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SUPPLEMENTAL DECLARATION OF YOURAS ZIANKOVICH

I, Youras Ziankovich, declare as follows:

I am the Plaintiff in this action. I submit this declaration to clarify the circumstances surrounding service of process on the Colorado Defendants.

After filing this action, I retained a professional process server to effect service on the Office of Attorney Regulation Counsel (“OARC”) at its official address, 1300 Broadway, Suite 500, Denver, Colorado.

The process server informed me that OARC had not moved back to that location and that physical access to the office was unavailable (see Exhibit B). The process server further advised that service attempts at the official OARC address were unsuccessful because the office remained closed.

Consistent with the process server’s report, OARC’s own public website states that its office has been closed since January 2, 2024 due to a security incident and expressly instructs the public not to visit the office (see Exhibit A), recommending instead the use of phone, mail, or email communications.

OARC’s website does not identify any designated agent for service of process, any alternative physical service location, or any substitute procedure for effecting in-person service while the office remains closed.

Under these circumstances, and acting in good faith, service was effected through the Office of the Colorado Attorney General, the State’s chief legal office and the entity that represents OARC, the Presiding Disciplinary Judge, and the Colorado Supreme Court in civil litigation.

On December 29, 2025 at 3:05 PM, the Office of the Attorney General accepted service, as reflected by its official “Received” timestamp (see ECF No. 29-2). The Attorney General thereafter appeared through counsel and is actively litigating this case on behalf of the Colorado Defendants.

At all times, I acted with reasonable diligence and in good faith to effect service under circumstances where Defendants’ own office was physically inaccessible and where Defendants provided no alternative service mechanism.

I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct.