DECLARATION OF REZ KHAN
I, REZ KHAN, declare:
1. I am a citizen of the United States who resides in the State of California. I am a friend and business associate of Respondent Hopeton Brown’s. I have known Hopeton Brown for approximately 10 years. Except as to those matters stated on information and belief, I have personal knowledge of the facts set forth below and could and would testify competently thereto if asked to do so.
2. I am the owner of Seedless Clothing and promote special events. I have a degree in Psychology and International Security & Conflict Resolution.
3. Hopeton Brown is known professionally as “The Scientist” and is considered a living legend in the Reggae field of music. I was present for the Sister Carol performance at the Belly Up Tavern on April 20, 2009. I promoted this event. Hopeton Brown was the sound engineer and Amara Wilson was his guest for the evening. Sister Carol is one of Jamaica’s top entertainers. The Belly Up Tavern is a club in Solana Beach, California where live acts perform. Rolling Stone Magazine regards the Belly Up Tavern as a very important venue for live music and entertainment.
4. I met Amara Wilson that evening and she seemed pleasant. Everything seemed fine between Amara Wilson and Hopeton Brown. Amara Wilson reminded me of a groupie. She was excited to be part of the crew and backstage. I am becoming very frustrated with these types of women. I have heard the allegations about Hopeton Brown, a so-called “soft kidnapping” with respect to Amara Wilson, and know they are nothing other than malicious lies and slander. When I promote an event, I keep a close eye on everything. I am exposed to liability. If I see a gang member fly a sign, which is not permitted, I ask security to deal with the situation. When I see a drunk girl or woman, I put her in a cab. This event was a party. There was not a human being present who did not to be there. Amara Wilson was free to do whatever she wanted over the course of the evening. She was not there against her will. Hopeton Brown was working, engineering the show, and incredibly busy. At any moment, throughout the evening, she was free to leave of her own accord.
5. In the 10 or so years I have known Hopeton Brown, he has always conducted himself professionally. I have never seen him behave in a rude, abusive, or aggressive manner. That type
behavior is not part of his personality. He is the consummate professional and a gentleman.
I declare under penalty of perjury that the foregoing is true and correct.
Executed this 21 of April 2011 at Los Angeles, California.
____________________________________
REZ KHAN
Signed