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  • David G Bertrand et al vs Jessica BerryUnlimited Defamation (13) document preview
  • David G Bertrand et al vs Jessica BerryUnlimited Defamation (13) document preview
  • David G Bertrand et al vs Jessica BerryUnlimited Defamation (13) document preview
  • David G Bertrand et al vs Jessica BerryUnlimited Defamation (13) document preview
  • David G Bertrand et al vs Jessica BerryUnlimited Defamation (13) document preview
  • David G Bertrand et al vs Jessica BerryUnlimited Defamation (13) document preview
  • David G Bertrand et al vs Jessica BerryUnlimited Defamation (13) document preview
  • David G Bertrand et al vs Jessica BerryUnlimited Defamation (13) document preview
						
                                

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CoC ON DW oO FW NY eB eS Coo N Do FF WwW DY bn YY YY NY NY WD orn A oO fF OH KFS ELECTRONICALLY FILED Superior Court of California County of Santa Barbara Mark T. Coffin, State Bar No. 168571 Darrel E. Parker, Executive Officer Scott A. Jaske, State Bar No. PL-461842 11/10/2021 3:46 PM MARK T. COFFIN, P.C. By: Narzralli Baksh, Deputy 21 E. Carrillo Street, Suite 240 Santa Barbara, California 93101 Telephone: (805) 248-7118 Facsimile: (866) 567-4028 Email: mtc@markcoffinlaw.com Email: scott@ markcoffinlaw.com Attomeys for Plaintiff DAVID G. BERTRAND and DOROTHY CHURCHILL-JOHNSON SUPERIOR COURT OF CALIFORNIA FOR THE COUNTY OF SANTA BARBARA DAVID G. BERTRAND, an Individual, Case No. 19CV02429 DOROTHY CHURCHILL-JOHNSON, an Individual, DECLARATION OF JASON oe STREATFEILD Plaintiff, Assigned for all purposes to the vs. Hon. Colleen K. Sterne JESSICA BERRY, an Individual, and DOES 1 Dept: 5 through 100, Inclusive, Complaint Date: May 7, 2019 Defendants. Trial Date: October 25, 2021 1 DECLARATION OF JASON STREATFEILDCoC ON DW oO FW NY eB eS Coo N Do FF WwW DY bn YY YY NY NY WD orn A oO fF OH KFS DECLARATION OF JASON STREATFEILD I, Jason Streatfeild, declare: If called upon as a wi except as to those stat to be true. . About five years ago, a rental lease for this ed upon information and belie! I rented a house in Montecito roperty, which has been occuy Chery] Streatfeild, and our two young daughters. C for Mr. Bertrand. . In approximately the had originally shown us the rental house. A true an , and as to those matters, I bel owned by Mr. David Bertran ied since that time by my ex- ery] now works as a personal . Tamacompetent adult, and I have personal knowledge of the facts stated in this Declaration. tness, I could and would competently testify to the truth of these facts, ieve them . Isigned wife, assistant ‘irst quarter of 2019, I received a text message from Jessica Berry, who correct copy of the text message I received is contained within the attached exhibit marked Exhibit 221, a copy of which is attache to this Declaration. . In her text message (Exb 221), Ms. Berry made several extremely derogatory statements about Mr. Bertrand, including: “David is Satan and his actions are CRIMINAL.” “He buys you off so he can abuse your family. If you have not seen his evil & learned from my abuse, than whatever happens to your girls is YOUR FAULT FOR NOT LISTENING AND RECOGNIZING WHAT HE HAS IRREFUTABLY DONE.” (Capitalized words in original.) . The text message (Exb. 221) continued: “YOU ARE FOLLOWING THE ALLURE OF HIS MONEY AND THE HOPE OF COMMISSION RATHER THAN RECOGNIZING THE CONTENT OF HIS CHARACTER. DAVID LOVES THAT YOU PIMP YOUR GIRLS OUT TO HIM IN THAT WAY. GUARANTEED. I SHOULD KNOW AFTER OVER A DECADE OF HIS ABUSE.” (Capitalization in original. . I was appalled to read this text. I had met Ms. Berry prev iously, but did not know her well. In particular, I interpreted her statement to Jason that “David loves that you pimp your girls out to him...” as implying that Mr. Bertrand was a pedop 2 ile and a sexual predator. DECLARATION OF JASON STREATFEILDCoC ON DW oO FW NY eB eS Coo N Do FF WwW DY bn YY YY NY NY WD orn A oO fF OH KFS 7. Ms. Berry’s text also implied that she had factual knowledge and experience to support these outrageous claims, by concluding her text with the statement: “It’s YOUR FAULT for not seeing the truth and hearing my alarm.” 8. I discussed this text with my ex-wife Cheryl, as to whether we should be concemed for the safety of our girls. Cheryl assured me she would be vigilant and would keep our daughters away from Mr. Bertrand’s house. 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 | O-2¢-1I ee , at Santa Barbara, California. 3 DECLARATION OF JASON STREATFEILDEXHIBIT 221 EXHIBIT 221al AT&T 2:06 PM Done 1 of 128 a ey +1 (650) 515-0161 > Oo @o cA o oO 5 “‘Q _v ~_ | SHOULD KNOW AFTER OVER A DECADE OF HIS ABUSE. It's YOUR FAULT for not seeing the truth and hearing my alarm. a © ¢ BEA a Aa V7 48% @_) net tRAND Exb 221-1 :— BERT 00168