Declaration of Robert Frohwein in Support of Motion to Dismiss — United States ex rel. Pietschner v. Petralia

Summary

Exhibit 1, filed March 11, 2025 as Document 68-1 in United States of America, ex rel. Paul Pietschner v. Kathryn Petralia, Robert Frohwein, and Spencer Robinson, Case No. 4:21-cv-110-SDJ, in the U.S. District Court for the Eastern District of Texas. It is the declaration of defendant Robert Frohwein in support of his motion to dismiss, executed March 6, 2025. The declaration states that he lived and worked in Georgia until February 2022, then relocated to California, and has never lived, worked or owned property in Texas. It states that he does not transact business in Texas and that, to the best of his recollection, knowledge and belief, while employed by Kabbage, he did not communicate with Paycheck Protection Program borrowers in Texas or review or approve their loan applications. The exhibit is three pages, including a cover page.

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Full text

Case 4:21-cv-00110-SDJ   Document 68-1   Filed 03/11/25   Page 1 of 3 PageID #: 589




                Exhibit 1
Case 4:21-cv-00110-SDJ         Document 68-1          Filed 03/11/25    Page 2 of 3 PageID #: 590




                              UNITED STATES DISTRICT COURT
                               EASTERN DISTRICT OF TEXAS


 UNITED STATES OF AMERICA, ex rel.
 PAUL PIETSCHNER,
                                                          Case No. 4:21-cv-110-SDJ
                v.

 KATHRYN PETRALIA, ROBERT
 FROHWEIN, and SPENCER ROBINSON.



                             DECLARATION OF ROBERT FROHWEIN
                            IN SUPPORT OF HIS MOTION TO DISMISS


        I, Robert Frohwein, hereby declare as follows:

        1.      From August 1996 until February 2022, I lived and worked in Atlanta, Georgia. In

 February 2022, I relocated to California, where I presently live, work, and intend to remain. I have

 never lived, worked, or owned property in Texas.

        2.      I do not presently transact business in Texas, nor did I when the above-captioned

 complaint was filed.

        3.      To the best of my recollection, knowledge, and belief, while I was employed by

 Kabbage, I never had any communications with Paycheck Protection Program (“PPP”) borrowers

 in Texas, nor did I did review or approve any loan applications for PPP borrowers in Texas.




                                            Exhibit 1 - Page 1
Case 4:21-cv-00110-SDJ        Document 68-1          Filed 03/11/25     Page 3 of 3 PageID #: 591




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

 recollection, knowledge, and belief.

        Executed on March 6, 2025, at Saratoga, CA.




                                                                     _________________
                                                                  Robert Frohwein




                                           Exhibit 1 - Page 2


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