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1 Michael D. Mortenson, State Bar No. 247758
mmortenson@mortensontaggart.com
2 Craig A. Taggart, State Bar No. 239168
ctaggart@mortensontaggart.com
3 David M. Keithly, State Bar No. 292101
dkeithly@mortensontaggart.com
4 Hannah L. Miller, State Bar No. 333843
hmiller@mortensontaggart.com
5 MORTENSON TAGGART ADAMS LLP
300 Spectrum Center Dr., Suite 1200
6 Irvine, CA 92618
Telephone: (949) 774-2224
7 Facsimile: (949) 774-2545
8 Attorneys for Defendants
FORD MOTOR COMPANY and
9 JIM BURKE FORD
10
SUPERIOR COURT OF THE STATE OF CALIFORNIA
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FOR THE COUNTY OF KERN
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13 KARINA VARGAS, GONZALO VARGAS, Case No. BCV-22-101682-JEB
and LIVIER VARGAS, Hon. J. Eric Bradshaw
14 Dept. J
Plaintiffs,
15
vs. DECLARATION OF HANNAH L.
16 MILLER PURSUANT TO C.C.P. §
FORD MOTOR COMPANY; JIM BURKE C.C.P. § 430.41(A)(2) REGARDING
17 FORD; and DOES 1 through 10, inclusive, DEFENDANTS’ GOOD FAITH
ATTEMPT TO MEET AND CONFER
18 Defendants. IN ADVANCE OF DEMURRER
19
20
21 Complaint Filed: July 7, 2022
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25
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DECLARATION OF HANNAH L. MILLER PURSUANT TO C.C.P. § 430.41(A)(2)
1 DECLARATION OF HANNAH L. MILLER
2 I, Hannah L. Miller, declare and state as follows:
3 1. I am an attorney authorized to practice law in the State of California and admitted
4 to practice before this Court. I am an attorney at Mortenson Taggart Adams LLP, and I am an
5 attorney for Defendants Ford Motor Company (“Ford”) and Jim Burke Ford (collectively,
6 “Defendants”) in this case. I make this declaration based on my personal knowledge, the record
7 in this action, and the matters of public record, and ifcalled upon as a witness, I could and
8 would testify competently as to the matters discussed herein.
9 2. On July 7, 2022, Plaintiffs Karina Vargas, Gonzalo Vargas, and Livier Vargas
10 (“Plaintiffs”) filed their Complaint. Defendants were served on August 3, 2022; therefore,
11 Defendants’ deadline to respond to the complaint is September 2, 2022.
12 3. Pursuant to C.C.P. § 430.41, Defendants must meet and confer prior to filing a
13 demurrer.
14 4. On August 23 and 25, 2022, I reached out to meet and confer with Plaintiffs’
15 counsel via email to meet and confer telephonically. To date, I have not received any response
16 to our request to meet and confer.
17 5. This declaration is being filed in advance of Defendants’ deadline to respond to
18 the Complaint and following Defendants’ good faith attempt, but inability, to meet and confer
19 with Plaintiffs prior to the filing of a demurrer.
20 6. Pursuant to section 430.41, Defendants are entitled to an automatic 30-day
21 extension of their deadline to respond to the Complaint. Defendants’ deadline to respond is
22 now October 3, 2022.
23 I declare under penalty of perjury pursuant to the laws of the United States of America
24 and the State of California that the foregoing is true and correct.
25 Executed on August 29, 2022, at Irvine, California.
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28 Hannah L. Miller
-1-
DECLARATION OF HANNAH L. MILLER PURSUANT TO C.C.P. § 430.41(A)(2)
PROOF OF SERVICE
1
STATE OF CALIFORNIA )
2 ) ss
COUNTY OF ORANGE )
3
I am employed by Mortenson Taggart Adams LLP in the County of Orange, State of
4 California. I am over the age of 18 and not a party to the within action. My business address
is: 300 Spectrum Center Drive, Suite 1200, Irvine, CA 92618. On August 29, 2022, I served
5 the within documents:
6 DECLARATION OF HANNAH L. MILLER PURSUANT TO C.C.P. § C.C.P. §
430.41(A)(2) REGARDING DEFENDANTS’ GOOD FAITH ATTEMPT TO MEET
7 AND CONFER IN ADVANCE OF DEMURRER
8 By electronic service by transmitting via my electronic service address
9 (amacdonald@mortensontaggart.com) the document(s) listed above to the
person(s) at the e-mail address(es) set forth below.
10
Tionna Dolin
11 STRATEGIC LEGAL PRACTICES, APC
1888 Century Park East, 19th Floor
12 Los Angeles, CA 90067
Telephone: (310) 929-4900
13 Facsimile: (310) 943-3838
emailservices@slpattorney.com
14
ATTORNEY FOR PLAINTIFF
15
16 I declare that I am employed in the office of a member of the bar of this court whose
direction the service was made. I declare under penalty of perjury under the laws of the State
17 of California that the above is true and correct.
