DEx. 16 Lodged Under Seal - The Washington Post€¦ · DEx. 16 Lodged Under Seal Case...

DEx. 16

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Case 3:13-cv-02519-GPC-WVG Document 49-3 Filed 09/22/14 of 27

DECLARATION OF KISSY GORDON

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David K. Schneider (CSB 139288) YUNKER & SCHNEIDER 655 West Broadway, Suite 1400 San Diego, California 92101 Telephone: (619) 233-5500 Facsimile: (619) 233-5535 Email: [email protected] Attorneys for Defendants TRUMP UNIVERSITY, LLC and DONALD J. TRUMP

UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF CALIFORNIA

TARLA MAKAEFF, BRANDON KELLER, ED OBERKROM, SONNY LOW, J.R. EVERETT and JOHN BROWN, on Behalf of Themselves and All Others Similarly Situated,

Plaintiffs, v. TRUMP UNIVERSITY, LLC, (aka Trump Entrepreneur Initiative, LLC, a New York Limited Liability Company, DONALD J. TRUMP, and DOES 2 through 50, inclusive,

Defendants. AND ALL RELATED CROSS-ACTIONS.

) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Case No. 10 CV 0940 CAB (WVG) CLASS ACTION DECLARATION OF KISSY GORDON DATE: February 12, 2013 TIME: 2:30 p.m. CTRM: 2 — 4

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DECLARATION OF GREGORY LEISHMAN

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Case No. 10 CV 0940 CAB (WVG) CLASS ACTION DECLARATION OF GREGORY LEISHMAN DATE: February 12, 2013 TIME: 2:30 p.m. CTRM: 2 — 4

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DECLARATION OF STEPHEN NESBIT

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Case No. 10 CV 0940 CAB (WVG) CLASS ACTION DECLARATION OF STEPHEN NESBIT DATE: February 12, 2013 TIME: 2:30 p.m. CTRM: 2 — 4

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DECLARATION OF PAUL R. CANUP

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Case No. 10 CV 0940 CAB (WVG) CLASS ACTION DECLARATION OF PAUL R. CANUP DATE: February 12, 2013 TIME: 2:30 p.m. CTRM: 2 — 4

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1 DECLARATION OF PAUL CANUP

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3 I, Paul R. Canup, declare:

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5 1. I am over the age of 18 and not a party to this action. The following facts are

6 based on my own personal knowledge and, if called as a witness, I could testify to them.

7 2. I am providing this declaration freely and voluntarily. I have had the opportunity

8 to review the contents of this declaration and to make any changes I believe are necessary so that

9 it is accurate. I understand that Trump University (aka Trump Entrepreneur Initiative) may use

10 this declaration to support its defense in Makaeff v. Trump University et al., a case described to -

11 me.

12 3. Prior to enrolling in Trump University I did not have experience in real estate as

13 far as investing or anything related. I had never searched for, nor purchased real estate for

14 income purposes. I did have experience however in buying and selling a few homes, but those

15 were for the sole purpose to live in. I had been working in project management for a chemical

16 company when I decided I wanted to begin a new career, and become involved in real estate

17 investing. It was around this time that I heard an advertisement on the radio for a DVD set

18 introducing Trump University (Wealth Builder's Blueprint). I ordered it and then decided to

19 attend the free seminar in 2009. It was a bit of a slow process to become involved since I was

20 still working full time, but it was definitely manageable.

21 4. Following the free seminar, I signed up for a three day retreat in August of that

22 year, and then enrolled in the Trump Gold Elite program. Over the next year and a half, I

23 attended numerous retreats all over the country. These events were what I really valued the most

24 about my experience with Trump University. They were packed with information, and I took a

25 large amount of notes, which I still refer to to this day, and use on an ongoing basis. The Trump

26 University documentation and the large volume of information delivered by the presenters

27 provided the foundation and roadmap for everything I do. The information provided, was unique

28 and found nowhere else to my knowledge. By learning the course material, I have the

DECLARATION OF PAUL R. CANUP

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1 confidence to act on the knowledge and successfully execute the tasks needed to take advantage

2 of the knowledge.

