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Case 1:12-cv-08551-LLS Document 31 Filed 04/26/13 Page 1 of 2

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

CORNWALL MANAGEMENT LTD and OLEG
SOLOVIEV a!k/a OLEG V ALENTINOVJCH
SOLOVIEV

Civil Action No. 12-cv-08551 (LLS)

Plaintiffs,

v.

THOR UNITED CORP. a/k/a THOR UNITED
CORPORATION, JOHN DOE THOR ENTITIES,
A TLANT CAPITAL HOLDINGS, LLC, OLEO
BATRACHENKO a/k/a OLEG
BATRATCHENKO a/k/a O.V.
BATRACHENKOV, PETER KAMBOLIN
NORTH 3RD DEVELOPMENT, LLC and
ABRAHAM BENNUN,

Defendants.

I, PETER KAMBOLIN, do hereby declare under the penalty of perjury pursuant to 28

U.S. C. § 1746 as follows:

1.

I am a named defendant in this action and respectfully submit this Declaration in

support of Defendants' Motion to Dismiss the Amended Complaint.

2.

Prior to 2005, I worked with Oleg Batrachenko, also a defendant in this action.

om of otrices located at 551 Fifth Avenue. New York, New York.

3.

Based on the conversations that we had when we worked together, J know that

Mr. Batrachenko had come to the United States from Russia, and was a Russian citizen.

4.

In 2005, Mr. Batraehenko lett New York to retum to live in Russia. To my

knowledge he has been a permanent resident of Russia ever since. and currently Jives in the

Moscow area with his wife and children.

5.

Since 2005, I have spoken with Mr. Batrachcnko from time to time and he has

always called me from Russia.

Case 1:12-cv-08551-LLS Document 31 Filed 04/26/13 Page 2 of 2

1 declare under penalty of perjury that the foregoing statements are tme and conect.

Date: April 18, 2013

2