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DECLARATION OF SHAWN MOGHADAM

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J. ROBERT MULLEN
ATTORNEY AT LAW
23151 Moulton Parkway
Laguna Hills, California 92653
Telephone: (949) 588-1198
Facsimile: (949) 588-6258







UNITED STATES BANKRUPTCY COURT
CENTRAL DISTRICT OF CALIFORNIA
SANTA ANA DIVISION



In re:

FARDIS REZVANI,

Debtor.
____________________________________

ALLEN BARADAR,


Plaintiff,


vs.

FARDIS REZVANI,

Defendant.
Case No.: 8:11-bk-13084-RK

Chapter 7

Adversary No.: 8:11-ap-21268-RK

DECLARATION OF SHAWN
MOGHADAM

Date: September 6, 2012
Time: 10:00 a.m.
Courtroom: 5D





I, Shawn Moghadam, declare:
1. I graduated from the Pasadena School of Design in 2006.
2. Ive worked as an automotive designer for over 7 years.
3. Over the last 5 years, Ive spent approximately 40 hours a week doing 3D design work
at General Motors Advance Design Facility. Im not actually employed by General Motors. My
employer is a staffing agency who pays me and takes tax withholdings from my pay checks. Im
J. Robert Mullen (California State Bar No. 137271)
Attorney at Law
23151 Moulton Parkway
Laguna Hills, CA 92653
Telephone: (949) 588-1198
Facsimile: (949) 588-6258
bobmullen@cox.net

Attorney for Plaintiff Allen Baradar


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DECLARATION OF SHAWN MOGHADAM

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J. ROBERT MULLEN
ATTORNEY AT LAW
23151 Moulton Parkway
Laguna Hills, California 92653
Telephone: (949) 588-1198
Facsimile: (949) 588-6258
free to do work on the side.
4. A co-worker at the General Motors design studio introduced me to Fardis Rezvani.
5. At the time of this introduction, Rezvani asked if I would be interested in doing design
work on a sports car that he claimed to have built from the ground up. This was around the
summer of 2009. I agreed to do 10 hours of work for him at a discounted rate of $50 per hour.
6. I performed the design work and was paid for my work.
7. After performing this initial work, Rezvani said he was interested in my doing more
work and we agreed to meet in person to discuss the possibility of my doing more work for him.
We met in Irvine at a supermarket which was my first face-to-face meeting with Rezvani and it
took place in around October 2009.
8. It was either at a continuation of the supermarket meeting or at a subsequent meeting in
Irvine at Rezvanis home that I saw for the first time in person the actual car that I was doing body
design work on. The car was parked in Rezvanis driveway and it had a chassis, suspension,
steering, wheels, tires, engine and an unfinished body. Rezvani told me that the entire car was his
original creation and I was impressed such that I complimented him a number of times for his
work. At no point did Rezvani tell me that he was using a kit car as a platform to build the car.
9. Sometime after the first time I saw the car, Rezvani told me that a company named
Auto Centre had offered $2 million to buy his company and he provide me with a Letter of Intent
involving this acquisition, a copy of which is Plaintiffs Exhibit 7. By this point, Rezvani had told
me that he had started a company to market and sell the sports car that I was doing the design
work on.
10. Rezvani also provided me with a copy of an Offering Memorandum for Vollara Cars,
LLC, a copy of which is Plaintiffs Exhibit 4. By this point, Rezvani had told me that the cars that
his company planned to market and sell would be called Vollaras.
11. When Rezvani told me about his company, he also told me that he put over $250,000
of his own money into creating the Vollara sports car.
12. On November 23, 2009, Rezvani and I exchanged emails concerning my acquisition of
an ownership in Rezvanis sports car company in exchange for my services. I was concerned

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DECLARATION OF SHAWN MOGHADAM

