Case 2:23-cv-07593-HDV-KS Document 85-1 Filed 03/05/25 Page 1 of 5 Page ID
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1 ABBE DAVID LOWELL
[email protected] 2 WINSTON & STRAWN LLP
1901 L St., N.W.
3 Washington, D.C. 20036-3508
Telephone: (202) 282-5000
4 Facsimile: (202) 282-5100
5 BRYAN M. SULLIVAN, State Bar Number 209743
[email protected] 6 ZACHARY C. HANSEN, State Bar Number 325128
[email protected] 7 EARLY SULLIVAN WRIGHT
GIZER & McRAE LLP
8 6420 Wilshire Boulevard, 17th Floor
Los Angeles, California 90048
9 Telephone: (323) 301-4660
Facsimile: (323) 301-4676
10
Attorneys for Plaintiff
11 Robert Hunter Biden
12 UNITED STATES DISTRICT COURT
13 CENTRAL DISTRICT OF CALIFORNIA
14 WESTERN DIVISION
15 ROBERT HUNTER BIDEN, an Case No. 2:23-cv-07593-HDV-KS
individual,
16 Assigned to:
Plaintiff, District Judge Hernán D. Vera
17
vs. DECLARATION OF ROBERT
18 HUNTER BIDEN IN SUPPORT OF
GARRETT ZIEGLER, an individual, PLAINTIFF ROBERT HUNTER
19 BIDEN’S EX PARTE
ICU, LLC, a Wyoming Limited APPLICATION FOR AN ORDER
20 Liability Company d/b/a Marco Polo, MOTION AND MOTION TO
and DOES 1 through 10, inclusive, VOLUNTARILY DISMISS ACTION
21 PURSUANT TO FED. RULE CIV.
PROC. 41(a)(2)
22 Defendants.
[Notice of Ex Parte Application and Ex
23 Parte Application; Declaration of
Bryan M. Sullivan; and [Proposed]
24 Order filed and served concurrently
herewith]
25
Place: Ctrm. 5B
26 Judge: Hon. Honorable Hernan D. Vera
27
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5804079.1 1
DECLARATION OF HUNTER BIDEN IN SUPPORT OF EX PARTE APPLICATION
Case 2:23-cv-07593-HDV-KS Document 85-1 Filed 03/05/25 Page 2 of 5 Page ID
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1 DECLARATION OF ROBERT HUNTER BIDEN
2 I, Robert Hunter Biden, declare and state as follows:
3 1. I am over the age of 18 and am the Plaintiff in this Action. I submit this
4 declaration in support of Plaintiff Robert Hunter Biden’s Notice Of Motion And
5 Motion To Voluntarily Dismiss Action Pursuant To Fed. Rule Civ. Proc. 41(A)(2). If
6 called as a witness, I would and could testify to the matters contained herein.
7 2. While I believe in the merits of this case, and, indeed, note that
8 Defendant Garrett Ziegler admitted to hacking my iCloud in multiple public
9 statements, I am requesting to dismiss this action because I do not have the financial
10 resources to continue litigating this case. Indeed, Defendants admitted in public
11 statements in December 2022 in an interview with Roger Stone, which I have seen,
12 as follows:
13 And we actually got into his iPhone backup, we were the
14 first group to do it in June of 2022, we cracked the
15 encrypted code that was stored on his laptop. And more
16 drug deals were in there, which set our, set our release date
17 back.
18 3. Since late 2023 and through today, my income has decreased
19 significantly. Prior to that time, my income primarily came from sales of my artwork
20 and sales of my memoir entitled “Beautiful Things”. In the 2 to 3 years prior to
21 December 2023, I sold 27 pieces for art at an average price of $54,481.48, but since
22 then I have only sold 1 piece of art for $36,000. Similarly, for my book sales, in the
23 six month period before the statements (April 1, 2023 through September 30, 2023),
24 based on the September 30, 2023 statement, 3,161 copies of my book were sold, but
25 in the six months after the statements, only approximately 1,100 books were sold.
