MICHAEL J. KURGAN

6538 Collins Avenue

Unit 288

Miami Beach, FL 33141

Phone (858) 480-9330

E-Mail n46 lbb@gmail.com

Defendant Pro Se

IN THE UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

THE LANCE AND LINDA NEIBAUER

JOINT TRUST, by and through LANCE

NEIBAUER, as trustee, Case No. 6:14-cv-01192-MC

Plaintiff DEFENDANTS RESPONSE TO

PLAINTIFF'S FIRST JUDGMENT

DEBTOR INTERROGATORIES TO

DEFENDANT

vs.

MICHAEL J. KURGAN, an individual,

Defendant.

To: Plaintiff and its attorney ofrecord:

Pursuant to Rules 26, 69(a)(2) and 33 ofthe Federal Rules ofCivil Procedure ("FRCP"),

Defendant hereby responds to the PlaintiffThe Lance and Linda Neibauer Joint Trust, by and

through Lance Neibauer, as trustee ("Plaintiff'), interrogatories propounded to Defendant Michael

J. Kurgan ("Defendant").

PAGE 1 - DEFENDANTS RESPONSE TO PLAINTIFF'S FIRST SET OF

INTERROGATORIES TO DEFENDANT

Exhibit

Exhibit I - Page 1 of 8

I - Page 1 of 23

Case 6:14-cv-01192-MC Document 94-9 Filed 11/20/17 Page 1 of 8
INTERROGATORIES TO JUDGMENT DEBTOR. MICHAEL KURGAN

INTERROGATORY NO. 1: State your full name, your Social Security number, your current

residential address and your residential telephone number.

RESPONSE NO. 1:

Defendant objects to the Interrogatory to the extent that it requests the Defendant's Social

Security Number as that is confidential information that is not likely to aid in the enforcement of

the judgment. Without waiving the objection:

MICHAEL J. KURGAN

134 Rutland Blvd

West Palm Beach, FL 33405

Phone NA

INTERROGATORY NO, 2; State your spouse or partner's name and residence address.

RESPONSE NO. 2:

Elisabeth Gonzalez

134 Rutland Blvd

West Palm Beach, FL 33405

INTERROGATORY NO. 3: State and describe your occupation. When describing your

occupation, include at least the following information:

a. Job title;

b. Employment commencement date;

c. Job responsibilities;

d. Current salary.

RESPONSE NO. 3:

a. Job title; ChiefExecutive Officer

b. Employment commencement date; 12/1/2008

c. Job responsibilities; CEO

d. Current salary. I do not receive any salary.

PAGE 2 - DEFENDANTS RESPONSE TO PLAINTIFF'S FIRST SET OF

INTERROGATORIES TO DEFENDANT

Exhibit

Exhibit I - Page 2 of 8 I - Page 2 of 23

Case 6:14-cv-01192-MC Document 94-9 Filed 11/20/17 Page 2 of 8
INTERROGATORY NO. 4: State the name, address and telephone number for each company

or person who has employed you, or contracted for your services, since July 1, 2012.

RESPONSE NO. 4:

As chief Executive Officer and COO, I have not been employed or had my services

contracted for since July 1, 2012 other than as an officer of Service Wing and

Matseco, Inc. Both located at 8565 S. Eastern Ave., Suite 150, Las Vegas, NY 89123

Service Wing Phone number 858.461.5200 Matseco 702.861.0100

INTERROGATORY NO. 5: Ifyou have been self-employed at any time since July 1, 2012,

list, in chronological order, the name and location ofthe business and the nature ofthe work.

RESPONSE NO. 5:

Not Applicable.

INTERROGATORY NO. 6: List all sources of funds, including the amount ofthe funds,

received by you for the past two (2) years and indicate whether you receive such funds on a

regular basis. Sources of funds include, but are not limited to gifts, bequests, alimony, support or

property settlement payments, cash prizes, gaming winnings, judgments, settlements, monies in

trust, interest income, proceeds from the sale of collectibles, loans, or lines of credit. (Attach

additional sheets ifnecessary).

RESPONSE NO. 6:

None as I understand the definition of you.

INTERROGATORY NO. 9: List all business interests in which you are a sole proprietor, a

partner, or a joint venturer. For each interest, list the following:

a. Name and address ofthe business.

b. Name(s) and address(es) ofthe partners or joint venturers.

Nature ofthe business, partnership or joint venture,

d. Net value of your interest in the business.

c.

PAGE 3 - DEFENDANTS RESPONSE TO PLAINTIFF'S FIRST SET OF

INTERROGATORIES TO DEFENDANT

Exhibit

Exhibit I - Page 3 of 8 I - Page 3 of 23

Case 6:14-cv-01192-MC Document 94-9 Filed 11/20/17 Page 3 of 8
(Attach additional sheets ifnecessary)

RESPONSE NO. 9:

I am not a sole proprietor, a partner, or a joint venture of any business.

INTERROGATORY NO. 10: List all corporations in which you are either a shareholder,

director or officer (or combination thereof). For each corporation, list the following:

a. Name and address ofthe business.

b. Nature ofthe business.

c. Number of corporate shares outstanding.

d. Number of corporate shares held by you.

e. Net value of corporate assets.

f. Value of your interest in the corporation.

g. Your position, if you are an officer or director ofthe corporation.

h. Your compensation, if you are an officer, director, or employee ofthe corporation.

i. Location of share certificate.

