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FILED
IN THE CIRCUIT COURT FOR THE STATE OF OREGON
FOR THE COUNTY OF MULTNOMAH
ENDEAVOUR CAPITAL FUND VL LP.
a Delaware limited partnership; and Case No. (Tey 411.95,
ENDEAVOUR ASSOCIATES FUND VI,
LP.,a Delaware limited partnership,
Plaintiffs, DECLARATION OF STEPHEN BABSON
IN SUPPORT OF ENDEAVOUR’S
v. MOTIONS FOR EXPEDITED
APPOINTMENT OF A RECEIVER,
ZOOM MANAGEMENT, INC., an ORDER TO SHOW CAUSE, AND FOR
Oregon corporation; ZOOM CARE, P.C., | TEMPORARY RESTRAINING ORDER
an Oregon corporation; and ZOOM CARE
WASHINGTON, P.L.L.C.,a Washington | (Portions of this Declaration and Exhibits 2-11,
Limited Liability Company. 13, and 16-17 Publically Filed in Redacted
Form Pursuant to Court Order)
Defendant.
1, Stephen Babson, hereby declare as follows:
1. Lam over the age of eighteen and I have personal knowledge of the matters set,
forth herein, and, if called upon to do so, could testify competently to their truth,
2. Lama Managing Director of Endeavour Capital (“Endeavour”), which invests in
Western U.S.-based, middle-market companies in partnership with founders, family owners, and
managers.
3. Endeavour has invested significant capital and resources into Zoom Management,
Inc. (*ZMI"). ZMI is a part of an interconnected family of companies that make up the Zoom+
Care enterprise. Zoom+Care is a healthcare business that provides individual health care
services through a collection of neighborhood clinies and technology tools. With the stated goal
of using technology to transform healthcare, Zoom+Care utilizes features such as same-day
Perkins Coie LLP.
5 1120 NW. Couch Strest, 10th Floor
I. DECLARATION OF STEPHEN BABSON IN SUPPORT OF Pea Reiton iss alae
ENDEAVOUR'S MOTION FOR EXPEDITED ae