Case 8:12-ap-01550-ES Doc 103 Filed 02/28/17 Entered 02/28/17 16:03:49 Desc

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Matthew E. Hess (State Bar No. 214732)

MATTHEW E. HESS, ATTORNEY AT LAW
1801 Century Park East, 24th Floor
Los Angeles, OA 90067
Telephone: (310) 751-7544
Facsimile: (310)464-0397
E-mail matthew.hess@hessiawyers.com

Attorney for Debtor JAY PHOTOGLOU

U N I T E D S TAT E S B A N K R U P T C Y C O U R T

CENTRAL DISTRICT OF CALIFORNIA - SANTA ANA DIVISION

In re: Case No.: 8:12-BK-17907-ES

JAY PHOTOGLOU,
Adversary No. 8:12-AP-1550-ES
D e b t o r.
D E C L A R AT I O N O F C H R I S W I N N

GRETCHEN ROSSI,

Plaintiff,

JAY PHOTOGLOU,

Defendant.

D E C L A R AT I O N O F C H R I S W I N N
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1 I, Chris Winn, declare as follows:

2 1. I am over the age of eighteen and not a party to this action. I
3 have personal knowledge of the facts herein and, if called as a witness,
4 can testify competently thereto.
5 2. I am the president of Sales and Service Inc. (SSI), a leading
6 manufacturer's representative in the semiconductor industry.
7 3. I first met Gretchen Rossi in the spring of 2008, during the
8 Spring Heat Wave boat race in Lake Havasu, Arizona. I was introduced to
9 her by Jay Photoglou, my close friend. At that time, Jay had a house in
10 Lake Havasu, although he later lost the house in foreclosure, along with
11 his speedboat.
12 4. When I arrived in Lake Havasu, I located Jay at a bar. At the
13 bar, Jay introduced me to Rossi. I remember this because Rossi kept
14 leaving the table to take calls every twenty minutes or so. At one point,
15 Rossi got a call while but did not get up to leave. I could hear a man on
16 the other end of the call yelling at Rossi. As soon as Rossi put down the
17 phone, she said that the person who had called was "the producer," and
18 that she was about to join the cast of the Real Housewives of Orange
19 County television show. At that time, I had never seen the RHOC show,
20 although I had heard of it because one of my friends married a cast
21 member. But the conversation was unusual enough that I can still
22 remember it years later.
23 5. During the trip to Lake Havasu, I stayed at Jay's house, in one
24 of the guest bedrooms. Our mutual friend, Mike Horton, stayed there too.
25 6. Rossi also stayed at Jay's house, in Jay's bedroom.
26 7. I try to avoid gossip, and I do not like revealing what I am about
27 to describe. But it happened, and given what has happened between
28 Rossi and Jay, I think it is important to tell the truth.

1
D E C L A R AT I O N O F C H R I S W I N N
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1 the boat with him, but everyone was tired from staying up late to party the
2 night before, and no one (including Rossi) wanted to get up and start the
3 day. As a result. Jay missed the time trials. As the actual race was about
4 to begin, he became worried about missing the race and said that if his
5 guests weren't going to get up, he'd just go to the race by himself. I
6 thought that Jay was right to be concerned and that his behavior was
7 perfectly reasonable.
8 20. In February 2009, Rossi and Slade Smiley came to my
9 birthday party at Maestros Ocean without Jay.
10 21. Shortly after the breakup, on March 23, 2009, Rossi came to
11 our house when our four-year old son was having his birthday party. She
12 asked me to "get Jay to drop his lawsuit," and to "talk some sense" into
13 him. She said that she was worried about losing her job on the RHOC
14 cast, because "Jay was not supposed to exist."
15 22. I saw the episode of RHOC in which Rossi called Jay a stalker.
16 This is outrageous. She was lying. They dated for several months and
17 were very close.
18

19 23. I declare under penalty of perjury under the laws of the United
20 States and the State of California that the foregoing is true and correct.
21 Executed this day of February, 2017 at Orange County, California.

D E C L A R AT I O N O F C H R I S W I N N
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