(Attach additional sheets ifnecessary).

RESPONSE NO. 10:

a. Name and address ofthe business. Service wing Healthcare, Service Wing Solutions,

Precision Approach, Matseco.

b. Nature ofthe business. Early-stage Company that develops and markets technology

tools. Matseco develops commercial water treatment.

c. Number of corporate shares outstanding. 20,000,000,/ 20,000.00/ 10,000,000,

10,000,000

d. Number of corporate shares held by you.0

e. Net value of corporate assets. NA, NA, NA, NA

f. Value of your interest in the corporation. 0

PAGE 4 -DEFENDANTS RESPONSE TO PLAINTIFF'S FIRST SET OF

INTERROGATORIES TO DEFENDANT

Exhibit

Exhibit I - Page 4 of 8

I - Page 4 of 23

Case 6:14-cv-01192-MC Document 94-9 Filed 11/20/17 Page 4 of 8
g. Your position, ifyou are an officer or director ofthe corporation. CEO, CEO, CEO,

COO

h. Your compensation, if you are an officer, director, or employee ofthe corporation.

None.

i. All 8565 S. Eastern Ave., Suite 150, Las Vegas NV 89123

INTERROGATORY NO. 11; List all limited liability companies in which you are a member,

manager or officer (or combination thereof). For each LLC, list the following:

a. Name and address ofthe business.

b. Nature ofthe business.

c. Number ofmember interests outstanding.

d. Percentage ofprofits and losses to which you are entitled.

e. Net value of corporate assets.

f. Value of your interest in the limited liability company.

g. Your position, if you are an officer or manager ofthe limited liability company.

h. Your compensation, ifyou are an officer, manager, or employee ofthe limited liability

company.

(Attach additional sheets ifnecessary).

RESPONSE NO. 11:

NONE, and therefore NOT APPLICABLE

INTERROGATORY NO. 12: List all real property which you own, rent or are buying or have

owned in the past 2 years. For each property, include the following information:

a. Address ofthe property.

b. Type ofproperty (home, lot, apartment, etc.).

c. Whether you own the property, are renting the property, or are buying the property on a

contract.

PAGE 5 - DEFENDANTS RESPONSE TO PLAINTIFF'S FIRST SET OF

INTERROGATORIES TO DEFENDANT

Exhibit

Exhibit I - Page 5 of 8

I - Page 5 of 23

Case 6:14-cv-01192-MC Document 94-9 Filed 11/20/17 Page 5 of 8
I DECLARE UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND

CORRECT AND THIS WAS EXECUTED ON THE DATE SET FORTH BELOW.

DATED: July 19, 2017.

. ^

- . MICHAEL J. KURGAN

6538 Collins Avenue

Unit 288

Miami Beach, FL 33141

Phone (858) 480-9330

E-Mail n461bb@gmail.com

Defendant Pro Se

PAGE 21 - DEFENDANTS RESPONSE TO PLAINTIFF'S FIRST SET OF

INTERROGATORIES TO DEFENDANT

Exhibit

Exhibit I - Page 6 of 8

I - Page 21 of 23

Case 6:14-cv-01192-MC Document 94-9 Filed 11/20/17 Page 6 of 8
CERTIFICATE OF SERVICE

I hereby certify that on July 19, 2017, 1 served the foregoing DEFENDANT'S

RESPONSE TO PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT on the

following:

Nicholas J. Henderson, OSB No. 074027

Email: nhenderson@portlaw.com

Motschenbacher & Blattner, LLP

117 SW Taylor Street, Suite 200

Portland, Oregon 97204-3029

Telephone: (503) 417-0508

Facsimile: (503)417-0501

[X] Via First Class Mail

[ ] Via Facsimile

[ ] Via Hand Delivery

[ ] Via ECF Notification

[ ] Via Electronic Mail to:

DATED: July 19,2017.

-u'

MICHAEL J^KERGAN

6538 CoJKfisAvenue

Unit 288

Miami Beach, FL 33141

Phone (858) 480-9330

E-Mail n46 1 bb@gmail.com

Defendant Pro Se

Exhibit

Exhibit I - Page 7 of 8

I - Page 22 of 23

Case 6:14-cv-01192-MC Document 94-9 Filed 11/20/17 Page 7 of 8
CERTIFICATE OF SERVICE

I hereby certify that on August 31, 2017, 1 re-served the foregoing DEFENDANT'S

RESPONSE TO PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT on the

following:

Nicholas J. Henderson, OSB No. 074027

Email: nhenderson@portlaw.com

Motschenbacher & Blattner, LLP

1 17 SW Taylor Street, Suite 200

Portland, Oregon 97204-3029

Telephone: (503)417-0508

Facsimile: (503)417-0501

[X] Via Priority Mail Trackable

[ ] Via Facsimile

[ ] Via Hand Delivery

[ ] Via ECF Notification

[ ] Via Electronic Mail to:

DATED: July 19,:

MIOgA^U

6J3^ColUns Avenue

Unit 288

Miami Beach, FL 33141

Phone (858) 480-9330

E-Mail n46 1 bb@gmail.com

J. KURGAN

Defendant Pro Se

Exhibit Exhibit I - Page 8 of 8 I - Page 23 of 23

Case 6:14-cv-01192-MC Document 94-9 Filed 11/20/17 Page 8 of 8