Free Reply in Support of Motion - District Court of Arizona - Arizona

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Exhibit A
SUPPLEMENTAL AFFIDAVIT OF KATHY MCCLOUD STATE OF ARIZONA County of YUMA } }ss. }

I, KATHY M CCLOU D, swear under oath as follows: 7 8 9 10 11 12 13 14 15 16 17 18 19 4. 20 21 22 23 24 25 26 27 28 included, as allowed by generally accepted accounting principles. 6. As of October 2003, Cha Cha, L.L.C., held the Velda Ranch and the 14th Street principles and reflects Cha Cha, LLC's true and accurate net worth. 5. According to generally accepted accounting principles, assets are valued Accumulated depreciation of assets has also been The Balance Sheet was prepared according to generally accepted accounting 3. I have prepared the Balance Sheet for Cha Cha, L.L.C., as of October 2003, Supplemental Affidavit are based upon my personal knowledge and I believe I would be competent to testify to these matters if called as a witness at any hearing. 2. I am the Comptroller for Cha Cha, L.L.C. 1. This Supplemental Affidavit is submitted in support of Cha Cha, L.L.C., an

Arizona Limited Liabili ty Company, for its Application for Fees and Expenses Under the Equal Access to Justice Act (28 U.S.C. § 2412 ). The statem ents contain ed in this

the date of filing of this condemnation proceeding. A copy of the Balance Sheet is attached hereto.

according to their a cquisitio n cost.

Ranch as assets. These properties w ere the subject properties in this condemnation

Case 2:03-cv-02006-SRB

Document 178-2

Filed 03/20/2007

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proceeding. On the attached Balance Sheet these properties are valued at their acquisition cost and not at the fair market value awarded by the jury in this case in August 2006. 7. As of October 16, 2003, the net worth of Cha Cha, L.L.C. did not exceed

$7,000,000.00. DAT ED: 3/20/07 .

/s/ Kathy McCloud Kathy McCloud

Case 2:03-cv-02006-SRB

Document 178-2

Filed 03/20/2007

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