Declaration of Kevin A.

I, Kevin A., hereby declare:

1. I am over the age of eighteen (18) years of age and have personal knowledge of the following testimony and if called upon to testify thereto in a court of law, I can and will do so competently.
2. On or about March 26, 2019, I, Kevin A., and Sholom Goodman ("Goodman") mutually agreed upon and entered into a Secured Loan Agreement (hereinafter the "Agreement") whereby I loaned Goodman the sum of One Hundred Thousand Dollars ($100,000.00 USD) at an interest rate of 10% secured by real estate owned by Defendant located at 932 South Westmoreland Ave., Los Angeles, California 90006 (the Security Property"), and a personal guarantee, and Goodman agreed to repay the loaned funds with interest according to a repayment schedule set forth in the Agreement.
3. Attached as Exhibit A is a true and correct copy of the fully executed Secured Loan Agreement referenced in paragraph two (2).
4. Goodman knowingly and intentionally represented and warranted to me that the loan was secured by Goodman's sufficient ownership in the Security Property and that I would have adequate recourse against the Security Property if Goodman did not repay the loan because Goodman would not encumber the Security Property or otherwise effect my priority security interest in the Security Property as further set forth in paragraph G of the Agreement.
5. Subsequently, Goodman made several payments in substantial compliance with the terms of the Agreement; however, Goodman ceased making payments before fully completing the agreed-upon repayment schedule. At the time I filed this lawsuit, August 31, 2024, Defendant still owed me a balance of $28,111.75 on the original loan.
6. After Goodman's breach, I also discovered that Goodman was no longer an owner of the Security Property and that Goodman and the co-owners of the Security Property sold the Security Property without notifying me or allowing me any reasonable opportunity to gain a priority security interest in the Security Property pursuant to the representations and warranties made by Goodman in the Agreement.
7. I later learned that Goodman never intended to honor the representations and warranties he made in the Agreement and the false representations and warranties were made knowingly and intentionally for the purpose of fraudulently inducing me into entering into the Agreement and offering Goodman a personal loan.
8. Through false representations, misrepresentation, or material omissions, Goodman fraudulently induced me into entering into the Agreement to provide Goodman a personal loan and then subsequently breached the Agreement by failing to repay the personal loan pursuant to the terms and condition of the Agreement.
9. I made many attempts to resolve this dispute informally; however, when such attempts were unsuccessful and communication broke down, I brought this lawsuit.
10. After being served with the Company in this lawsuit, Goodman reached out to me via my attorney and expressed a desire to resolve the matter informally. We re-engaged in settlement negotiations until approximately mid-December 2024 when Defendant Goodman stopped communicating with me once again.

I declare under penalty of perjury of the laws of the State of California that the forgoing is true and correct.

Executed this 30th day of August 2024 in Los Angeles County, California.