DeclarationCal. Super. - 6th Dist.January 31, 2020Electronically Filed by Superior Court of CA, County of Santa Clara, on 3/9/2020 4:41 PM Reviewed By: R. Nguyen Case #20CV362872 Envelope: 4142941 20CV362872 Santa Clara - Civil R. Nguyen 10 ll 12 l3 14 15 16 l7 18 19 20 21 22 23 24 25 REBEKAH J. ROSE, ESQ. (State Bar No. 258072) LAW OFFICE OF REBEKAH J. ROSE 13200 Hwy 9, Suite 15 Boulder Creek, California 95006 Telephone: (408) 61 3-9401 rebekah@rroselaw.com Attorney for Plaintiffs Rick Reynolds and Rosa Figueroa SUPERIOR COURT FOR THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA RICK REYNOLDS AND ROSA CASE NO. 20 CV 362872 FIGUEROA, DECLARATION OF REBEKAH J ROSE IN SUPPORT OF PLAINTIFFS’ Plaintiffs, MOTION FOR PRELIMINARY INJUNCTION v. VALERIE HAWES, an individual and Dfltefi A_Pril 14: 2020 DOES 1-25 Inclusive, Tlme' 9‘00 a‘m' Dept. 19 Defendants. REBEKAH J. ROSE declares: 1. I am an attorney at law, duly admitted to practice before all the couns of the State of California and I am an attorney at Law Office of Rebekah J. Rose, attorneys of record herein for Plaintiffs Rick Reynokds and Rosa Figueroa. I am familiar with the aspects of this case, including all of the matters which are set forth in this Declaration. If called upon t0 testify 0n the contents of this declaration, I could and would completely testify to the following based upon my own personal knowledge. 2. On February 23, 2020, after Plaintiffs became aware that Defendant was preparing the Home for sale, I contacted Defendant’s realtor to inform her there was litigation pending as to the Home. Defendants realtor response indicated she was unaware ofany l DECLARATION 0F REBEKAH J. ROSE IN SUPPORT 0F PLAINTIFFS’ MOTION FOR PRELIMINARY INJUNCTION 10 ll 12 l3 l4 15 l6 l7 18 19 20 21 22 23 24 25 lawsuit and inquired as to when it was filed. A copy of these e-majl exchanges are attached hereto as Exhibit “A.” I declare under penalty of peljury under the laws of the State of California that the foregoing is true and correct and if called to testify in this matter, I could do so competently. Executed March 9, 2020 at Boulder Creek, California. e REBEKAH J. ROSE 2 DECLARATION 0F REBEKAH J. ROSE IN SUPPORT OF PLAINTIFFS' MOTION FOR PRELIMINARY [NJUNCTION EXHIBIT A 3l1l2020 ‘ose Management Consultants Mail - 200 Ford Road No. 21 8- Reynoids v Hawes :3; I "w 2, [af m}: f; 54‘ .7 .I mfl Rebekah Rose M3 a: 200 Ford Road No. 218- Reynolds v Hawes Rebekah Rose Sun, Feb 23 2020 at 1 .40 PM To: Christine Rosi Bcc: Rick Reynolds , "R. C." Dear Ms. Rosi, This omce represents Rick Reynoids and Rosa Figueroa in an action against Valerie Hawes pertaining to ownership ofthe above referenced property. Please find attached a letter re same. If you have any questions, contact me at your convenience. Rebekah J. Rose Law Office of Rebekah J. Rose 13200 Hwy 9, Suite 15 Boulder Creek, CA 95006 (403) 61 3-9401 rebekah@rrose!aw.com :3 Ltr to C. Roéi.pdf 335K https:limait.google.com/mail/uIO?ik=ad44b58c228view=pt&search=all&pelmmsgid=msg-a%3Ar-1 037838485229499945&simpl=msg-a%3Ar-1 037838. .. 1/1 unlzuzo '“ose Management Consultan$ Mail - 200 Ford Road No. 218. Reynolds v Hawes .v-‘ll {{7 3%.g3;fl WM? :11} m. Rebekah Rose 200 Ford Road No. 21 8- Reynolds v Hawes Christine Rosi Sun Feb 23 2020 at‘l:57 PM To: Rebekah Rose What is the litigation about? Was this just filed? Sincerely, Christine Rosi lntero Real Estate Services Broker Associate 510-396-4536 Mobile DRE No. 00985805 LIKE my Fan Page Joyfuf Living Today i Voted Five Star Agent in Diablo Magazine 2013, 2015, 2016,2018 i Here’s what my clients are saying about me I {Quoted text hidden] [Quoted text hidden] httpszllmailgooglaoomlmaillu/O?ik=ad44b59c22&view=pt&searchalta‘pennmsgidmsg-PASM 659366339697780479&simpl=msg-M3A1 6593563396. . . 1/1 w .mucu "ose Management Consultants Mail - 200 Ford Road N_o. 21B- Reynolds v Hawes i 3 EM“? < g Rebekah Rose 200 Ford Road No. 218- Reynolds v Hawes Rebekah Rose Sun, Feb 23 2020 at 2:51 PM To: Chn‘sfine Rosi Hi Christine, It was filed January 3 Ist and a service copy was provided to her counsel shortly tbercafier. Mr. Singer indicated Ms/ Hawcs would be retaining a new fu-m to respond to the complaint but 1 have not received information re who will be representing Ms. Hawes or if she intends to represent herself. The litigation is pertaining to ownership interest in the subject property, plaintiffs claim the right to purchase the property pursuant to an agreement with Ms. Hawes. Rebekah J. Rose Law Office of Rebekah .1. Rose 13200 Hwy 9, Suite 15 Bouider Creek, CA 95006 (408) 613-9401 rebekah@rroseiawAcom [Quoted text hidden] https:IImaiI.google.com/maillul0?ik=ad44b59022&view=pt&search=alI8:permmsgikmsg-a%3Ar-2434285785 183069770&simp|=msg-a%3Ar-2434285 . . . 1/1 L7,