Declaration

Cal. Super. - 6th Dist.December 7, 2020

\OOOflQUI-RUJNH NNNNNNNNNHr-Ar-tr-tr-‘r-‘r-‘r-‘r-AH OOQO‘xUl-hUJNb-‘OKOOOQONUI-RUJNF-‘O ZOCV37391 6 Santa Clara - Civil Fred W. Schwinn (SBN 225575) E'ectmn'ca")! Flled Raeon R. Roulston (SBN 255622) by SUperlor court Of CA’ Matthew c. Salmonsen (SBN 302854) C°unty 0f Santa C'aras CONSUMER LAW CENTER, INC. 0n 6/16/2021 2137 PM 1435 K011 Circle, Suite 104 Reviewed By: R. Walker San Jose, California 95 1 12-4610 Case #20CV37391 6 Telephone Number: (408) 294-6100 Envelope: 6663348 Facsimile Number: (408) 294-6190 Email Address: fred.schwinn@sjconsumerlaw.com Attorneys for Defendant SANJAY JAYAWARDENA SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY 0F SANTA CLARA DAVID CHAI, individually and 011 behalf Case No, 20CV373916 0f all others similarly situated, (Unlimited Civil Case) Plaintiffa DECLARATION 0F MATTHEW C. V- SALMONSEN 1N SUPPORT 0F AUTOMATIC 30-DAY EXTENSION OFVELOCITY INVESTMENTS, LLC, a New TIME TO FILE DEMURRER Jersey limited liability company; VELOCITY PORTFOLIO GROUP, INC., a Delaware corporation; and DOES 1 through 10, inclusive, Defendants. I, Matthew C. Salmonsen, declare as follows: 1. I am an attorney-at-law duly licensed t0 practice before all the courts 0f the State of California and I am an associate attorney in the law firm Consumer Law Center, Inc., attorneys of record for Plaintiff, DAVID CHAI (hereinafter “Plaintiff’). 2. I have personal knowledge 0f the following facts, and if called as a Witness, I could and would competently testify thereto. 3. Imake this declaration pursuant to Code of Civil Procedure § 430.41(a)(2). 4. Defendants, VELOCITY INVESTMENTS, LLC and VELOCITY PORTFOLIO GROUP, INC. (hereinafter collectively referred to as “Defendants”), served by email Answer t0 _ 1 _ DECLARATION OF MATTHEW C. SALMONSEN Case N0. 20CV373916 \OOOflQUI-RUJNH NNNNNNNNNHr-Ar-tr-tr-‘r-‘r-‘r-‘r-AH OOQO‘xUl-hUJNb-‘OKOOOQONUI-RUJNF-‘O Complaint by Velocity Investments. LLC and Answer t0 Complaint by Velocity Portfolio Group. Inc. (hereinafter “Answers”) in this matter on 0r about June 4, 2021. The Answers d0 not appear to have been filed as of the date 0f this declaration. 5. On June 16, 2021, I engaged in a telephonic meet and confer With Timothy P. Johnson, purported counsel for Defendants in this case. We discussed the matters t0 be raised in Plaintiff’ s contemplated demurrers and Mr. Johnson indicated a Willingness t0 serve amended pleadings. However, it was discussed that outstanding issues relating to the status 0f Defendants’ representation in this case needed t0 be resolved first. 6. Because the parties were unable t0 meet and confer at least five days before the due date for Plaintiff’ s contemplated demurrers, and because 0f outstanding questions relating t0 the status 0f Defendants’ representation in this case, Plaintiff hereby submits this declaration in support of an automatic 30-day extension t0 file a Demurrer, pursuant t0 Code 0f Civil Procedure § 430.41(a)(2). 7. Pursuant t0 Code 0f Civil Procedure § 430.41(a)(2), the new deadline for Plaintiff t0 file a Demurrer t0 the Answers is July 16, 2021. I declare under penalty 0f perjury under the laws 0f the State 0f California that the foregoing is true and correct. Executed this 16th day of June, 2021, at San Jose, California. /s/ Matthew C. Salmonsen Matthew C. Salmonsen (SBN 302854) _ 2 _ DECLARATION OF MATTHEW C. SALMONSEN Case N0. 20CV373916