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I Austa Wakily declare as follows:

1. I am one of the attorneys for judgment creditors Knapp, Peterson & Clarke, Stephen Ray

Garcia, Stephen Harris, and Andre Jardini (collectively KPC) in the above captioned matter. I

make this Declaration based on my own personal knowledge and would be competent to testify to

them in court.

2. Attached as Exhibit A is a true and correct copy of the Statement of Decision issued by this

Court in the underlying action, Gaggero v. Knapp, Petersen & Clarke, et al, Los Angeles Superior

Court (Case No. BC286925). Attached as Exhibit A-2 is a true and correct copy of excerpts from

the Appellate Courts Decision affirming this Courts ruling in the underlying case. Gaggero v.

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Knapp, Petersen & Clarke, et al (2010), California Court of Appeal, Second Appellate District,

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Division Eight, (Appeal Case No B207567) (Trial Case No. BC286925).

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3. Attached as Exhibit B is a true and correct copy of the Amended Judgment filed in the
Gaggero v. Knapp, Petersen & Clarke, et al, Los Angeles Superior Court (Case No. BC286925).

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4. Attached as Exhibits C is a true and correct copy of excerpts from the Reporters

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Transcript on Appeal of Stephen Gaggeros Direct Examination on June 27, 2005. Gaggero v.

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Yura (2008), California Court of Appeal, Second Appellate District, Division Five, (Appeal Case

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No. B203780) (Trial Case No. BC239810).

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5. Attached as Exhibits D is a true and correct copy of excerpts from the Reporters

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Transcript on Appeal of Stephen Gaggeros Direct Examination on June 28, 2005. Gaggero v.

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Yura (2008), California Court of Appeal, Second Appellate District, Division Five, (Appeal Case

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No. B203780) (Trial Case No. BC239810).

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6. Attached as Exhibits E is a true and correct copy of excerpts from the Reporters

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Transcript on Appeal of Stephen Gaggeros Direct Examination on June 29, 2005. Gaggero v.

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Yura (2008), California Court of Appeal, Second Appellate District, Division Five, (Appeal Case

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No. B203780) (Trial Case No. BC239810).

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7. Attached as Exhibits F is a true and correct copy of excerpts from the Reporters Transcript

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on Appeal of Joseph Praske Direct Examination on June 30, 2005. Gaggero v. Yura (2008),

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-2DECLARATION OF AUSTA WAKILY IN SUPPORT OF

MOTION TO AMEND JUDGMENT TO ADD JUDMENT DEBTORS

California Court of Appeal, Second Appellate District, Division Five, (Appeal Case No. B203780)

(Trial Case No. BC239810).

8. Attached as Exhibits G is a true and correct copy of excerpts from the Reporters

Transcript on Appeal of Joseph Praske Cross Examination on June 30, 2005. Gaggero v. Yura

(2008), California Court of Appeal, Second Appellate District, Division Five, (Appeal Case No.

B203780) (Trial Case No. BC239810).

9. Attached as Exhibits H is a true and correct copy of excerpts from the Reporters

Transcript on Appeal of Stephen Gaggeros Re-Direct Examination on July 15, 2005. Gaggero v.

Yura (2008), California Court of Appeal, Second Appellate District, Division Five, (Appeal Case

MILLER | LLP

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No. B203780) (Trial Case No. BC239810).

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10. Attached as Exhibits I is a true and correct copy of excerpts from the Reporters Transcript

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on Appeal of Stephen Gaggeros Re-Direct Examination on July 19, 2005. Gaggero v. Yura

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(2008), California Court of Appeal, Second Appellate District, Division Five, (Appeal Case No.

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B203780) (Trial Case No. BC239810).

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11. Attached as Exhibit J is a true and correct copy of the Reporters Certificate for Transcripts

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on Appeal for the Reporters Daily Transcripts on June 27, 2005; June 28, 2005; June 29, 2005;

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June 30, 2005; July 15, 2005; and July 19, 2005 applicable to Exhibits C- I.

