Democratic National Committee v. The Russian Federation et al

Filing 153

DECLARATION of Julia A. Horwitz in Support re: #151 MOTION to Serve Defendant Aras Agalarov by Alternate Means.. Document filed by Democratic National Committee. (Attachments: #1 Exhibit A)(Sellers, Joseph)

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
DEMOCRATIC NATIONAL COMMITTEE,
Plaintiff,
v.
THE RUSSIAN FEDERATION et al.,
Defendants.

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) Civil Action No. 1:18-cv-03501-JGK
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DECLARATION OF JULIA A. HORWITZ
I, Julia Horwitz, declare as follows:
1.

I am an attorney at Cohen Milstein Sellers & Toll, PLLC. I am counsel for Plaintiff in the

above-referenced matter. I submit this declaration in connection with Plaintiff’s Motion to Serve
Defendant Aras Agalarov by Alternate Means. I have personal knowledge of all facts stated in this
declaration, and if called to testify, I could and would testify competently thereto.
2.

Despite diligent efforts to search databases, dockets, and news reports for addresses,

Plaintiff’s counsel has not located a mailing address for Defendant Aras Agalarov in Russia or in
Azerbaijan. Plaintiff’s counsel has located only one United States address: a luxury condominium
on Fisher Island in Miami Beach, Florida.
3.

Plaintiff’s counsel believes that Aras Agalarov resides abroad, likely in Moscow, where

Crocus Group, Aras Agalarov’s real estate development firm, is based.
4.

Plaintiff’s counsel located this Florida address without the guidance of Aras Agalarov’s

counsel, by consulting publicly-available real estate reports.

5.

Plaintiff’s counsel mailed Aras Agalarov a service waiver at the Florida address on May 2,

2018. When Plaintiff’s counsel did not receive a response to the waiver by the deadline, Plaintiff’s
counsel hired a process server to attempt personal service at the Florida address.
6.

After the process server was unable to serve Aras Agalarov at the Florida address,

Plaintiff’s counsel searched real estate reports and other publicly available sources for other
addresses where Aras Agalarov might reside. However, this search was fruitless.

I declare under penalty of perjury that the foregoing is true and correct.
Executed this 24th day of July 2018 in Washington, D.C.

_____________________
Julia Horwitz

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