon S. Kang (Bar No. 7042) (Local Counsel) 330 S. Third Street, Suite 1010 Las Vegas, Nevada 89101 Telephone: [phone] Facsimile: [phone] [e-mail] Attorneys for Plaintiff INCORP SERVICES, INC.

UNITED STATES DISTRICT COURT DISTRICT OF NEVADA INCORP SERVICES, INC., a Nevada corporation, Plaintiff, vs. LEGALZOOM.COM, INC., a Delaware corporation, Defendant. Case No. 2:09-cv-00273-RLH-LRL DECLARATION OF TENNIE SEDLACEK IN SUPPORT OF PLAINTIFF'S OPPOSITION TO DEFENDANT LEGALZOOM.COM, INC.'S MOTION TO TRANSFER VENUE

Case No. 2:09-cv-00273-RLH-LRL

DECL. OF T. SEDLACEK ISO OPP. TO MOTION TO TRANSFER VENUE
Dockets.Justia.com

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I, Tennie Sedlacek, declare as follows: 1. I am the President of the Nevada corporation, Incorp Services, Inc.

("Incorp"), a party in this action. As President, I have knowledge regarding Incorp's current and former employees, Incorp's customer base, and Incorp's day-to-day operations. Unless otherwise stated, I have personal knowledge of the matters stated herein. 2. Incorp is a corporation registered with the Nevada Secretary of State,

headquartered in Henderson, Nevada. 3. Incorp has about 45 employees, all of whom are located in Nevada.

Several of Incorp's employees witnessed LegalZoom.com, Inc. ("LegalZoom")'s misconduct at issue in this lawsuit and/or witnessed the harm suffered by Incorp as a result of LegalZoom's misconduct. Incorp intends to call the following employees as witnesses at trial to testify about these subjects: a. Gayle Clauges, Director of Customer Service, located in Las Vegas, Nevada; b. Cecilia Padilla, Account Executive, located in Las Vegas, Nevada; and c. 4. Marcus Moore, Account Executive, located in Las Vegas, Nevada.

Compelling roughly 7% of Incorp's employees to travel to California for a

trial would greatly hinder Incorp's ability to carry out its day-to-day operations and fulfill its obligations to its customers. 5. Several third parties also witnessed LegalZoom's misconduct. At this time,

Incorp intends to call the following third-parties as witnesses at trial to testify about the false and defamatory statements made by LegalZoom about Incorp: a. b. Doug Ansell, located in Las Vegas, Nevada; and Anthony P. Schober, former customer of Incorp, located in Plano, Texas. 6. Incorp has never had any employees in California, maintained an office in
1 DECL. OF T. SEDLACEK ISO OPP. TO MOTION TO TRANSFER VENUE

Case No. 2:09-cv-00273-RLH-LRL