IN THE SUPERIOR COURT FOR THE STATE OF WASHINGTON

IN AND FOR THE COUNTY OF KING

NAOMI ANTLE, an individual, and REUBEN REISENWEBER, an individual,
Plaintiffs,
v.
STEPHAN KLOS, an individual, STEPHAN ANTHONY LARSON and JANE DOE LARSON and the marital community consisted thereof, BRIAN LARSON and JANE DOE LARSON and the marital community consisted thereof, KENNETH NEAL and JANE DOE NEAL and the marital community consisted thereof, BVISUAL GROUP LIMITED, a Washington limited liability company, BVISUAL USA, INC a corporation, BVISUAL, S.A., a Washington company, and JOHN DOES 1-5,
Defendants.
/ NO. 12-2-37063-0 SEA
MOTION TO DISMISS OR, OR IN THE ALTERNATIVE, TO TRANSFER OR CHANGE VENUE

I, ______, was a director of the company during the relevant time in the above captioned lawsuit. I have first-hand knowledge of certain facts pertinent to this action and I declare and state as follows.

  1. The Defendants, Stephan Anthony Larson, Brian Larson and Jane Doe Larson, and Kenneth Neal have and currently reside in Okanogan County.
  2. The Defendants bVisual, SA a Panama Corporation, bVisual Group Ltd. an Irish Corporation, and bVisual USA, Inc. had a physical premise and operations in Okanogan County.
  3. The Defendants bVisual, SA a Panama Corporation, bVisual Group Ltd. an Irish Corporation, and bVisual USA, Inc. did NOT have any physical presence or operations in King County.
  4. All business of bVisual was conducted in Okanogan County.
  5. Naomi Antle traveled to Okanogan County where she met the Company, was demonstrated the product, met many of the employees, some of the shareholders and agreed to invest. I did not go to King County to meet with Naomi Antle.
  6. All work performed in Washington State by bVisual employees related to this lawsuit was performed in Okanogan County, the company employed software programmers who telecommuted to Okanogan County.
  7. At least fifteen (15) of the named material key witnesses for Plaintiff has been, during relevant times, and remains a residence of Okanogan County. Such witnesses will be asked to testify as shown on Exhibit A.
  8. All company documents have been continuously located in Okanogan County.
  9. I am a resident of Okanogan County. I do not intend to travel to King County as a witness for depositions or trial. King County is in excess of 250 miles from my residence. I cannot miss work. The inconvenience would prohibit my attendance. I would be able to attend as a witness in Okanogan County.
  10. Many more individuals who received demonstrations reside in Okanogan County than King County.
  11. The product and servers can only be fully demonstrated in Okanogan County.

Submitted under penalty of perjury.

By:______
Printed:______

Dated:______

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