EXHIBIT G

Case: 1:12-cv-00163 Document #: 1-13 Filed: 01/10/12 Page 1 of 4 PageID #:73
UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS - EASTERN DIVISION

v. DECLARATION OF TRACY COENEN IN

SUPPORT OF NOTICE OF REMOVAL

Case No.

-------------------------

MARCUS EVANS, INCORPORATED,

Plaintiff,

TRACY COENEN and SEQUENCE INC.,

Defendants.

DECLARATION OF TRACY COENEN IN SUPPORT OF NOTICE OF REMOVAL

I, TRACY COENEN, having personal knowledge of the matters set forth herein, state as

follows:

1. I am, individually, one of the defendants in this action, and the sole shareholder in

the corporate defendant in this action, Sequence Inc. ("Sequence").

2. I am and have been the sole shareholder in Sequence since the incorporation of

Tracy L. Coenen, S.C. in 2000, which I renamed to Sequence Inc. in 2003. A true and correct

copy of the Articles oflncorporation for Tracy L. Coenen, S.C., and a true and correct copy of

the Wisconsin Department of Financial Institution's online business records search as it appeared

on January 6, 2011 - noting the renaming of Tracy L. Coenen, S.C. to Sequence Inc. - are

collectively attached hereto as Exhibit A.

3. Sequence is incorporated in the state of Wisconsin, with its principal place of

business at 111 East Wisconsin Avenue, Suite 1230, Milwaukee, Wisconsin 53202. A true and

correct copy of a certificate of good standing issued by the Wisconsin Department of Financial

Institutions, which maintains the records of all companies doing business in Wisconsin, for

Sequence, is attached hereto as Exhibit B.

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4. Sequence is only organized under the laws of Wisconsin; it is not organized under

the laws of Illinois. A true and correct copy of results from a search of the Illinois Secretary of

State database for businesses named "Sequence" is attached hereto as Exhibit C, and shows that

Sequence Inc. is not organized in Illinois.

5. All of the invoices Sequence must regularly pay, including those for telephone

use, internet access, electricity, other utilities, and professional services from others, are

transmitted to Sequence's 111 East Wisconsin Avenue address.

6. I perform substantially all of Sequence's corporate and business activity at the

company's 111 East Wisconsin Avenue headquarters.

7. Moreover, all earnings of Sequence are Wisconsin earnings and reported

appropriately to the Wisconsin taxing authorities. Sequence has only Wisconsin employees and

pays Wisconsin wages, and reports and pays all state payroll taxes to Wisconsin.

8. Personally, I am and have continuously been a citizen of the state of Wisconsin

for my entire life. I have never been a citizen of any other state.

9. My residence is in the state of Wisconsin, all of my earnings are from Wisconsin,

and I pay property and income taxes to the state of Wisconsin - not Illinois.

10. All of my utility bills, insurance policy invoices, correspondence concerning my

professional licenses, and other notices are sent exclusively to my Wisconsin office.

11. I am registered to vote in the state of Wisconsin, rather than Illinois.

12. Furthermore, I possess a Wisconsin Driver's License, a true and correct, partially

redacted copy of which is attached hereto as Exhibit D.

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Dee\. of Traey Coenen in Support ofNotiee of Removal

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13. My automobile is registered exclusively in the state of Wisconsin, and bears

Wisconsin-issued license plates. A true and correct, partially redacted copy of my current

automobile registration is attached hereto as Exhibit E.

14. I am not aware of the existence of any facts that would make Sequence or myself

citizens of Illinois, for the purposes of Marcus Evans Incorporated's lawsuit or otherwise.

15. A true and correct copy ofthe Complaint and all documents or other process

served upon me is attached hereto as Exhibit F.

I declare under penalty of perjury that the foregoing is true and correct to the best of my

knowledge.

Dated this 6th day of January, 2012 in Milwaukee, Wisconsin.

~a------.........

Tracy Coenen

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Dee!. of Traey Coenen in Support ofNotiee of Removal

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