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Diby Ako v. Arriva Best Security, Inc., et al.

U.S.D.C. (N.D. Tex.) Case No. 3:22-cv-1751

Declaration of Attorney Sean Short

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

DIBY AKO PLAINTIFF

vs. No. 3:22-cv-1751

ARRIVA BEST SECURITY, INC., DEFENDANTS

and AMOIFO KOFFI

 

DECLARATION OF ATTORNEY SEAN SHORT

Attorney Sean Short hereby states on oath as follows:

1. I am over the age of 18 and legally qualified to execute this Declaration.

2. I am an attorney licensed and in good standing in the State of Arkansas, as 

well as numerous United States District Courts. I practice law with the law firm of Sanford 

Law Firm, PLLC.

3. I am familiar with the facts of Plaintiff Diby Ako’s lawsuit against Defendants 

Arriva Best Security, Inc., and Amoifo Koffi, and I have assisted the attorney of record in 

this case with various aspects of the litigation since its inception.

4. As of April 12, 2024, I know of no instances where either Defendant, or one 

of their representatives, has attempted to contact myself or Sanford Law Firm, PLLC.

5. On April 9, 2024, I used the TLOxp service to perform a skip trace for 

individuals named Amoifo Koffi which produced one result and provided me with a date 

of birth for that individual.

6. On April 9, 2024, I personally submitted a record request for Defendant 

Amoifo Koffi on the Servicemembers Civil Relief Act (“SCRA”) Website, 

Case 3:22-cv-01751-S Document 35-2 Filed 04/12/24 Page 1 of 3 PageID 173
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Diby Ako v. Arriva Best Security, Inc., et al.

U.S.D.C. (N.D. Tex.) Case No. 3:22-cv-1751

Declaration of Attorney Sean Short

https://scra.dmdc.osd.mil/scra/#/single-record, using the date of birth I received from the 

skip trace I performed and the Status Report that I received in response to my request 

from the Department of Defense Manpower Data Center confirmed that Defendant Amoifo 

Koffi is not an active duty servicemember of any branch of the United States Uniformed 

Services. A true and correct copy of the Status Report is attached hereto as Exhibit A.

Pursuant to 28 U.S.C. § 1746, I verify under penalty of perjury under the laws 

of the United States of America that the foregoing is true and correct.

Dated: April 10, 2024

/s/ Sean Short______

Sean Short

Case 3:22-cv-01751-S Document 35-2 Filed 04/12/24 Page 2 of 3 PageID 174
SSN:

Birth Date:

Last Name:

First Name:

Middle Name:

Status As Of:

Certificate ID:

Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of

the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, Space Force, NOAA, Public

Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.

HOWEVER, WITHOUT A SOCIAL SECURITY NUMBER, THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY

ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO. NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY

IDENTIFY AN INDIVIDUAL.

Sam Yousefzadeh, Director

Department of Defense - Manpower Data Center

4800 Mark Center Drive, Suite 04E25

Alexandria, VA 22350

Department of Defense Manpower Data Center Results as of : 

SCRA

On Active Duty On Active Duty Status Date

Active Duty Start Date Active Duty End Date Status Service Component

This response reflects the individuals' active duty status based on the Active Duty Status Date

Left Active Duty Within 367 Days of Active Duty Status Date

Active Duty Start Date Active Duty End Date Status Service Component

This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date

The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date

Order Notification Start Date Order Notification End Date Status Service Component

This response reflects whether the individual or his/her unit has received early notification to report for active duty

Jan-XX-1963

KOFFI

AMOIFO

Apr-09-2024

GVFMQVBQW0696Q8

Apr-09-2024 12:20:10 PM

5.19

NA NA No NA

NA NA No NA

NA NA No NA

Ex. 02-A

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