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009589.0024\4648826.2 DECLARATION OF ROBERT C. DIVINE IN SUPPORT OF 

RECEIVER’S AND MONITOR’S ADMINISTRATIVE 

MOTION FOR ORDER AUTHORIZING EMPLOYMENT OF 

PROFESSIONALS 

3:17-CV-00223-RS

Wendel, Rosen, Black & Dean LLP 

1111 Broadway, 24t h Floor 

Oakland, California 94607-4036 

Elizabeth Berke-Dreyfuss (Bar No. 114651) 

WENDEL, ROSEN, BLACK & DEAN LLP 

1111 Broadway, 24th Floor 

Oakland, California 94607-4036 

Telephone: (510) 834-6600 

Fax: (510) 834-1928 

Email: edreyfuss@wendel.com 

Proposed Attorneys for Susan L. Uecker, 

Receiver and Monitor 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

SECURITIES AND EXCHANGE 

COMMISSION, 

Plaintiff, 

vs. 

SAN FRANCISCO REGIONAL CENTER, LLC; 

THOMAS M. HENDERSON; CALIFORNIA 

GOLD MEDAL, L.P.; CALL SOCKET, L.P.; 

CALL SOCKET II, L.P.; CALLSOCKET III, 

L.P.; COMPREHENSIVE CARE OF 

OAKLAND, L.P.; NA3PL, L.P.; WEST 

OAKLAND PLAZA, L.P.; CALLSOCKET, 

LLC; CALLSOCKET II, LLC; CALLSOCKET 

III, LLC; COMPREHENSIVE CARE OF 

CALIFORNIA, LLC; IMMEDIA, LLC; and 

NORTH AMERICA 3PL, LLC,

Defendants, 

-andCALLSOCKET HOLDING COMPANY, LLC; 

CALLSOCKET III HOLDING COMPANY, 

LLC; BERKELEY HEALTHCARE 

DYNAMICS, LLC; CENTRAL CALIFORNIA 

FARMS, LLC; and JL GATEWAY, LLC, 

Relief Defendants. 

 Case No. 3:17-CV-00223-RS 

DECLARATION OF ROBERT C. DIVINE 

IN SUPPORT OF RECEIVER’S AND 

MONITOR’S ADMINISTRATIVE 

MOTION FOR ORDER AUTHORIZING 

EMPLOYMENT OF PROFESSIONALS

I, Robert C. Divine, declare: 

Case 3:17-cv-00223-RS Document 103-3 Filed 04/06/17 Page 1 of 4
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009589.0024\4648826.2 DECLARATION OF ROBERT C. DIVINE IN SUPPORT OF 

RECEIVER’S AND MONITOR’S ADMINISTRATIVE MOTION 

FOR ORDER AUTHORIZING EMPLOYMENT OF 

PROFESSIONALS

2 3:17-CV-00223-RS

Wendel, Rosen, Black & Dean LLP 

1111 Broadway, 24t h Floor 

Oakland, California 94607-4036 

1. I am an attorney licensed to practice in the State of Tennessee, and a shareholder in 

the law firm of Baker Donelson (“Baker Donelson”). The following facts are true of my own 

personal knowledge, and if called upon to do so, I would and could competently testify thereto 

except as to those matters that are alleged upon information and belief and as to those matters, I 

believe them to be true. I make this declaration in support of Susan L. Uecker, Receiver’s and 

Monitor’s Motion for Order Authorizing Employment of Professionals. 

2. I have extensive experience serving clients throughout the world in the arrangement 

of all types of business-based temporary and permanent immigration status, including specialty 

occupations (H-1B, TN, E-3), individual and blanket international transferee programs (L-1), 

traders and investors (E-1/E-2, EB-5), medical workers, religious workers, labor certification, 

national interest waivers and extraordinary ability aliens. I have represented and assisted 

employers and other parties in some of the largest immigration enforcement investigations and 

prosecutions. I provide strategic advice and training for employers in their immigration 

compliance efforts. I also represent many business developers in creating, managing and using 

“Regional Centers” that can create indirect jobs toward the 10 new U.S. jobs whose creation can 

give rise to EB-5 permanent residence for investment in the developers’ projects. I am the elected 

Vice President of the national industry association of “EB-5” Regional Centers, Association to 

Invest in USA (IIUSA). I represent developers similarly using other parties’ Regional Centers. I 

coordinate this work with attorneys supporting securities law compliance in offerings to investors, 

with economists identifying “targeted employment areas” and projecting indirect job creation, 

with licensed securities brokers coordinating offerings, and with attorneys obtaining U.S. 

