Document for Juanita Olson vs Lidia Ryan

• 
• 
• 
• 
• 
• 
• 
• 

						
                                
Preview
                                1    JOHN P. HANNON II
                        Law Offices of John P.       Hannon II
                   2    SB No:    111692
                        273 Knappton Road
                   3    Naselle, WA      98638
                        PH:   (831) 239-4898
                   4
                        E-Mail:    jph3002@yahoo.com
                   5
                        Attorney for Plaintiff:
                   6    JUANITA OLSON

                   7

                   8                      IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
                   9                                            COUNTY OF SANTA CRUZ
                 10
                 11     JUANITA OLSON,                                        )        CASE NO.: 21CV00921
                                                                              )
                 12                       Plaintiff,                          )        DECLARATION OF JOHN P. HANNON
                                                                              )        IN SUPPORT OF MOTION FOR
                 13     V.                                                    )        FURTHER DISCOVERY-SANCTIONS
                                                                              )
                 14     LIDIA RYAN, et al.,                                   )
                                                                              )
                 15                       Defendants.                         )
                 16                                                           )
                                                                              )        Hearing Date:              12/5/2022
                 17     AND RELATED CROSS-ACTION,                             )        Time:                      8:30 a.m.
                                                                                       Dept.:                     5
                 18                                                                    Judge:                     T. Volkmann
                 19              I, John P. Hannon II, declare that I am the attorney for Plaintiff, Juanita Olson.              I further
                 20     declare:

                 21              1.  The motion before this court seeks to strike the cross-complaint of Defendant.                 In this
                 22     cross-complaint, Defendant is seeking damages for alleged fraud on the part of Plaintiff.                  The facts
                 23     supporting such claims are largely unknown at this time.
                 24              2.  Defendant's deposition was set and reset on a number of occasions based upon various
                 25     communications from Defendant.            Ultimately, her deposition and the production of documents
                 26     was set for May 13, 2022.        Defendant did not appear at her deposition.
                 27              3.  On August 1, 2022, a motion to compel attendance at deposition was heard by this court
                 28     as an unopposed motion.        This court ordered that Defendant appear for her deposition within 30
                                                                                 -1-
                                                        EXHIBIT

                                                                        A
                                                        EXHIBIT

                                                                         B
                                                        EXHIBIT

                                                                        C
                                                        EXHIBIT

                                                                        D
                                                        EXHIBIT

                                                                        E
                                                        EXHIBIT

                                                                         F
                                                        EXHIBIT

                                                                        G
                                                       EXHIBIT

                                                                       H
                                                        EXHIBIT

                                                                         I
                                                        EXHIBIT

                                                                         J
                                                       EXHIBIT

                                                                       K
                                                        EXHIBIT

                                                                        L
                                                       EXHIBIT

                                                                      M
                                                       EXHIBIT

                                                                       N
                                                       EXHIBIT

                                                                        p
                                                       EXHIBIT


                                                                       Q
                                                       EXHIBIT

                                                                        s
                                                       EXHIBIT

                                                                       T