On August 14, 2020 a
Party Statement
was filed
involving a dispute between
Stephens, Donnetta,
and
Crown Ace Hardware,
Does 1 Through 100 Inclusive,
Monsato Company,
Wilbur-Ellis Company, Llc,
Wilbur-Ellis Nutrition, Llc,
for Product Liability Unlimited
in the District Court of San Bernardino County.
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ORIGINAL
Paul R. Kiesel (CA SBN 119854)
Melanie Meneses Palmer (CA SBN 286752)
KIESEL LAW LLP
8648 Wilshire Boulevard
DEC o1 2821
Beverly Hills, California 9021 1—2910
Tel: (310) 854-4444
Fax: (310) 854-0812
kiesel@kiesel.law
OOONOUI-PMNH
palmer@kiesel.law
William D. Shapiro, Esq.
Fletcher V. Trammell, Esq. Brian D. Shapiro, Esq.
FAX Melissa Binstock Ephron, Esq. Matthew D. Shapiro, Esq.
TRAMMELL, PC LAW OFFICES OF
BY
3262 Westheimer Rd., Ste. 423 WILLIAM D. SHAPIRO
Houston, TX 77098 893 East Brier Drive
Tel: (800) 405-1740 San Bernardino, CA 92408-2837
Fax: (800) 532-0992 Tel: (900) 890-1000
fletch@trammellpc.com Fax: (909) 890-1001
melissa@trammellpc.com bill@wshapiro.com
brian@wshapiro.com
Attorneysfor Plaintifl matt@wshapir0.com
DONNETTA STEPHENS
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO
DONNETTA STEPHENS, Case N0. CIVSB2104801
NNNNNNNNNH—AHp—‘p—HHHHH
OONOUl-hWNHOOOOVGMhUJNF-‘O
Plaintiff Assignedfor All Purposes t0 the Hon. Gilbert
G. Ochoa, Dept. S24
VS.
DECLARATION OF MELISSA
BINSTOCK EPHRON IN SUPPORT OF
MONSANTO COMPANY, ET AL., PLAINTIFF’S OPPOSITION TO
Defendants. MONSANTO COMPANY’S NOTICE OF
MOTION AND MOTION FOR
DIRECTED VERDICT AT THE CLOSE
OF EVIDENCE
Department: $24
Judge: Hon. Gilbert G. Ochoa
Complaint Filed: August 14, 2020
Trial Date: July l9, 2021
Declaration of Melissa Binstock Ephron
DECLARATION OF MELISSA BINSTOCK EPHRON
I, Melissa Binstock Ephron, declare and state:
1. I am an attorney admitted to practice law in the state of Texas and have pro hac vice
privileges in this case. I am an associate attorney at Trammell, P.C. and am one of the
©00N©U1$UJNH
attorneys 0f record for Plaintiff Donnetta Stephens (“Plaintiff”). I am over eighteen years 0f
age and am fully competent t0 make this Declaration in Support of Plaintiff’s Opposition to
Monsanto Company’s Motion for Directed Verdict at the Close 0f Evidence. Ihave personal
knowledge of the facts stated in this declaration, and if called to testify, I could and would
competently testify t0 the matters stated herein.
Attached hereto as Exhibit 1 is a true and correct copy 0f this Court’s July 19, 2021 Ruling
0n Motion for Summary Judgment/Adjudication in Stephens v. Monsanto.
Attached hereto as Exhibit 2 is a true and correct copy 0f this Court’s November 22, 2021
Ruling on Nonsuit in Stephens v. Monsanto.
Attached hereto as Exhibit 3 isa true and correct copy of this Court’s July 26, 2021 Sargon
Ruling in Stephens v.Monsanto.
Attached hereto as Exhibit 4 is a true and correct copy ofrelevant excerpts from the October
25, 2021 Trial Testimony inStephens v. Monsanto.
. Attached hereto as Exhibit 5
NNNNNNNNNh—‘Hp—Ab—dt—dt—It—Ip—twr—t
isa true and correct copy ofrelevant excerpts from the October
14, 2021 Trial Testimony in Stephens v. Monsanto.
Attached hereto as Exhibit 6
OONONMAWNHOCOOVQUl-PWN—‘O
isa true and correct copy ofrelevant excerpts from the October
19, 2021 Trial Testimony in Stephens v. Monsanto.
. Attached hereto as Exhibit 7 is a true and correct copy of relevant excerpts from Trial
Exhibit 1642 in Stephens v.Monsanto.
Attached hereto as Exhibit 9 is a true and correct copy of relevant excerpts from the
November 8, 2021 Trial Testimony inStephens v.Monsanto.
Attached hereto as Exhibit 10 is a true and correct copy 0f relevant excerpts from the
October 18, 2021 Trial Testimony in Stephens v. Monsanto.
