Declaration In OppositionCal. Super. - 6th Dist.December 7, 2020TIMQTHY P. JoHNsoN (BAR No. 66333) BARRON & NEWBURGER, P.C. 1970 OLo TvsTIN AvFNvE, SEcoNo FLooR SANTA ANA. CA LIFO RN I A 92705 TELEPHONE: (714) 832-1170 FAcsIMILE: (714) 832-1179 E-MAIL:tjohnson@bn-lawyers.corn Attorneys for Defendants Velocity Investments, LLC and Velocity Portfolio Group, Inc. 10 11 12 SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA DAVID CHAI, individually and on behalf of Case No. 20CV373916 all others similarly situated, (Unlimited Civil Case) 13 vs. Plaintiff, Assigned for All Purposes to The Honorable Patricia M. Lucas 15 16 17 19 20 21 22 23 VELOCITY INVESTMENTS, LLC, a New Jersey limited liability company; VELOCITY PORTFOLIO GROUP, INC., a Delaware corporation; and DOES I through 10. inclusive. Defendants. Hearing Date: Hearing Time: Hearing Dept. Hearing Location: February 23, 2022 I:30 p.m. 3 191 North First Street San Jose, Califontia DECLARATION OF TIMOTHY P. JOHNSON IN SUPPORT OF DEFENDANTS'PPOSITION TO MOTION FOR CLASS CERTIFICATION 24 25 26 27 28 DECLARATION OF TIMOTHY P. JOHNISON I, Timothy P. Johnson, declare as follows: 1. I am an attorney at law, licensed to practice before all of the courts of the state of California. I am the attorney for Defendants Velocity Investments, LLC and Velocity Portfolio DECI.ARATION OF TIMOTI IY P. JOHNSON -I- ISO Ol'POSITION TO CLASS CFurl'IFICA'I'ION Case N o. 2ocv3739 I a Electronically Filed by Superior Court of CA, County of Santa Clara, on 2/2/2022 2:54 PM Reviewed By: R. Walker Case #20CV373916 Envelope: 8200179 20CV373916 Santa Clara - Civil Group, Inc. ("Defendants"). 2. Plaintiff s deposition was taken on January 27, 2022. Attached as Exhibit I to this Declaration are true and correct copies of the relevant pages of that deposition I declare under penalty of perjury under the laws of the state of California that the foregoing is true and correct. If called as a witness, I could and v"ould so testify Executed this 2" day of February, 2022, at Santa Ana, California ~MOT Y P. Jlllaase~ 10 12 13 14 15 16 17 19 20 21 22 23 25 26 27 OIPPI,ARATION OF TIMOTIIY P IOI INSON ISO OPPOSI I ION TO CLASS CERTIFICATION Case N o. 20CV3 739 I 6