18 Executed on August 29, 2022, at Irvine, California.
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20 Alissa Macdonald
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PROOF OF SERVICE
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1 Michael D. Mortenson, State Bar No. 247758 mmortenson@mortensontaggart.com 2 Craig A. Taggart, State Bar No. 239168 ctaggart@mortensontaggart.com 3 David M. Keithly, State Bar No. 292101 dkeithly@mortensontaggart.com 4 Hannah L. Miller, State Bar No. 333843 hmiller@mortensontaggart.com 5 MORTENSON TAGGART ADAMS LLP 300 Spectrum Center Dr., Suite 1200 6 Irvine, CA 92618 Telephone: (949) 774-2224 7 Facsimile: (949) 774-2545 8 Attorneys for Defendants FORD MOTOR COMPANY and 9 JIM BURKE FORD 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA 11 FOR THE COUNTY OF KERN 12 13 KARINA VARGAS, GONZALO VARGAS, Case No. BCV-22-101682-JEB and LIVIER VARGAS, Hon. J. Eric Bradshaw 14 Dept. J Plaintiffs, 15 vs. DECLARATION OF HANNAH L. 16 MILLER PURSUANT TO C.C.P. § FORD MOTOR COMPANY; JIM BURKE C.C.P. § 430.41(A)(2) REGARDING 17 FORD; and DOES 1 through 10, inclusive, DEFENDANTS’ GOOD FAITH ATTEMPT TO MEET AND CONFER 18 Defendants. IN ADVANCE OF DEMURRER 19 20 21 Complaint Filed: July 7, 2022 22 23 24 25 26 27 28 DECLARATION OF HANNAH L. MILLER PURSUANT TO C.C.P. § 430.41(A)(2) 1 DECLARATION OF HANNAH L. MILLER 2 I, Hannah L. Miller, declare and state as follows: 3 1. I am an attorney authorized to practice law in the State of California and admitted 4 to practice before this Court. I am an attorney at Mortenson Taggart Adams LLP, and I am an 5 attorney for Defendants Ford Motor Company (“Ford”) and Jim Burke Ford (collectively, 6 “Defendants”) in this case. I make this declaration based on my personal knowledge, the record 7 in this action, and the matters of public record, and ifcalled upon as a witness, I could and 8 would testify competently as to the matters discussed herein. 9 2. On July 7, 2022, Plaintiffs Karina Vargas, Gonzalo Vargas, and Livier Vargas 10 (“Plaintiffs”) filed their Complaint. Defendants were served on August 3, 2022; therefore, 11 Defendants’ deadline to respond to the complaint is September 2, 2022. 12 3. Pursuant to C.C.P. § 430.41, Defendants must meet and confer prior to filing a 13 demurrer. 14 4. On August 23 and 25, 2022, I reached out to meet and confer with Plaintiffs’ 15 counsel via email to meet and confer telephonically. To date, I have not received any response 16 to our request to meet and confer. 17 5. This declaration is being filed in advance of Defendants’ deadline to respond to 18 the Complaint and following Defendants’ good faith attempt, but inability, to meet and confer 19 with Plaintiffs prior to the filing of a demurrer. 20 6. Pursuant to section 430.41, Defendants are entitled to an automatic 30-day 21 extension of their deadline to respond to the Complaint. Defendants’ deadline to respond is 22 now October 3, 2022. 23 I declare under penalty of perjury pursuant to the laws of the United States of America 24 and the State of California that the foregoing is true and correct. 25 Executed on August 29, 2022, at Irvine, California. 26 27 28 Hannah L. Miller -1- DECLARATION OF HANNAH L. MILLER PURSUANT TO C.C.P. § 430.41(A)(2) PROOF OF SERVICE 1 STATE OF CALIFORNIA ) 2 ) ss COUNTY OF ORANGE ) 3 I am employed by Mortenson Taggart Adams LLP in the County of Orange, State of 4 California. I am over the age of 18 and not a party to the within action. My business address is: 300 Spectrum Center Drive, Suite 1200, Irvine, CA 92618. On August 29, 2022, I served 5 the within documents: 6 DECLARATION OF HANNAH L. MILLER PURSUANT TO C.C.P. § C.C.P. § 430.41(A)(2) REGARDING DEFENDANTS’ GOOD FAITH ATTEMPT TO MEET 7 AND CONFER IN ADVANCE OF DEMURRER 8 By electronic service by transmitting via my electronic service address 9 (amacdonald@mortensontaggart.com) the document(s) listed above to the person(s) at the e-mail address(es) set forth below. 10 Tionna Dolin 11 STRATEGIC LEGAL PRACTICES, APC 1888 Century Park East, 19th Floor 12 Los Angeles, CA 90067 Telephone: (310) 929-4900 13 Facsimile: (310) 943-3838 emailservices@slpattorney.com 14 ATTORNEY FOR PLAINTIFF 15 16 I declare that I am employed in the office of a member of the bar of this court whose direction the service was made. I declare under penalty of perjury under the laws of the State 17 of California that the above is true and correct. 18 Executed on August 29, 2022, at Irvine, California. 19 20 Alissa Macdonald 21 22 23 24 25 26 27 28 PROOF OF SERVICE