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ELECTRONICALLY FILED
Superior Court of California
County of Santa Barbara
Mark T. Coffin, State Bar No. 168571 Darrel E. Parker, Executive Officer
1 MARK T. COFFIN, P.C. 10/6/2020 4:46 PM
2 21 E. Carrillo Street, Suite 240 By: Terri Chavez, Deputy
Santa Barbara, California 93101
3 Telephone: (805) 248-7118
Facsimile: (866) 567-4028
4 Email: mtc@markcoffinlaw.com
5 Attorneys for Plaintiff DAVID G. BERTRAND and DOROTHY CHURCHILL-JOHNSON
6
7 SUPERIOR COURT OF CALIFORNIA
8 FOR THE COUNTY OF SANTA BARBARA
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10 DAVID G. BERTRAND, an Individual, Case No. 19CV02429, Related to
DOROTHY CHURCHILL-JOHNSON, an Case No. 19CV02357
11 Individual,
DECLARATION OF BRITTANY
12 Plaintiff, BRYAN, M.D., IN SUPPORT OF
13 vs. MOTION FOR TRIAL SETTING
PREFERENCE
14 JESSICA BERRY, an Individual, and DOES 1
through 100, Inclusive,
15 Assigned for all purposes to the
Defendants. Hon. Colleen K. Sterne
16 Dept: 5
Complaint Date: May 7, 2019
17 Trial Date: No Trial Date Set
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DECLARATION OF BRITTANY BRYAN, M.D., IN SUPPORT OF
MOTION FOR TRIAL SETTING PREFERENCE
DECLARATION OF BRITTANY BRYAN. M.D.. IN SUPPORT OF
MOTION FOR TRIAL SETTING PREFERENCE
1. Brittany Bryan. M.D.. declare:
1. I am a competent adult. and I have personal knowledge of the facts stated in this Declaration.
If called upon as a witness. I could and would competently testify to the truth of these facts.
except as to those stated upon information and belief. and as to those matters. I believe them
to be true. This Declaration is made in support of David Bertrand’s Motion for Trial Setting
Preference.
I am Board certified in Internal Medicine in the State of California, and have been practicing
as a licensed medical doctor in C alifomia for seven years. My practice is located in Santa
11 Barbara. California. and David Bertrand has been my patient since 12/3/2018.
12 DJ
Mr. Bertrand is currently 91 years old, and has several medical issues including coronary
13 anery disease with prior heart attack and stent placement. hypertension, high cholesterol.
14 glaucoma, and severe back pain.
15 I understand that the criteria for this motion requires consideration of whether Mr. Bertrand’s
16 health “is such that a preference is necessary to prevent prejudicing the party’s interest in the
17 litigation." In my professional opinion. Ms. Bertrand’s medical condition satisfies this
18 criteria, and he would benefit from an expeditious trial date.
19 I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct. and that this Declaration was executed on 9/28/2020 .at
21 _Santa Barbara . California.
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23 Brittany Bryan. M.D., Declarant
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DECLARATION OF BRITTANYHBRYAN, M.D.. IN SUPPORT OF
MOTION FOR TRIAL SETTING PREFERENCE
PROOF OF SERVICE
STATE 01" CALIFORNIA, COUNTY OF SANTA BARBARA
I am employed in the Count;-{ of Santa I:}aIl:Jara= State ul‘Calilhmia. T am over the age of 18
years and not a party to this ac’rion. My businesas:address is 21 E. Carrillo Street, Suite 240, Santa
Barbara, California 93101. On October 6, 2020, I sawed thfi foregoing documents described as
DECLARATION OF BRITTANY BRYAN, M.D., IN SUPPORT OF MOTION FOR TRIAL
SETTING PREFERENCE, on the interestcd parties in this action:
Address Part},r
Jessica Berry Jcésica Berry
PO. Box JESSICH BEER}: In pro per (Dafaman'nn).
