DeclarationCal. Super. - 3rd Dist.November 25, 20191 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 REESE LAW GROUP Tristan P. Espinosa, Esq., Bar #312481 3168 Lionshead Ave Carlsbad CA 92010 760/842-5850 Attorneys for Plaintiff, STATE NATIONAL INSURANCE COMPANY SUPERIOR COURT OF CALIFORNIA, COUNTY OF PLACER ROSEVILLE BRANCH STATE NATIONAL INSURANCE COMPANY Plaintiff, v. JERRY DOMONIC VASQUEZ Defendants. Case No. MCV0075296 DECLARATION PURSUANT TO 1033(b) I, Tristan P. Espinosa, Esq., declare as follows: 1. I am an attorney licensed to practice before all of the Courts of the State of California. I am an attorney with the law firm of Reese Law Group, A Professional Law Corporation, the attorneys of record for the Plaintiff herein. I have been primarily responsible for monitoring and prosecuting this action on behalf of the Plaintiff. This Declaration is offered in support of Plaintiff's request for Court Judgment to include Plaintiff's costs pursuant to C.C.P. §1033. All of the facts set-forth below are known to me personally. If called upon to testify to the truth thereof, I could and would be willing to do so. 2. Plaintiff could not have brought the action within small claims court because it is a corporate entity, represented by counsel. Pursuant to C.C.P. §1033(b)(2), Plaintiff is limited to the actual cost of the filing fee, the actual cost of service of process, and when allowed by law, reasonable attorney fees. Declaration Pursuant to 1033(b) 11/02/2020 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on this _______________, at Carlsbad, California. Tristan P. Espinosa, Esq. Attorney for Plaintiff Declaration Pursuant to 1033(b) 3. On August 26, 2020, pursuant to C.C.P. §1033(b)(2), a demand letter was mailed to defendant. This letter informed the defendant of the intended legal action and the potential liabilityfor plaintiff's costs. A true and accurate copy of this demand letter is attached hereto and labeledas Exhibit "A". EXHIBIT A