26 Given the positive feedback and reviews of my artwork and memoir, I was expecting
27 to obtain paid speaking engagements and paid appearances, but that has not happened.
28 / / /
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DECLARATION OF HUNTER BIDEN IN SUPPORT OF EX PARTE APPLICATION
Case 2:23-cv-07593-HDV-KS Document 85-1 Filed 03/05/25 Page 3 of 5 Page ID
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1 4. This significant decrease in revenue has also impacted my ability to pay
2 off my significant debt, which as has been reported in the press as being several
3 million dollars. As a result of this, I am not in a position where I can borrow money.
4 5. In addition to this significant decrease in income and my debt, my lack
5 of financial resources has been exacerbated by the fires in the Pacific Palisades in
6 early January, which has rendered my rental house unlivable for an extended period
7 of time and, like many others in that situation, I am having difficulty in finding a new
8 permanent place to live.
9 6. While I was aware that my financial position had significantly
10 deteriorated over time, it was not until the past month that I realized I had to take
11 drastic actions to alleviate this situation. Then, during the week of February 24, 2025,
12 I was informed of all the work that was going to be performed over the next two
13 months and the estimated amount of fees and costs and over the weekend of March
14 1-2, 2025, I decided to voluntarily dismiss this action.
15 7. While I have other civil actions pending, I am assessing each one on a
16 case-by-case basis to allocate my limited resources. I cannot describe the details of
17 those analyses as it involves attorney-client communications and the attorney work
18 doctrine, but significant changes will be made to all of the cases in which I am
19 involved. For this case, despite Defendants’ public admissions that they “hacked” my
20 iCloud and manipulated my data, given the procedural posture of the case, the limited
21 extent of discovery taken, and the need for expert testimony, I have made the decision
22 to request that this case be voluntarily dismissed without prejudice and not expend
23 any further resources and time on this case.
24 8. Ultimately, this dismissal is necessary so I can focus my time and
25 resources dealing with my relocation, the damage I and my family have incurred due
26 / / /
27 / / /
28 / / /
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DECLARATION OF HUNTER BIDEN IN SUPPORT OF EX PARTE APPLICATION
Case 2:23-cv-07593-HDV-KS Document 85-1 Filed 03/05/25 Page 4 of 5 Page ID
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Case 2:23-cv-07593-HDV-KS Document 85-1 Filed 03/05/25 Page 5 of 5 Page ID
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1 CERTIFICATE OF SERVICE
2 I, April Wright, hereby certify that on this 5th day of March, 2025, a copy of
3 the foregoing DECLARATION OF ROBERT HUNTER BIDEN IN SUPPORT
4 OF PLAINTIFF ROBERT HUNTER BIDEN’S EX PARTE APPLICATION FOR
5 AN ORDER MOTION AND MOTION TO VOLUNTARILY DISMISS ACTION
6 PURSUANT TO FED. RULE CIV. PROC. 41(a)(2) was served via email, on the
7 following:
8 Jennifer Linsley Holliday Robert H. Tyler
LAW OFFICE OF ADVOCATES FOR
9 JENNIFER LINSLEY HOLLIDAY, FAITH & FREEDOM
ESQ. 25026 Las Brisas Road
10 7190 W. Sunset Boulevard, #1430 Murrieta, CA 92562
Los Angeles, CA 90046 Tel: (951) 600-2733
11 Tel: (805) 622-0225 Email: [email protected]
Email: [email protected]
12 Attorney for Defendants
Attorney for Defendants Garrett Ziegler and ICU, LLC
13 Garrett Ziegler and ICU, LLC
14
15
16
/s/ April Wright
17 APRIL WRIGHT
An employee of EARLY SULLIVAN
18 WRIGHT GIZER & MCRAE LLP
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5803799.3
DECLARATION OF HUNTER BIDEN IN SUPPORT OF EX PARTE APPLICATION
