Case 2:19-cv-02306-MWF-AFM Document 37-1 Filed 08/05/19 Page 1 of 3 Page ID #:319

1 Jeffrey J. Pyle (pro hac vice pending)

Aaron S. Jacobs (Cal. Bar No. 214953)
PRINCE LOBEL TYE LLP
3 One International Place, Suite 3700
Boston, MA 02110
4
tel. (617) 456-8000
5 fax (617) 456-8100
2

6

Matthew Vella (Cal. Bar No. 314548)

7 PRINCE LOBEL TYE LLP
8 357 S Coast Highway, Suite 200

Laguna Beach, CA 92651

9 tel. (949) 232-6375
10 fax (949) 861-9133
11
12 Attorneys for Defendant Matthew J. Weymouth
13
14

UNITED STATES DISTRICT COURT

15

CENTRAL DISTRICT OF CALIFORNIA

16

WESTERN DIVISION

17

MATTHEW HOGAN,

18

Plaintiff,

19

v.

20

MATTHEW J. WEYMOUTH,
PATRICK C. CHUNG,
PRO SPORTORITY (ISRAEL) LTD.,
KARL RASMUSSEN,
BEASLEY BROADCAST GROUP
INC., MELISSA EANNUZZO, and
DOES 1-10,

21
22
23

No. 2:19-cv-02306-MWF-AFMx

24

DECLARATION OF MATTHEW
WEYMOUTH IN SUPPORT OF
MOTION TO DISMISS

Date:
Time:
Location:
Judge:

September 9, 2019
10:00 a.m.
Courtroom 5A
Michael W. Fitzgerald

Defendants.

25
26
27
28

1
3250381.v1

Case No. 2:19-cv-02306-MWF-AFMx

 Case 2:19-cv-02306-MWF-AFM Document 37-1 Filed 08/05/19 Page 2 of 3 Page ID #:320

DECLARATION OF MATTHEW WEYMOUTH

1
2

I, Matthew Weymouth, declare:

3

1.

I am over the age of 18. The matters stated in this declaration are true

4 of my own personal knowledge. If called as a witness, I could and would
5 competently testify to these matters.
6

2.

I am a resident of Mansfield, Massachusetts. I am thirty-three (33)

7 years old, and have lived in Massachusetts for my entire life, with the exception of
8 when my family lived in Maine for a period of time when I was very young.
9

3.

I attended Johnson & Wales University in Rhode Island between

10 approximately 2007 and 2011. During college, I met Matthew Hogan through a
11 mutual friend while both of us were at a social gathering at the University of
12 Massachusetts’ Amherst Campus. After college, we did not stay in close touch
13 although we very occasionally had contact with each other through social media.
14

4.

I have traveled to California only one time in my life, in 2012, for a trip

15 lasting approximately three days. I do not own any assets in California, and do not
16 conduct business in California.
17

5.

I have known Patrick Chung socially since approximately May of 2009.

18 Chung and I are friends. Chung lives in Massachusetts.
19

6.

On or about February 3, 2019 Hogan sent me text messages during

20 Super Bowl LIII that I deemed inappropriate and threatening. At the time I received
21 the messages and responded, I was in Atlanta, Georgia. I later provided screenshots
22 of the messages to Chung. At the time I provided these screenshots to Chung, both
23 Chung and I were home in Massachusetts. I did not make any misrepresentation to
24 Chung concerning the circumstances of the text messages.
25

7.

I did not compose, edit, or post the Instagram and Facebook posts dated

26 February 6, 2019 that are at issue in Hogan’s complaint. I have never posted content
27
28

2
3250381.v1

Case No. 2:19-cv-02306-MWF-AFMx

 Case 2:19-cv-02306-MWF-AFM Document 37-1 Filed 08/05/19 Page 3 of 3 Page ID #:321

I

to any social media account belonging ts Patrick Chung. I have never managed any

2

of Chung's social media accounts.

3

.t

I declare under penalty of perjury under the laws of the United States

of

5

America that the foregoing is true and correct, and that this declaration was executed

6

on

this54

Cay of August, 2019, in Mansfield, Massachusetts.

7

I
9

Matthew Weynrouth

t0

n
t2

l3
t4

l5
l6

l7
l8
l9
2A

2l
72
23

21
35

26
27
38
3
l23O3Sl.r I

Carc No.

I;lc+r'02306'M$f .AFIlx