In Bowden v. Robinson (1977) 67 Cal. App. 3d 705, the court rejected a declaration of a corporate officer that asserted "to the best of my knowledge," certain individuals were never elected as corporate officers, and "to the best of my knowledge" he never said shares could legally be issued in California. The Bowden declaration is obviously suspect, since the question of what corporate officers were elected would be easily verifiable from corporate records. And, as the court observed, it was unclear with regard to the statement about the issuance of shares whether the declarant meant that he did not recall making the representation, or was affirmatively saying he never uttered it. So the court held the declaration in question was inadequate to show who the company's corporate officers were. It did not, however, hold that the phrase somehow magically nullifies whatever statement follows it. It merely held, correctly, that the phrase "to the best of my knowledge" introduces an element of uncertainty which, under certain circumstances, can be lethal. Indeed, the Bowden court invalidated another statement in the declaration-- which also used the phrase "to the best of my knowledge"--not on the basis that it was not based on personal knowledge, but on the basis it was a lay opinion on a matter of law.