Government (OFAC) licenses to serve investors from restricted countries. I also represent 

individual investors in obtaining conditional permanent residence and in removing conditions 

from permanent residence. I am currently involved in a similar case in representing the receiver in 

the Securities and Exchange Commission v. Path America, LLC pending before the United States 

District Court for the Western District of Washington. 

3. By presidential appointment, I served in Washington, D.C., from July 2004, until 

November 2006, as Chief Counsel of United States Citizenship and Immigration Services 

Case 3:17-cv-00223-RS Document 103-3 Filed 04/06/17 Page 2 of 4
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009589.0024\4648826.2 DECLARATION OF ROBERT C. DIVINE IN SUPPORT OF 

RECEIVER’S AND MONITOR’S ADMINISTRATIVE MOTION 

FOR ORDER AUTHORIZING EMPLOYMENT OF 

PROFESSIONALS

3 3:17-CV-00223-RS

Wendel, Rosen, Black & Dean LLP 

1111 Broadway, 24t h Floor 

Oakland, California 94607-4036 

(USCIS), the world’s largest immigration services agency within the U.S. Department of 

Homeland Security. From July 2005, until July 2006, I served as Acting Deputy Director of 

USCIS, spearheading the USCIS Transformation Program, testifying in Congress about the EVerify system, enhancing operational security, and increasing transparency of rules and 

procedures. In early 2004 I served as an expert retained to assist the U.S. Commission on 

International Religious Freedom in its congressionally mandated study on the expedited removal 

process. I have testified as an expert on immigration law for courts in the United States and 

abroad. Since 1994, I have authored a well-known treatise on immigration law, Immigration 

Practice (Juris Publishing), now in its 15th edition. On January 7, 2011, I testified before the 

Senate Judiciary Committee regarding the job-creating effects of the EB-5 immigrant investor 

program and the importance of renewing the regional center authorizing legislation. 

4. My hourly rates and the hourly rates of the Baker Donelson attorneys who will 

assist me and the hourly rates are: 

Attorney Practice Hourly Rate 

Robert C. Divine 

Partner 

Immigration $585 

Melanie Walker 

Associate 

Immigration $315 

Kathleen Harrison 

Associate 

Immigration $280 

5. Baker Donelson also employs paralegals with hourly rates of $200. Baker 

Donelson’s charges its costs as actual costs. Baker Donelson will seek compensation in 

compliance with the terms of the Appointment Order and agrees to bill its fees and costs in this 

case in accordance with the Billing Instructions for Receivers in Civil Actions Commenced by the 

U.S. Securities and Exchange Commission, and upon application and approval by the Court. 

6. I have performed a conflict check and have no conflicts in this matter. Neither I 

nor Baker Donelson are attorneys for or associated with or employed by any party to this action, 

except that I have worked with the Worldway migration agency, one of the agencies that placed 

investors with the CallSocket EB-5 Projects, on other immigration matters that are unrelated to 

Case 3:17-cv-00223-RS Document 103-3 Filed 04/06/17 Page 3 of 4
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009589.0024\4648826.2 DECLARATION OF ROBERT C. DIVINE IN SUPPORT OF 

RECEIVER’S AND MONITOR’S ADMINISTRATIVE MOTION 

FOR ORDER AUTHORIZING EMPLOYMENT OF 

PROFESSIONALS

4 3:17-CV-00223-RS

Wendel, Rosen, Black & Dean LLP 

1111 Broadway, 24t h Floor 

Oakland, California 94607-4036 

this action. In addition, I also represented the Receiver as the receiver’s immigration counsel in 

the State Court Action. 

I declare under penalty of perjury that the foregoing is true and correct and that this 

declaration was executed under the laws of the State of Tennessee on April 3, 2017. 

/s/ Robert C. Divine 

 Robert C. Divine 

Case 3:17-cv-00223-RS Document 103-3 Filed 04/06/17 Page 4 of 4