DeclarationCal. Super. - 6th Dist.February 17, 2021ATTORNEY 0R PARTY WTHOUT ATrORNEY (Nuns, Safe Bar nunbef, and address): STEPHANIE DAVIN (SBN 30791 1)_ RANKIN | STOCK | HEABERLIN l ONEAL 96 No. 3rd St. Suite 500, San Jose, CA 95112 mmmm: (408)293-0463 mxuoxopam (408)293-9514 I L Esmmoasssmpumao: stephanie@rankinstock.com . FEB l 7 2021 monnsv Fon (Name): R. Catholic Welfare Corp. of SJ. dba St. Lucy Sch] SUPERIOR COURT 0F CALIFORNIA, coum‘v 0F Santa Clara smEETAooREss: 191 N. First Street MAIUNGADDRESS: crrYAND ZIP coca: San Jose, California 951 13 men mas; Downtown Superior Court- Main Courthouse PLAINnFF/pETmONER: R. Catholic Welfare Corp. of S.J. dba St. Lucy Sc DEFENDANT/RESPONDENT: Sumati Panchal a.k.a. "Rose" DECLARATION I, Susan Grover declare: 1. I am currently principal of St. Lucy P 'sh School located at 76 Kennedy Ave. in Campbell, California, and have served in this capacity for the past é years. 2. St. Lucy Pan'sh School is directly adjacent to St. Lucy Parish. 2. For the past 4-5 years, St. Lucy Parish and School have been seeking proactive ways to work with Sumati Panchal, "Rose," in order to get her help and move her from living on the street. However, she seems unwilling to consider any social services offered to her. 3. Rose's behavior began with leaving boxes of food and loaded shopping carts around the Parish, hidden in bushes, in front of the church, between the church and the VTA, and then on the sidewalk in front of the church property. She eventually moved next to the School's fence. 4. Rose has consistently disregarded numerous requests to not bring boxes of perishable food, distribute this food, and/or leave this food on or near Parish and School grounds. Her refusal led to the Pan'sh to ask her not to come onto the grounds anymore, as it resulted in significant clean-up and health considerations at the Parish. 5. Once the School’s Pre-K class was allowed by the County to return to “in-class” instruction in August of 2020, the School asked her not to block the School’s front gate, the sidewalk by the School entrance, and the parking places in front of the School. This request was not only for her safety, but also for the safety of the children and the families dropping them off. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct Date: 2/ l 2/21 Susan Grover W (TYPE OR PRINT NAME) (SIGNATURE OF UECLARANT) D Attorney for D Plaintiff D Petitioner D Defendant D Respondent m Other (Specify): Protected Person Emir -':.'c.°’”°‘m"'”“ DECLARATION mum MC-antnova-ry 1.308] [rpyprem-napficv .. _. . _ l- . ._. . _ I f_.' é:'..’..‘:‘::'_;:.-"'I Inggwhat yqu entered 0n your. torm’,‘ please press the Clea'r This Form button Minheend oftheform whenflnlsh‘ed ., . ., ,. ,. ,. ‘ ._. _ PLAINTIFF/PETITIONER: R. Catholic Welfare Corp. of SJ. dba St. Lucy S CASE NUMBER: DEFENDANTIRESPONDENT: Sumati Panchal a.k.a. "Rose" DECLARATION (This form mus! be attached to another form or court paper befora it can be filed in court.) 6. Rose then moved around the comer to Industrial Ave, where she presently resides. With this move, Rose set up her home on the City of Campbell's property (sidewalk) just outside the School’s chain-link fence directly across fiom the door to the Kindergarten classroom. Notwithstanding many requests to remove her “supplies," Rose began to have perishable food items gathered, delivered, and stacked on the sidewalk daily. Her "supplies" were directly adjacent to the School property on Industrial Ave. She has had food delivered fiom unknown individuals for years, but now they deliver it right next to the St. Lucy School fence. She distributes and entertains those who need the food throughout the day and night. To block her activities from thc children’s view, the School had to hang tarps (3) on the fence, however, her many guests and thc boxcs of food delivered daily extend beyond the tarps. 7. School is now in session for “in-pcrson” instruction on weekdays from 8-2230pm. At least 7 times a day, Kindergarten and First Grade students use the exit and pass in close proximity to the piles of food and ofien unknown people who are dropping off these food items for Rose. Conversations between Rose and her guests are easily viewed and hear by the Kindergarten class as well as Grade 1-3 students who play on the playground next to the fence. Those who deliver the food, and the people who come to get the food, congregate and socialize during the day and night with Rose and do not wcar masks. 8. The safety of the children is of paramount importance to the Parish and School. 1n being allowed to reopen, the Parish and School have very specific and mandated State and local guidelines regarding cleanliness, social distancing, masks, etc. Rose and her guests have been witnessed many times not observing the mask and social distancing mandates. The sidewalk next to the School is cluttered with debris and old food boxes and it is very unsanitary. 9. In addition, there have been u'mes when the guests visiting Rose take the unpleasant liberty of using the bathroom in the middle of the street and in plain view of the School’s students. Needless to say, such behavior is seriously both disturbing and continuously concerning. There is literally no way to know who will show up to visit Rose, what they will bring, or what they will do in front of the School’s students. (Continued) I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Date: 2/ 1 2/21 Susan Grover W (TYPE OR PRINTM) (SIGNATURE 0F DECLARANT) D Attorney for D Plaintiff D Petitioner D Defendant D Respondent m Other (Specify): Protected Person Fmfimfi’ofls‘nfl“ MTACHED DECLARAHON M0031 (Ru. de 1.ml Pm. 1 d1 g- w .. 2 .2”; . ‘5 ..‘ rnzfi 4o" «4‘; -V w,_ 'r-Il’w: fl nuMow“Wan'wg&=£§@fim&¢w‘rm '::.=' 0.....- VLI- P__.__ I “.3... VLI- F-“ l I.AI--;V'T‘.1E;IH;:I