5. In late 2010, I utilized the Trump website (Foreclosure Deal Source) to purchase

4 my first investment property in California, and with the knowledge I gained from the Trump

5 University training, I was able to successfully interview, select, and set up a power team for my

6 business, with an attorney, property manager, contractors, etc. Then a month later, I bought my

7 second property in California. The rehabs were completed and renters were literally standing at

8 the door during the rehab ready to sign leases. The first lease started in January 1,2011, and

9 both properties have been rented full time since their rehabs were completed. I have hired a

10 property management company to manage them for me, as I reside in another state, and the

11 property manager has done a great job! Both of these properties have been continuously

12 producing a good cash flow and profit since day one.

13 6. In 2011, I went to Detroit and purchased a total of five properties there between

14 April and September. I have rehabbed those properties and I am currently renting all five, with

15 an ROI of 16 to 22 percent.

16 7. Shortly after these purchases, I then invested in a raw land property in Texas.

17 After a presentation to the local city council, I was successful in placing the land under contract

18 for double my original investment for a new city park. My project was submitted in a state-wide

19 competition for the best architectural project, and won the state-wide, first place award in this

20 competition as the best project of the year. There is no way I could have managed this land

21 acquisition and the sales contract without the solid foundation provided by the Trump University

22 training and insight to real estate investing.

23 8. All the properties I have invested in I consider an amazing and big success. My

24 plans are to continue making investments, and in the next couple of years, to transition into real

25 estate as my new career. Trump University provided me with several approaches to real estate

26 investing. Since to date, I have only utilized part of this training, I look forward to the

27 adventures ahead utilizing some of the other approaches, especially commercial real estate/multi-

28 family. The training and insights provided by the presenters have been priceless.2

DECLARATION OF PAUL CANUP

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1 9. I attended all of the Trump University training retreats, and even one event twice.

2 I have worked to take advantage of the training by implementing what I learned. For instance,

3 the Wealth Preservation training hosted by 1.1. Childers was used to set up my business structure

4 and strategy. I now have two LLC's and an LP that hold property, a financial LLC to fmance

5 property acquisitions, and a C Corporation.

6 10. As part of the Trump Entrepreneur Initiative programs, I was asked to fill out

7 evaluations. I never felt pressured to say something that was not true on the evaluations, and I

8 filled them out honestly. I felt they were administered fairly, with no bias. I prepared a Field

9 Mentor Evaluation Form after my 3-day field mentorship. I gave my field mentor an

10 EXCELLENT overall rating of5, the highest rating. From my Overall Experience question, I

11 stated, " ... it was great and better than expected. It was action packed and a lot of valuable time

12 was devoted to discussing what I needed to do to fill gaps in my knowledge and understanding.

13 Fast- paced, approaching mental overload!". And, I still agree with what I said to this day.

14 11. I did not meet or speak with Donald 1. Trump as part of my Trump Entrepreneur

15 Initiative experience, nor did he make any promises to me about the education I would receive.

16 In purchasing Trump Entrepreneur programs, I understood that I would not be working

17 personally with Donald 1. Trump.

18 12. My experience at Trump University has greatly helped me to advance

19 successfully in the world of real estate investing. I feel that if you study long and hard, will

20 devote yourself to understand and master the material, you will be successful. I never felt there

21 were ever any false promises or guarantees made by anyone at Trump. Students should know

22 when entering this field, that the real estate business is difficult, and they should expect to put in

23 a lot of self disciplined work. There is a lot to learn, so the learning process has been long, but I

24 have been able to do some amazing things, and seeing good success. It really works!

25 I declare under penalty of perjury under the laws of the United States of America that the

26 foregoing is true and correct.

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DECLARATIONOFPAUL CANUPDEx. 19, Page 108


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Executed on this 3rd day of June 2012,at Lafayette, Louisiana.c~ State

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4DECLARATION OF PAUL CANUP

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DEx. 20

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DECLARATION OF ROBERT MULACK

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Case No. 10 CV 0940 CAB (WVG) CLASS ACTION DECLARATION OF ROBERT MULACK DATE: February 12, 2013 TIME: 2:30 p.m. CTRM: 2 — 4

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DECLARATION OF SCOTT TALHELM

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Case No. 10 CV 0940 CAB (WVG) CLASS ACTION DECLARATION OF SCOTT TALHELM DATE: February 12, 2013 TIME: 2:30 p.m. CTRM: 2 — 4

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