Democratic National Committee v. The Russian Federation et al

Filing 242

DECLARATION of Joseph M. Sellers in Opposition re: #224 MOTION to Dismiss the Second Amended Complaint., #229 MOTION to Dismiss Second Amended Complaint.. Document filed by Democratic National Committee. (Sellers, Joseph)

Case 1:18-cv-03501-JGK Document 242 Filed 04/18/19 Page 1 of 2

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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DECLARATION OF JOSEPH M. SELLERS:
I, Joseph M. Sellers, declare as follows:
1.

I am a partner 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 Omnibus
Memorandum of Law in Opposition to Defendants’ Motions to Dismiss and Russia’s Statement
of Immunity. I have personal knowledge of all facts stated in this declaration, and if called to
testify, I could and would testify competently thereto.
2.

Plaintiff certifies that, based on the information currently available to it and its counsel,

Defendant WikiLeaks is not subject to the jurisdiction of any state.
3.

Plaintiff further certifies that, if the Court finds Defendants Aras Agalarov and Emin

Agalarov (the “Agalarovs”) are not subject to jurisdiction under N.Y.C.P.L.R. § 302, based on the
information currently available to Plaintiff and its counsel, the Agalarovs are not subject to the
jurisdiction of any state.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.

Case 1:18-cv-03501-JGK Document 242 Filed 04/18/19 Page 2 of 2

Executed this 18th day of April 2019 in Washington, D.C.

/s/ Joseph M. Sellers__________
Joseph M. Sellers

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