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12. Attached as Exhibit K is a true and correct copy of excerpts from the Reporters Daily

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Transcript taken on August 2, 2007 in Gaggero v. Knapp, Petersen & Clarke, et al, Los Angeles

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Superior Court (Case No. BC286925).

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13. Attached as Exhibit L is a true and correct copy of excerpts from the Reporters Daily

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Transcript on August 7, 2007 in Gaggero v. Knapp, Petersen & Clarke, et al, Los Angeles

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Superior Court (Case No. BC286925).

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14. Attached as Exhibit M is a true and correct copy of the Declarations of Stephen M.

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Gaggero and Joseph Praske in support of a Motion for Reconsideration filed the Gaggero v. Yura,

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Los Angeles Superior Court (Case No. BC239810).

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-3DECLARATION OF AUSTA WAKILY IN SUPPORT OF

MOTION TO AMEND JUDGMENT TO ADD JUDMENT DEBTORS

MILLER | LLP

15. Attached as Exhibit N is a true and correct copy this Courts transcript for the October 5,

2011 hearing on the KPCs motion to compel further responses to post-judgment special

interrogatories in Gaggero v. Knapp, Petersen & Clarke, et al, Los Angeles Superior Court (Case

No. BC286925).

16. Attached as Exhibit O are documents obtained from the website of the Secretary of State of

Nevada. The website provides basic information on corporations or other business entities

incorporated in the state. I personally printed true and correct copies of the information for Pacific

Coast Management on April 3, 2012 by visiting http://nvsos.gov/sosentitysearch and entering

Pacific Coast Management in the search box

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17. Attached as Exhibit P are documents obtained from the website of the Secretary of State of

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California. The website provides basic information on corporations or other business entities

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incorporated in the state. I personally printed true and correct copies of information for 511 OFW,

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LP, Gingerbread Court, LP, Malibu Broadbeach, LP, Marina Glencoe, LP, Blu House, LLC, and

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Boardwalk Sunset, LLC on April 3, 2012 by visiting following website http://kepler.sos.ca.gov

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and entering the entity names in the search box.

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18. Attached as Exhibit Q is Gaggeros responses to KPC Special Interrogatories (Set One).

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KPC served post-judgment Special Interrogatories (Set One) on April 25, 2011. I have reviewed

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all correspondence and motions relating to post-judgment Special Interrogatories (Set One).

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Responses to the discovery were due on June 1, 2011. KPC granted Gaggeros counsel, David

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Chatfield a 2 week extension to June 14, 2011 and another one week extension to June 21, 2011.

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Gaggero served his responses on June 21, 2011. Gaggero did not produce any documents.

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Gaggero provided evasive and frivolous responses. KPC filed a motion to compel further

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responses on August 9, 2011, which this Court granted on October 5, 2011.

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19. Attached as Exhibit R is a true and correct copy of Gaggeros response to KPCs post-

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judgment Request for Production of Documents (Set Two). The discovery was served on January

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31, 2012. Gaggeros attorney, Chatfield, requested a 30 day extension based on Gaggeros limited

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availability due to his traveling. Gaggero received an extension to respond to March 20, 2012.

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-4DECLARATION OF AUSTA WAKILY IN SUPPORT OF

MOTION TO AMEND JUDGMENT TO ADD JUDMENT DEBTORS

Gaggero, through his attorney, provided responses on March 20, 2012. Gaggero did not provide

any documents.

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20. Attached as Exhibit S is true and correct copy of excerpts from Joseph Praske's Third

Party Debtor Exam taken on June 9, 2009 and the Reporter's Certificate of the transcript.

I declare under penalty of perjury that the foregoing is true and correct. Executed on April

2012 in Los Angeles California.

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-5DECLARATION OF AUSTA WAKILY IN SUPPORT OF

MOTION TO AMEND JUDGMENT TO ADD JUDMENT DEBTORS