10. Attached hereto as Exhibit 11 is a true and correct copy of relevant excerpts from the
October 20, 2021 Trial Testimony in Stephens v.Monsanto.
Declaration 0f Melissa Binstock Ephron
2
Document Filed Date
October 26, 2021
Case Filing Date
August 14, 2020
Category
Product Liability Unlimited
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ORIGINAL Paul R. Kiesel (CA SBN 119854) Melanie Meneses Palmer (CA SBN 286752) KIESEL LAW LLP 8648 Wilshire Boulevard DEC o1 2821 Beverly Hills, California 9021 1—2910 Tel: (310) 854-4444 Fax: (310) 854-0812 kiesel@kiesel.law OOONOUI-PMNH palmer@kiesel.law William D. Shapiro, Esq. Fletcher V. Trammell, Esq. Brian D. Shapiro, Esq. FAX Melissa Binstock Ephron, Esq. Matthew D. Shapiro, Esq. TRAMMELL, PC LAW OFFICES OF BY 3262 Westheimer Rd., Ste. 423 WILLIAM D. SHAPIRO Houston, TX 77098 893 East Brier Drive Tel: (800) 405-1740 San Bernardino, CA 92408-2837 Fax: (800) 532-0992 Tel: (900) 890-1000 fletch@trammellpc.com Fax: (909) 890-1001 melissa@trammellpc.com bill@wshapiro.com brian@wshapiro.com Attorneysfor Plaintifl matt@wshapir0.com DONNETTA STEPHENS SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO DONNETTA STEPHENS, Case N0. CIVSB2104801 NNNNNNNNNH—AHp—‘p—HHHHH OONOUl-hWNHOOOOVGMhUJNF-‘O Plaintiff Assignedfor All Purposes t0 the Hon. Gilbert G. Ochoa, Dept. S24 VS. DECLARATION OF MELISSA BINSTOCK EPHRON IN SUPPORT OF MONSANTO COMPANY, ET AL., PLAINTIFF’S OPPOSITION TO Defendants. MONSANTO COMPANY’S NOTICE OF MOTION AND MOTION FOR DIRECTED VERDICT AT THE CLOSE OF EVIDENCE Department: $24 Judge: Hon. Gilbert G. Ochoa Complaint Filed: August 14, 2020 Trial Date: July l9, 2021 Declaration of Melissa Binstock Ephron DECLARATION OF MELISSA BINSTOCK EPHRON I, Melissa Binstock Ephron, declare and state: 1. I am an attorney admitted to practice law in the state of Texas and have pro hac vice privileges in this case. I am an associate attorney at Trammell, P.C. and am one of the ©00N©U1$UJNH attorneys 0f record for Plaintiff Donnetta Stephens (“Plaintiff”). I am over eighteen years 0f age and am fully competent t0 make this Declaration in Support of Plaintiff’s Opposition to Monsanto Company’s Motion for Directed Verdict at the Close 0f Evidence. Ihave personal knowledge of the facts stated in this declaration, and if called to testify, I could and would competently testify t0 the matters stated herein. Attached hereto as Exhibit 1 is a true and correct copy 0f this Court’s July 19, 2021 Ruling 0n Motion for Summary Judgment/Adjudication in Stephens v. Monsanto. Attached hereto as Exhibit 2 is a true and correct copy 0f this Court’s November 22, 2021 Ruling on Nonsuit in Stephens v. Monsanto. Attached hereto as Exhibit 3 isa true and correct copy of this Court’s July 26, 2021 Sargon Ruling in Stephens v.Monsanto. Attached hereto as Exhibit 4 is a true and correct copy ofrelevant excerpts from the October 25, 2021 Trial Testimony inStephens v. Monsanto. . Attached hereto as Exhibit 5 NNNNNNNNNh—‘Hp—Ab—dt—dt—It—Ip—twr—t isa true and correct copy ofrelevant excerpts from the October 14, 2021 Trial Testimony in Stephens v. Monsanto. Attached hereto as Exhibit 6 OONONMAWNHOCOOVQUl-PWN—‘O isa true and correct copy ofrelevant excerpts from the October 19, 2021 Trial Testimony in Stephens v. Monsanto. . Attached hereto as Exhibit 7 is a true and correct copy of relevant excerpts from Trial Exhibit 1642 in Stephens v.Monsanto. Attached hereto as Exhibit 9 is a true and correct copy of relevant excerpts from the November 8, 2021 Trial Testimony inStephens v.Monsanto. Attached hereto as Exhibit 10 is a true and correct copy 0f relevant excerpts from the October 18, 2021 Trial Testimony in Stephens v. Monsanto. 10. Attached hereto as Exhibit 11 is a true and correct copy of relevant excerpts from the October 20, 2021 Trial Testimony in Stephens v.Monsanto. Declaration 0f Melissa Binstock Ephron 2