DECLARATION OF DUE DILLIGENCE

January 8, 2024

Eun Jung Lim
17192 Murphy Avenue #17723
Irvine, California [92623]
invokemyright@protonmail.com

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF ORANGE

EUN JUNG LIM,
Plaintiff,
v.
HOAG MEMORIAL HOSPITAL
PRESBYTERIAN; and HERBERT
CONRAD, in his official and individual
capacity,
Defendants.

Case No.: 30-2022-01242187-CU-PO-CJC

DECLARATION OF DUE DILLIGENCE

I, EUN JUNG LIM, declare,
1. The whereabouts of the following is unknown and I cannot, after reasonable search, locate and
serve the person:

 HERBERT CONRAD

2. My efforts to locate and serve the said Defendant were as follows:
i. On Wednesday, February 2, 2022, Plaintiff’s process server emailed Plaintiff and
notified her that nobody knew who Herbert Conrad was and that there was no
Herbert working at Hoag Memorial Hospital Presbyterian.

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DECLARATION OF DUE DILLIGENCE

ii. On February 3, 2022, the process server informed the Plaintiff that a skip trace
search was done and there was no trace of Herbert Conrad in California between
the ages of 27-35.
iii. On February 4, 2022, the process server informed the Plaintiff that the process
server would go back to Hoag Memorial Hospital in Irvine to look for Herbert
Conrad.
iv. On February 14, 2022, the process server again went back to the Hoag Memorial
Hospital Presbyterian. A security guard called Alexander informed the process
server was Herbert Conrad did not work at the hospital any more, and that he had
not been working there for the last six months.
v. The process server further sought to confirm whether Herbert Conrad worked at
the Hoag Memorial Hospital Presbyterian. On February 14, 2022, Dave L.
Sergeant informed the process server that he could not disclose any information
about who worked there as security.
vi. The closest identity that matched Herbert Conrad was:

Herbert M Conrad
WESTMINSTER, CALIFORNIA
Westminster, California
However, the said individual is not traceable.

3. The last contact I had with Defendant Herbert Conrad was at the scene of the incidence
on January 25, 2020. Upon reasonable belief and information, Defendant Herbert Conrad
worked as security at Hoag hospital Irvine emergency desk the grave yard shift. Location
back in 2020.

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DECLARATION OF DUE DILLIGENCE

I declare under penalty of perjury under the laws of the State of California that the
forgoing is true and correct.
Dated: June 13, 2022

Respectfully submitted,

______________________________
EUN JUNG LIM

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