Jorge M. Chiriboga-Klein, MBA, Esq.

• Immigration Law: Represented over 100 clients of a large immigration law firm in California in Asylum, Withholding and CAT in a short period of time. Represented them in Master Hearings, and Merits Hearings., Have over 100 court appearances. Knowledge of INA, ACA, CVP, Visa Applications, USCIS representation. I589,declarations, direct, redirect and closing arguments. Represented clients in EOIRs in Southern California. . • Represent pilots in employment and contractual disputes with a Part 135 carrier. Developed significant knowledge of Federal Aviation Regulation compliance and relevant aviation industry statutes and regulations . • Performed litigation task and motion practice (Motion for Summary Judgement, Motions to Compel Discovery, among others) in an insurance case in Florida, representing a Roof Contractor as Defendant against Insurer claiming State Civil RICO violations, Common Law Fraud, and other alleged violations of the Florida Deceptive and Unfair Trade Practices Act (“FDUTPA”). . Produced and summarized some discovery materials related to litigation between clinics and a major Health Insurance Company • Advise corporate clients on tax, employment affairs and contracts and compliance and risk assessment in a highly regulated industry (vaping). Counseled prospects on P.R. Tax Incentive Code (Act 60 of 2019). Prepared all organizational documents for various corporate clients with complex shareholder/member structures. • Represent clients in civil cases in the areas of torts, breach of contracts, negotiation of loan modifications under Reg X and RESPA, administrative and commercial litigation, either plaintiffs or defendants in state and federal courts. Litigated employment case in the aviation industry. • Prevailed in tort and employment cases representing defendants through summary judgment

• Responsible for all legal and corporate affairs of this $200 MM Delaware trust (the “Company”) that bought life insurance policies (“life settlements”) and then sold beneficial interests in these to over 1,200 investors in 43 states by independent contractors, usually investment advisors or insurance agents. First in-house counsel hired in the Company's history. • Performed a comprehensive legal review of all aspects of the business, including corporate documentation, operations and practices, investments, sales training and procedures, supplier relations, and advertising materials. Did extensive due diligence on regulatory compliance status with 43 state securities regulators and the SEC. Identified situations of possible regulatory actions in some states and proactively resolved them. • Reviewed, redrafted, and established independent contractor sales policies and investor accreditation. Redrafted the Private Placement Memorandum of the Trust’s participations to comply with SEC guides and contemporaneous events in the Trust. • Managed litigation against the Company and its Independent Contractors by investors in Texas, California, and Wisconsin for alleged violations of state securities statutes. Supervised outside counsels hired to represent the Company and brought in-house tasks such as drafting briefs, motions, and initial complaint responses. Meticulously managed outside counsel tasks, costs, and involvement. Developed performance-based metrics to evaluate outside counsels’ effectiveness vs. counsel fees. • Investigated, responded to and resolved multiple inquiries and complaints from over 80 investors in 12 states, negotiating resolution and avoiding litigation in all cases. Negotiated and entered into agreements and orders with state securities authorities in Idaho, Maryland, North Carolina, and Florida, reducing fines by 60% and avoiding rescissions of investments of $4 MM. Resolved all these within six months without the use of outside counsel.

• Before taking the Bar Exam in March 2016, performed legal research for lawyers in the areas of Federal Criminal Statutes, such as Transportation of Animals for fighting 7 USC § 7156(b). Drafted motions to suppress evidence; drafted motions to dismiss the action. Performed research on 42 USC § 1983; drafted two complaints of two separate plaintiffs under this statute for a licensed attorney; assisted in depositions of plaintiffs; drafted response opposing motion to dismiss by the state. • Litigated successfully against 2 judicial sales of foreclosed property and foreclosure sentences;. • Advised clients on optimal corporate structure for control and taxes for new businesses. • Represented defendant in criminal cases in state court, including controlled substances, domestic violence, weapons possession and check fraud felonies.

• Founded managed and sold this Corporate Travel Management Company with interests in Latin America and the Caribbean. Grew the business to 40 MM in sales and 20 employees. Added $10 MM in revenue in 2014 without adding a single employee. • Involved in every operational, corporate, sales, finance detail of the Company. • Developed clientele in Trinidad, Perú, Argentina, Colombia, Costa Rica, and Venezuela, all major travel agencies in such countries.

While working full time and attending law school, interned at the office of the Solicitor General

• In charge of all operations of this small Corporate Travel Management Company. Acquired the company to form CTT HOLDINGS INC. Established and ran a call center for multi-country corporate travel management needs for various multinational clients, including Exxon Mobil, BHP Billiton, SAP, and Cable and Wireless in the Caribbean.

• Co-Head of the Investment Banking Division of this subsidiary of Boston based Pioneer Funds. Structured a $50 MM Joint Venture in the Caspian Sea between an Italian Energy Company and a multi-national consortium with interests in the Caspian Sea, as well as Lukoil. Advised RAO UES (the Public Electric Company in Russia) in its share repurchase program.

Admitted to practice in the Federal District Court for the District of Puerto Rico Admitted to practice in the Commonwealth of Puerto Rico