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Dec of Dillian Whyte

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Case 1:21-mc-23271-DPG Document 3-4 Entered on FLSD Docket 09/10/2021 Page 1 of 4

IN THE UNITED STATES DISTRICT COURT


FOR THE SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION

DILLIAN WHYTE, )
)
Petitioner, ) Civil Case No. 1:21-MC-23271-DPG
)
v. )
)
WORLD BOXING COUNCIL, INC., ) DECLARATION OF DILLIAN WHYTE
)
Respondent. )
)
_____________________________________ )

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Case 1:21-mc-23271-DPG Document 3-4 Entered on FLSD Docket 09/10/2021 Page 2 of 4

DECLARATION OF DILLIAN WHYTE

I, Dillian Whyte, declare as follows:

1. I am Jamaican by birth and moved to the United Kingdom at a young age.

I used my participation in combat sports as a way to deal with an economically challenged

childhood living in rough neighborhoods in Jamaica and South London. I have been

successful as a boxer, a former kickboxer, and a mixed martial artist. I submit this

declaration in support of my petition to obtain discovery under 28 U.S.C. section 1782.

The statements made herein are based on my personal knowledge and I could testify

competently thereto if called to do so.

2. As a former kickboxing champion, I have held the BIKMA British super-

heavyweight title and the European K1 title, and I have competed professionally and

successfully in mixed martial arts.

3. My professional boxing record is 28 wins (of which 19 were knockouts and

three were over former World Champions) and 2 losses, which followed a brief but

successful amateur career in which I won all seven of my fights, including, in my first

boxing match, an emphatic victory over current unified world heavyweight champion,

Anthony Joshua.

4. I have held the WBC interim world heavyweight title since March 2021,

having previously held the title from 2019 to 2020, prior to which I held the WBC silver

world title from 2017.

5. At the regional level, I have held multiple heavyweight boxing titles,

including all the other WBC titles for which I was eligible and, from 2016 to 2017, the

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Case 1:21-mc-23271-DPG Document 3-4 Entered on FLSD Docket 09/10/2021 Page 3 of 4

prestigious British “Lonsdale Belt”.

6. I have been continuously ranked as a top 10 heavyweight by Ring Magazine

in their widely-respected rankings for over 240 weeks. Currently, Ring Magazine ranks

me as the number 3 heavyweight in the world, having previously ranked me as high as

number 2. The Transnational Boxing Rankings Board rates me the number 3 heavyweight

in the world. Although as a WBC champion, most of the other sanctioning bodies do not

currently include me within their rankings, the one such body that does, the International

Boxing Organization, has me at number one (pursuant to their “objective, comprehensive,

computerized rankings” which they maintain “are the most reliable in the sport”) although

they do not mandate their champions to defend their titles. Thus, as a result of pursuing

the WBC title route, all title opportunities with other sanctioning bodies have been

foreclosed.

6. I am currently ranked by www.boxrec.com, one of the leading sources of

information about boxing that is relied upon by those in the industry and on which the

WBC itself purports to base its rankings, as number 2 (Tyson Fury and Deontay Wilder

were removed from the rankings because of their failure to fight since February 2020,

during a time when I fought twice and am preparing for a third fight that was due to occur

before Fury and Wilder next fight). I have fought and beaten more WBC and Ring

Magazine top ten boxers than both the present champion, Tyson Fury, and the former

champion, Deontay Wilder, combined.

7. I was first ranked as the number one contender in the WBC Heavyweight

rankings in November 2017 and held this position continually – for over 1,000 days - until

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Case 1:21-mc-23271-DPG Document 3-4 Entered on FLSD Docket 09/10/2021 Page 4 of 4

my loss to Povetkin on 20 August 2020. Ordinarily, the number one contender would

expect to challenge the full World Champion for their belt at the latest within a year of

assuming that position. In any event, the full World Champion is obliged to make a

mandatory defence of his title every 12 months, which in the ordinary course would be

against the highest ranked – and most deserving – contender. In my case, for reasons I

cannot fathom, I was leapfrogged twice by less worthy and lower ranked contenders and

now I find myself in no man’s land by an apparent refusal of the WBC to follow its own

rules and to mandate my title shot in a timely fashion – or at all.

I declare under penalty of perjury under the laws of the United States of America

that the foregoing is true and correct. Executed this 7th day of September 2021 at

Vilamoura, Quarteira, Algarve, Portugal.

__________________________
Dillian Whyte

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