Kulshrestha v. First Union Commercial Corp., 107 Cal. App. 4th 415 (2003)

Dheeraj Kulshrestha sued First Union for wrongful termination, promissory fraud, and discrimination, among other things. In response to First Union’s motion for summary judgment, Kulshrestha filed a declaration that he executed in Columbus, Ohio but that did not state that it was signed “under penalty of perjury under the laws of the