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J. ROBERT MULLEN
ATTORNEY AT LAW
23151 Moulton Parkway
Laguna Hills, California 92653
Telephone: (949) 588-1198
Facsimile: (949) 588-6258
about design rights and Rezvani emailed that the design rights of the car has to stay in the LLC.
Rezvani offered a 5% ownership and said: Remember a 5% ownership translates to a $50K
initial investment. A copy of this email exchange is Plaintiffs Exhibit 5.
13. Rezvani and I later agreed to my owning 9% and I signed an agreement with Rezvani
Holdings, LLC DBA Volarra. A copy of the signed agreement dated December 11, 2009 is
Plaintiffs Exhibit 8.
14. One of the main reasons I signed the agreement with Rezvani Holdings, LLC DBA
Volarra was because Rezvani had told me that he had built the car from the ground up and had
thus far spent $250,000 of his own money in research and development on the car. The Offering
Memorandum said $350,000 had been spent in total. Rezvani had also told me that the company
was worth $500,000.
15. After I signed the agreement and did more design work, the Vollara car that I had seen
at Rezvanis house was taken to a company named n2a Motors in Corona so that the design
modifications I had made could incorporated into the body of the car.
16. During one of my visits to the n2A Motors shop to inspect the work being done on the
Vollara, Rezvani and I met the in-house designer who briefly mentioned that he had seen the
Vollara before and that it was produced by a man named Diego from the Dominican Republic.
Rezvani was part of this conversation and was with me when the in-house designer made this
comment but Rezvani did not say anything in reply although I had no reason to believe that
Rezvani did not hear what the in-house designer had said. At the time, all three of us were
standing within a few feet of each other while we were looking at the Vollara car. I guessed that
the in-house designer was mistaken, especially since immediately after the in-house designer made
the comment, Rezvani gave me a look that I interpreted as meaning that the in-house designer did
not know what he was talking about.
17. Later, on February 1, 2010, I decided to Google "Dominican Republic kit car" on my
smart phone and discovered the DDR SP4 vehicle which is the same car that Rezvani had claimed
to have engineered and built from the ground up. In reviewing the DDR website, I learned that the
car that Rezvani had claimed to have designed and built from the ground up was in actuality a kit

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DECLARATION OF SHAWN MOGHADAM

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J. ROBERT MULLEN
ATTORNEY AT LAW
23151 Moulton Parkway
Laguna Hills, California 92653
Telephone: (949) 588-1198
Facsimile: (949) 588-6258
car obtainable out of Florida for a retail price of under $20,000. The DDR web site had
photographs of the DDR car from all sorts of angles and there is no doubt that I was doing design
work on a DDR car.
18. I even found a photo on the DDR website of a DDR car that had the same body
damage as the car Rezvani had obtained and for which I was doing design work. I created
Plaintiffs Exhibit 12 following this discovery. The bottom left hand corner of Exhibit 12 contains
a screen shot from DDRs website which shows a DDR kit car on a trailer and the kit car has a
scuff on the passenger side right fender. On the upper left of Plaintiffs Exhibit 12 is a photograph
that Rezvani had sent to me of the Vollara car when I first started doing design work on the car
and that photo shows the same scuff mark that appears on the DDR kit car on the trailer.
19. After making this discovery, I informed Allen Baradar of my discovery and we
decided to request a meeting with Rezvani to discuss the truth about the origin of the Vollara car.
20. A meeting was arranged for February 6, 2010 but I did not tell Rezvani why Baradar
and I wanted the meeting. In fact, I stopped returning Rezvanis calls pending the meeting.
21. On February 6, 2010, Baradar and I met Rezvani at a restaurant in Los Angeles
County.
22. Baradar and I had arranged to meet at a nearby hotel immediately before the restaurant
meeting so that the two of us could go the restaurant together to meet Rezvani. Baradar and I met
at the hotel and proceeded to the restaurant where we met Rezvani.
23. After exchanging some initial pleasantries and ordering tea at the restaurant, I asked
Rezvani in a few different ways about the origin of the Vollara car without directly confronting
him with my discovery that the Vollara was really a DDR kit car. I wanted to see how much
Rezvani would tell us about the origin of the car without directly confronting him. When it
became clear that Rezvani was being evasive in his responses and that indirect questions were not
going to get to the truth, I mentioned DDR and Rezvani became defensive and he would neither
admit nor deny that the car was a DDR kit car. He was, however, adamant that it did not matter
where the car had come from and that the business venture he had founded would be successful
regardless of the origin of the car. Baradar and I meanwhile disputed Rezvani on this point and

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DECLARATION OF SHAWN MOGHADAM

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J. ROBERT MULLEN
ATTORNEY AT LAW
23151 Moulton Parkway
Laguna Hills, California 92653
Telephone: (949) 588-1198
Facsimile: (949) 588-6258
said that the one of strong appeals of the business venture was the claim that the Vollara was an
original creation from the ground up and not something that could be easily purchased from a kit
car company like DDR. At no point during the meeting did Rezvani restate his claim that he had
spent $250,000 of his own money in research and development. The tone of the meeting
deteriorated to the point where Rezvani unilaterally declared that his business relationship with me
and Baradar was terminated and he walked out of the meeting. Baradar followed Rezvani out of
the restaurant the first time this happened and got Rezvani to return to the meeting but Rezvani
again left the meeting declaring that his business relationship with me and Baradar was over.
24. Between signing the agreement dated December 11, 2009 (Plaintiffs Exhibit 8) and
my discovery on February 1, 2010 that the Vollara was really a DDR kit car, I put in many hours
of design work and produced over 50 pages of design work. I provided these services pursuant to
the December 11, 2009 agreement. After the restaurant meeting I did not put in any more work
towards the Vollara business venture and I have received nothing in return for my investment of
time into the company.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.

Dated: September 5, 2012 ________________________________
Shawn Moghadam