54E PO. Box 432
Santa Yncz, CA 93460 Solvang, CA 93464
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Ian Kaesmfir, Esq. Arromeyfor Respondent, JESSICA BEER Y
11 GEIITTEILMAN, UHl'I"I‘ERMAN 3L FFTD _
413 u. Canon Pcrdidn 51. {LC Apperrb.
12 Santa Barbara, CA 9310]
E: j an rEilghi Llenna11.c0m
13
I4
15 BY “.5. MAIL: This ducummt was served by United States mail thmugh the [IS 1305:1211
w; Sen-'10:. l enclosed the document in a sealed envelope or package addressed to the pcrsonfi)
16 at the address(es) above and placed the cnvelnpds} for collection and mailing, following our
mrdinarjr business practices. I am rfiadily familiar with this firm’s practice nf'cnllecting and
17 processing correspondence For mailing, On the same day that correspondence is placed for
collection and mailing, itis deposited in Lhe ordinary course of business with the United
13 Postal Service ar Santa Barbara, California, in a sealed envelope with postage [11i
Smiles
pa: _
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El BY FACSIMILE: The documenfls) were served by facsimile. Th6 facsimile transmission
20 was without error and completed prior to 5:00 pm. A copy of' the transmission report is
available upon request.
21
M VIA EMAIL: I served the documents ahnvc on all parties via electronic mail, to the
22 addresses as ]isLed on the attached service list, following my employer’s business practice for
collection and processing ofcor'respflndence. Such electronic transmission was reported as
23 complete and without error on this data
24 El (State) I declare under penalty of periury under the laws of the State of California that the
Ehregoing is true and corn-:cL,
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Executed on October 6, 2020, at Santa Barbara, California.
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27 a." 2) AMA
Emit A. Jaskc
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DECLARATION OF BRITTANY: BRYAN. M.fi.',TN gUfii‘I’fifi'T-fiiim
MOTION FOR TRIAL SETTING PREFERENCE
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ELECTRONICALLY FILED Superior Court of California County of Santa Barbara Mark T. Coffin, State Bar No. 168571 Darrel E. Parker, Executive Officer 1 MARK T. COFFIN, P.C. 10/6/2020 4:46 PM 2 21 E. Carrillo Street, Suite 240 By: Terri Chavez, Deputy Santa Barbara, California 93101 3 Telephone: (805) 248-7118 Facsimile: (866) 567-4028 4 Email: mtc@markcoffinlaw.com 5 Attorneys for Plaintiff DAVID G. BERTRAND and DOROTHY CHURCHILL-JOHNSON 6 7 SUPERIOR COURT OF CALIFORNIA 8 FOR THE COUNTY OF SANTA BARBARA 9 10 DAVID G. BERTRAND, an Individual, Case No. 19CV02429, Related to DOROTHY CHURCHILL-JOHNSON, an Case No. 19CV02357 11 Individual, DECLARATION OF BRITTANY 12 Plaintiff, BRYAN, M.D., IN SUPPORT OF 13 vs. MOTION FOR TRIAL SETTING PREFERENCE 14 JESSICA BERRY, an Individual, and DOES 1 through 100, Inclusive, 15 Assigned for all purposes to the Defendants. Hon. Colleen K. Sterne 16 Dept: 5 Complaint Date: May 7, 2019 17 Trial Date: No Trial Date Set 18 19 20 21 22 23 24 25 26 27 28 1 DECLARATION OF BRITTANY BRYAN, M.D., IN SUPPORT OF MOTION FOR TRIAL SETTING PREFERENCE DECLARATION OF BRITTANY BRYAN. M.D.. IN SUPPORT OF MOTION FOR TRIAL SETTING PREFERENCE 1. Brittany Bryan. M.D.. declare: 1. I am a competent adult. and I have personal knowledge of the facts stated in this Declaration. If called upon as a witness. I could and would competently testify to the truth of these facts. except as to those stated upon information and belief. and as to those matters. I believe them to be true. This Declaration is made in support of David Bertrand’s Motion for Trial Setting Preference. I am Board certified in Internal Medicine in the State of California, and have been practicing as a licensed medical doctor in C alifomia for seven years. My practice is located in Santa 11 Barbara. California. and David Bertrand has been my patient since 12/3/2018. 