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AFFIDAVIT OF ANDY ANDERSON 1. I am Andy Anderson, and I have owned my own stock investment firm, Andy Anderson Advisors, for the last twenty years. I have a degree in Marketing from the University of Southern California. For the last three years, I have been honored to be a friend of Lee and Robbie McLaughlin. I came to know Lee and Robbie when they joined the Great Wessex Country Club. They are just wonderful people and have a wonderful family. I am sick at heart to be making this statement as part of the litigation between Macca and his/her parents. I know that every decision they have made since they have had kids has been made in the best interest of their kids. They are so proud of Macca and of Sasha and Jenna, too. And I know because I have talked to them extensively that they would do anything to recover the investment they made in Odyssey Omni if they could. But, unfortunately, they can’t. Nor do I think they should have to. 2. I have advised clients for two decades about the risks and rewards of investing in the stock market. Before I ever talked about the rewards, I talked about the risks. People have to know that there are ups and downs and that the best you can do is educate yourself before you invest, and only invest an amount that you are comfortable with. One of my pet peeves with those who criticize market players is that they comment from perfect 20/20 hindsight. It is easy to criticize a stock choice that has turned out to be a bad one, just as it is easy to praise a stock choice once it has turned out to be a winner. But no one can know which a stock will be – winner or loser – before they invest. There is really not that much difference between those who earn money on stocks and those who lose, at least among those wise people who seek stock advice. It is always funny to me to hear people criticize stocks as an investment now. You certainly didn’t hear that in the ‘90s and the early 2000s when people were routinely increasing their portfolios by 20% a year without investing an additional dime. Even in this decade, when the stock market ride can be a little rough at times, there is still very, very good value in the stock market. And, despite some real loser IPOs, there have been some great opportunities there as well. In fact, without our investment in IPOs, my family would not have the considerable wealth we’ve amassed. 3. Let me talk specifically about Odyssey Omni and how Robbie and Lee got involved. A number of stock investment firms, including my own, had been carefully watching the technology companies in 2017 and 2018. Some of them were dogs, and some looked very promising. The companies that I am talking about are not the big boys, like Microsoft, Apple or Dell. I am talking about the dot.coms and particularly the search engine companies. Everyone had been keeping a particularly close eye on Zahoo! – an incredibly valuable search engine company, essentially owned by just two individuals. A couple of us, myself and Kelsey English at Stanley Morgan – Kelsey also belongs to the Club – had our eyes on Odyssey Omni. Although Odyssey Omni did not get the press that Zahoo! did, all our research suggested that the company had tremendous value. It hadn’t launched its search engine yet, but the concept looked good. Kelsey’s company had issued an internal report that I was able to get my hands on, suggesting that, if Odyssey Omni went public, it would be the opportunity of the year. 4. Well, you can imagine that this was all the talk at the Great Wessex Club when our golf foursome got together. That is one of the great things about golf, it really gives you a chance to do business and learn a lot about how others are doing business if you just keep your eyes and ears open, which I do, believe me. Kelsey, Robbie, Alex Johnson and I played about once a month back then. Robbie and Lee were very popular at the Club, not only because they are great people but because of Macca’s fame. All our kids hung out at the Club constantly hoping to get a glimpse of Macca. I think it drove Lee and Robbie a little crazy at times, always being bugged by the kids. At any rate, we did a lot of talking, over our gold rounds, about Odyssey Omni. Kelsey and I made it clear that we wanted to be in on the IPO when it came. I remember Robbie taking me aside, maybe in July 2018; I remember it was really hot. Robbie wanted to talk to me about investing Macca’s money in the stock market. I told Robbie I would put together a suggested portfolio of long-term investments. Robbie told me that long-term investments were out, because as guardian of Macca’s funds, Robbie couldn’t tie up those funds after Macca turned 18. The funds would become Macca’s then. Robbie was feeling that the interest Macca’s money was making in the bank, which was about nothing, really suggested irresponsible stewardship on Robbie’s part. So, we talked more about it over the next few days, and Robbie became increasingly interested in Odyssey Omni. I told Robbie that IPOs are generally risky, but I thought Odyssey Omni was a sure bet. I cautioned Robbie not to hold it too long as IPOs did tend to jump up and then fall back. Robbie understood. 5. Robbie asked me a week or so later whether there was anything I saw in the market that made more sense, and I could only say that Odyssey Omni looked like the best deal coming down the pike. The IPO for Odyssey Omni was in September 2018. The stock was trading at $25 per share at the end of the first day of trading. I bought shares for myself – I’m uncomfortable saying how many, and I bought 54,000 shares for Robbie. About one week later, when the share price had risen to $28, Robbie bought an additional 5,500 shares. I sold all my shares when the price hit $28, because that is what I always do with IPOs. I was kicking myself because about a month after that the share price went to $31. 6. Much to our surprise, Odyssey Omni folded in May 2019, less than one year after the IPO. What none of us knew was that the CEO and CFO of Odyssey Omni were nothing better than crooks. They’d lied from the beginning about their technology and how close they were to be able to launch it. They’d done all kinds of off-balance-sheet transactions to hide the extent of their losses and a whole lot of other misleading and illegal things. The Securities Exchange Commission caught them, but not before Robbie, Kelsey and thousands of other investors lost every cent they invested. There is a civil suit by the investors to try to get some of their money back, but those suits rarely result in any recovery for the shareholders. Only the lawyers get rich in those suits. 7. I feel truly sorry for Robbie and Lee, and for Macca as well. Kelsey asked me the other day if I felt any guilt for recommending the stock to Robbie. What could I say? If people in the investment business took their clients’ losses to heart, they’d never sleep. My advice to Robbie was sound when I gave it. It was a good, solid, smart investment for Robbie to make. It just didn’t work out, that’s all. It happens in the market. I sleep just fine.