Declaration of Kristin T Busch Iso Reply To Plaintiffs Opposition To Countys Msj

Reply

Cal. Super. - 2nd Dist.May 4, 2017

Electronically FILED by Sup¢ a Ww oo 0 J S N W n 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 COLLINS COLLINS MUIR + STEWART. I or Court of California, County of Los Angeles on 06/07/2019 03:52 PM Sherri R. Carter, Executive Officer/Clerk of Court, by E. Salcido,Deputy Clerk Brian K. Stewart, Esq. (State Bar No. 126412) Kristin T. Busch, Esq. (State Bar No. 311772) COLLINS COLLINS MUIR + STEWART LLP 1100 El Centro Street South Pasadena, CA 91030 (626) 243-1100 - FAX (626) 243-1111 Exempt from Payment of Filing Fee Pursuant to Govt. Code § 6103. Attorneys for Defendant COUNTY OF LOS ANGELES SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES - LONG BEACH RICHARD PEREZ, an individual, CASE NO. BC660258 [Assigned to Mark C. Kim, Dept. S27] Plaintiff DECLARATION OF KRISTIN T. BUSCH IN SUPPORT OF REPLY TO PLAINTIFF’S OPPOSITION TO COUNTY’S MOTION FOR SUMMARY JUDGMENT, OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION VS. JAMES LEON THOMAS, J.R., an individual; STATE OF CALIFORNIA, a governmental agency; COUNTY OF LOS ANGELES, a governmental agency; LOS ANGELES COUNTY SHERIFF'S DEPARTMENT, a governmental agency; CITY OF LONG BEACH, a governmental agency; CITY OF LOS ANGELES, governmental agency, and DOES 1-100, [Concurrently filed with County’s Response to Plaintiff's Objections to County’s Evidence, County’s Response to Plaintiff's Response to Separate Statement and County’s Response to Plaintiff’s Additional Undisputed Material Facts, inclusive, Reply in support of Motion for Summary Judgment/Summary Adjudication, County’s Motion Defendants. to Strike and Objections to Plaintiff's Evidence; and, [Proposed] Order Re: County’s Motion to Strike and Objections to Plaintiff’s Evidence] COUNTY OF LOS ANGELES, DATE: 6/13/19 TIME: 8:30 a.m. DEPT.: S27 Cross-Complainant, Vs. Complaint Filed: 5/4/17 JAMES LEON THOMAS, JR., and ROES 1- ) Trial Date: 11/4/19 50, inclusive, Cross-Defendants. N a r N e N a N a N e N a N a N a N a N a N a N a N a N a N a N a N a N a N a N a N a N a N a N a N a N a SN N e N e N e 20599 1 DECLARATION OF BUSCH IN SUPPORT OF REPLY TO PLAINTIFF’S OPPOSITION a Ww oo 0 J S N W n 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 COLLINS COLLINS MUIR + STEWART. DECLARATION OF KRISTIN T. BUSCH I, Kristin T. Busch, declare as follows: I. I am an attorney duly licensed and admitted to the courts of the State of California. I am attorney with the law firm of Collins Collins Muir + Stewart, which represents Defendant Count of Los Angeles in this matter. I have personal knowledge of each fact stated in this Declaration. If called upon to testify regarding the matters herein, I could and would do so competently. I make this Declaration in support of County’s Reply to Plaintiff’s Opposition to Motion for Summary Judgment, or in the alternative, Motion for Summary Adjudication. 2. Plaintiff noticed the inspection of the involved County vehicle driven by Deputy Andrew Hagewood - the 2009 Ford Crown Victoria bearing CA Plate No. 1323439 (“Subject Vehicle”), held in storage. I was present at the inspection. Based upon information and belief, Plaintiff retained Joe Manning to perform this inspection. Mr. Manning did not submit any declaration in support of Plaintiff’s Opposition to County’s MSJ/MSA. 5 As of the date of this declaration, Plaintiff has not raised any issues with regard to the inspection of the Subject Vehicle. I declare under the penalty of perjury pursuant to the laws of the State of California that the foregoing is true and correct. Executed on June 7, 2019 at South Pasadena, California. KRISTIN T. BUSCH 20599 2 DECLARATION OF BUSCH IN SUPPORT OF REPLY TO PLAINTIFF’S OPPOSITION a Ww oo 0 J S N W n 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 COLLINS COLLINS MUIR + STEWART. PROOF OF SERVICE (CCP gg 1013(a) and 2015.5; FRCP 5) State of California, ) ss. County of Los Angeles ) I am employed in the County of Los Angeles. I am over the age of 18 and not a party to the within action. My business address is 1100 El Centro Street, South Pasadena, California 91030. On this date, I served the foregoing document described as DECLARATION OF KRISTIN T. BUSCH IN SUPPORT OF REPLY TO PLAINTIFF’S OPPOSITION TO COUNTY’S MOTION FOR SUMMARY JUDGMENT, OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION on the interested parties in this action by placing same in a sealed envelope, addressed as follows: Christopher T. Aumais, Esq. James Lee, Esq. Ashkahn Mohamadi, Esq. FRIEDENTHAL, HEFFERNAN & BROWN, LLP GIRARDI | KEESE 215 N. Marengo Ave., Suite 165 1126 Wilshire Blvd. Pasadena, CA 91101 Los Angeles, CA 90047 (626) 628-2800 - FAX: (626) 628-2828 (213) 977-0211 - FAX: (213) 481-1554 jlee@fthblawyers.com caumais@girardikeese.com ATTORNEYS FOR DEFENDANT JAMES LEON amohamadi@girardikeese.com THOMAS ATTORNEYS FOR PLAINTIFF RICHARD PEREZ 1 (BY MAIL) - I caused such envelope(s) with postage thereon fully prepaid to be placed in the United States mail in South Pasadena, California to be served on the parties as indicated on the attached service list. I am “readily familiar” with the firm’s practice of collection and processing correspondence for mailing. Under that practice, it would be deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid at South Pasadena, California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. [J] BY CERTIFIED MAIL) I caused such envelope(s) with postage thereon fully prepaid via Certified Mail Return Receipt Requested to be placed in the United States Mail in South Pasadena, California. 0 BY EXPRESS MAIL OR ANOTHER METHOD OF DELIVERY PROVIDING FOR OVERNIGHT DELIVERY 0 (BY ELECTRONIC FILING AND/OR SERVICE) - I served a true copy, with all exhibits, electronically on designated recipients listed on the attached Service List on: (Date) at (Time) [XI FEDERAL EXPRESS - I caused the envelope to be delivered to an authorized courier or driver authorized to receive documents with delivery fees provided for. [1 BY FACSIMILE) - I caused the above-described document(s) to be transmitted to the offices of the interested parties at the facsimile number(s) indicated on the attached Service List and the activity report(s) generated by facsimile number (626) 243-1111 indicated all pages were transmitted. [1 BY PERSONAL SERVICE) - I caused such envelope(s) to be delivered by hand to the office(s) of the addressees). Executed on June 7, 2019 at South Pasadena, California. [XI (STATE) - I declare under penalty of perjury under the laws of the State of California that the above is true and correct. [1] (FEDERAL) - I declare that am employed in the office of a member of the bar of this court at whose direction the service was made. DEBBIE PARKER 20599 3 DECLARATION OF BUSCH IN SUPPORT OF REPLY TO PLAINTIFF’S OPPOSITION