12 DJ Mr. Bertrand is currently 91 years old, and has several medical issues including coronary 13 anery disease with prior heart attack and stent placement. hypertension, high cholesterol. 14 glaucoma, and severe back pain. 15 I understand that the criteria for this motion requires consideration of whether Mr. Bertrand’s 16 health “is such that a preference is necessary to prevent prejudicing the party’s interest in the 17 litigation." In my professional opinion. Ms. Bertrand’s medical condition satisfies this 18 criteria, and he would benefit from an expeditious trial date. 19 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. and that this Declaration was executed on 9/28/2020 .at 21 _Santa Barbara . California. 22 3 7 23 Brittany Bryan. M.D., Declarant 24 25 26 27 28 7 DECLARATION OF BRITTANYHBRYAN, M.D.. IN SUPPORT OF MOTION FOR TRIAL SETTING PREFERENCE PROOF OF SERVICE STATE 01" CALIFORNIA, COUNTY OF SANTA BARBARA I am employed in the Count;-{ of Santa I:}aIl:Jara= State ul‘Calilhmia. T am over the age of 18 years and not a party to this ac’rion. My businesas:address is 21 E. Carrillo Street, Suite 240, Santa Barbara, California 93101. On October 6, 2020, I sawed thfi foregoing documents described as DECLARATION OF BRITTANY BRYAN, M.D., IN SUPPORT OF MOTION FOR TRIAL SETTING PREFERENCE, on the interestcd parties in this action: Address Part},r Jessica Berry Jcésica Berry PO. Box JESSICH BEER}: In pro per (Dafaman'nn). 54E PO. Box 432 Santa Yncz, CA 93460 Solvang, CA 93464 10 Ian Kaesmfir, Esq. Arromeyfor Respondent, JESSICA BEER Y 11 GEIITTEILMAN, UHl'I"I‘ERMAN 3L FFTD _ 413 u. Canon Pcrdidn 51. {LC Apperrb. 12 Santa Barbara, CA 9310] E: j an rEilghi Llenna11.c0m 13 I4 15 BY “.5. MAIL: This ducummt was served by United States mail thmugh the [IS 1305:1211 w; Sen-'10:. l enclosed the document in a sealed envelope or package addressed to the pcrsonfi) 16 at the address(es) above and placed the cnvelnpds} for collection and mailing, following our mrdinarjr business practices. I am rfiadily familiar with this firm’s practice nf'cnllecting and 17 processing correspondence For mailing, On the same day that correspondence is placed for collection and mailing, itis deposited in Lhe ordinary course of business with the United 13 Postal Service ar Santa Barbara, California, in a sealed envelope with postage [11i Smiles pa: _ 19 El BY FACSIMILE: The documenfls) were served by facsimile. Th6 facsimile transmission 20 was without error and completed prior to 5:00 pm. A copy of' the transmission report is available upon request. 21 M VIA EMAIL: I served the documents ahnvc on all parties via electronic mail, to the 22 addresses as ]isLed on the attached service list, following my employer’s business practice for collection and processing ofcor'respflndence. Such electronic transmission was reported as 23 complete and without error on this data 24 El (State) I declare under penalty of periury under the laws of the State of California that the Ehregoing is true and corn-:cL, 25 Executed on October 6, 2020, at Santa Barbara, California. 26 _ M 27 a." 2) AMA Emit A. Jaskc 23 1 DECLARATION OF BRITTANY: BRYAN. M.fi.',TN gUfii‘I’fifi'T-fiiim MOTION FOR TRIAL SETTING PREFERENCE