DeclarationCal. Super. - 6th Dist.February 1, 2021wooqmowphme wwwwmwmer-II-tr-Iv-II-tr-Iv-tr-Ir-Iv-t OOQGDO‘lv-POOND-‘OCDOONGDOTr-PCJONHO Dmitry Stadlin, SBN 302361 STADLIN MARINHO LLP 111 N. Market Street. Suite 300 San Jose, California 95113 Tel: (408) 645-7801 Fax: (408) 645-7802 Email: ds@stadlinmarinh0.com Attorneys for Petitioner ALEXIS DACOSTA Electronically Filed by Superior Court of CA, County of Santa Clara, on 2/7/2022 1:02 PM Reviewed By: K. Nguyen Case #21 CH009837 Envelope: 8232143 SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SANTA CLARA ALEXIS DACOSTA Petitioner, And, KRZYSZTOF SYWULA, Respondent. Case N0.: 21CH009837 DECLARATION OF DMITRY STADLIN IN SUPPORT OF PETITIONER ALEXIS DACOSTA’S OPPOSITION TO RESPONDENT KRZYSZTOF SYWULA’S EXPARTE REQUEST TO CONTINUE TRIAL I, Dmitry Stadlin, declare as follows: 1. I am an attorney licensed and/or admitted to practice before all the Courts of the State 0f California, the U.S. District Court 0f the Northern District 0f California, the Ninth Circuit Court of Appeals, and the U.S. Supreme Court. 2. I am the attorney of record in this case for Petitioner Alexis DaCosta (“Petitioner”). 3. I have personal knowledge 0f the facts stated herein, and if called upon to testify, I could and would competently testify thereto. 4. I make this declaration in support 0f Petitioner’s Opposition t0 Respondent’s Request t0 Continue Trial set for March 21, 2022 in this matter. 5. Petitioner objects t0 the Motion to Continue Trial. This case has already been continued several times and Petitioner’s litigation expenses are mounting. I see n0 good cause stated for a continuance in Respondent’s Request t0 continue trial. 6. There is currently a TRO protecting Petitioner and his Wife, Gurbir Mann. Respondent has issued subpoenas for Petitioner’s email accounts and all additional 1 DECLARATION OF DMITRY STADLIN IN SUPPORT OF PETITIONER’S OPPOSITION TO RESPONDENT’S EXPARTE REQUEST TO CONTINUE TRIAL ©OOQOUOTI-POONI-l NNNNNNNNNr-II-tr-Ir-II-tr-Ir-Ir-tr-II-t mflmmfiwNI-‘OCDOONGDmb-PCDNHO information as a means 0f further harassment, and is seeking materials that are not relevant at the trial. 7. I have filed a Motion t0 Quash, Which the Court set t0 be heard 0n the same date currently set for trial. The Court should hear that motion, grant the motion to Quash and proceed With the trial. 8. Respondent’s request t0 continue the trial is premature because it presupposes that the Court would deny the Motion to Quash and grant discovery t0 Respondent in a Civil Harassment Case Where there are n0 statutory rights to discovery. I declare under the penalty of perjury under the laws 0f the State of California that the foregoing is true and correct. Dated: February 7, 2022. Respectfully submitted, Dmitry Stadlin, Esq. Attorney for Petitioner ALEXIS DACOSTA 2 DECLARATION OF DMITRY STADLIN IN SUPPORT OF PETITIONER’S OPPOSITION TO RESPONDENT’S EXPARTE REQUEST TO CONTINUE TRIAL