Unredacted Document — USA v. Western Distribution, LLC. et al. (Dkt. 44-1, C.D. Cal.)

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Waiver by Carl Bradley Johansson, Document 44-1 in Case 5:21-cr-00170-JGB. Johansson declares that Johansson gives up rights, claims and remedies arising from potential and actual conflicts facing the law firm Werksman Jackson & Quinn LLP, which also represents Western Distribution, LLC in this matter. The declaration states that attorney Mark Werksman advised Johansson to consult independent counsel, and lists rights including effective assistance of counsel, representation by separate counsel, and not waiving any conflict. It states that the waiver is voluntary, knowing and intelligent, and that no promises have been made that bear on it. The declaration is made under penalty of perjury and ends with the name Carl Bradley Johansson, executed at Los Angeles, California.

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Case 5:21-cr-00170-JGB Document 44-1 Filed 09/27/21 Pagelof2 PagelID
#:223

WAIVER OF CONFLICT OF INTEREST

BY CARL BRADLEY JOHANSSON

I, Carl Bradley Johansson, declare as follows:

1. lam executing this declaration to waive and to give up any and all
rights, claims and/or remedies I would otherwise have from potential and/or actual
conflicts of interest facing the law firm Werksman Jackson & Quinn LLP.

2. It is my wish that Werksman Jackson & Quinn LLP shall represent me
even though your firm also represents Western Distribution, LLC. I understand
that potential or actual conflicts of interests may exist now, or may arise later,
based on the fact that Werksman Jackson & Quinn LLP also represents Western
Distribution, LLC in this matter. I further understand that no one can determine at
this time all of the situations in which these conflicts of interest may exist or arise.

3. Ihave been advised by attorney Mark Werksman to consult
independent counsel regarding the issues raised by this waiver, and I understand
that should I feel for any reason that I need the advice of another attorney
regarding any aspect of the services of Werksman Jackson & Quinn LLP provides
to me, I should feel free to obtain my own attorney to provide advice and counsel
on this matter.

4. J understand that as this case proceeds any number of developments
may occur that may drastically alter my interests. I further understand that no one
can know what all of these potential developments are, how they may affect my
defense, or my interest in this case. However, I understand the following: a) I have
the right to effective assistance of counsel, including the right to be represented by
separate counsel, unfettered by any actual or potential conflicts of interest; b) I
have the right not to waive any actual or potential conflicts of interest; c) I have the
right to consult with independent counsel with respect to the meaning of this

waiver and whether I should execute it; d) if J refuse to waive any actual or
Case 5:21-cr-00170-JGB Document 44-1 Filed 09/27/21 Page2of2 PagelID
#:224

potential conflicts of interest, I understand that this could prohibit Werksman
Jackson & Quinn LLP from representing me at this time.

5. In executing this waiver, I am acting voluntarily, knowingly and
intelligently. I have been fully advised by counsel with respect to this matter and
am fully satisfied with the advice I have received. I have carefully read and
considered every part of this waiver and I fully understand every part of this
waiver. I have no questions concerning the meaning or significance of any part of
this waiver. I have had a full opportunity to consider this matter and to consult
with others. I do not wish any additional time to consider this matter and I do not
wish to consult with any other person.

6. I fully understand everything described above, and I hereby waive and
give up any and all rights, claims, and/or remedies arising from potential and/or
actual conflicts of interest caused by Werksman Jackson & Quinn LLP
representing Western Distribution, LLC.

7. I am not under the influence of any medication or any other substance
that would affect my understanding of judgment, nor do I suffer from any physical,
emotional or mental condition that would affect my understanding or judgment.

8. Iam not acting under duress and no promises have been made to or

against me or others that bear on this waiver.

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

best of my knowledge.

Executed this L‘Yday of September, 2021, at Los Angeles, California.

Carl Bradley Johansson


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