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JOHN P. HANNON II
Law Offices of John P. Hannon II
SB No: 111692
273 Knappton Road
Naselle, WA 98638
PH: (831) 239-4898
E-Mail: jph3003@yahoo.com
Attorney for Plaintiff:
JUANITA OLSON
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SANTA CRUZ
JUANITA OLSON, ) Case No: 21CV00921
)
Plaintiffs, )
) DECLARATION REGARDING
v. ) COMPLIANCE WITH CRC 3.1312
)
LIDIA RYAN, )
)
Defendant, )
) Hearing Date: 9/8/2022
) Time: 8:30 a.m.
AND RELATED CROSS-ACTION ) Dept.: 5
) Judge: T. Volkmann
I, John P. Hannon II, hereby declare:
1. Concurrent with the filing of this declaration, I am submitting to this court a proposed
order from the hearing held on September 8, 2022.
2. The court should note that I sent a standard e-mail to Defendant, Lidia Ryan, on
September 28, 2022, in compliance with California Rules of Court, Rule 3.1312, seeking her
comments on the proposed order. (A true and correct copy of this transmittal e-mail is attached
hereto as Exhibit A.) Along with the proposed order I sent a copy of the tentative ruling of this
court.
3. Ms. Ryan responded by e-mail on September 28, 2022. (A true and correct copy of this
e-mail from Ms. Ryan to me dated September 28, 2022, is attached hereto as Exhibit B.)4. I responded to the e-mail of Ms. Ryan also on September 28, 2022. (A true and correct
copy of my e-mail to Ms. Ryan of September 28, 2022, is attached hereto as Exhibit C)
5. Given the position of Ms. Ryan that she objects to all proceedings before this court, I do
not believe any more efforts to meet and confer would be fruitful. I ask the court to sign the order
after hearing in its current form.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct. pea,
Dated: Sa / 25
JOHN P. HANNON IT
Attorney for Plaintiff:
JUANITA OLSONEXHIBIT
A9/28/22, 5:29 PM Yahoo Mail - order after hearing
order after hearing
From: John Hannon (jph3003@yahoo.com)
To: triver.ryan@gmail.com
Cc: jmorockon@gmail.com
Date: Wednesday, September 28, 2022 at 11:37 AM PDT
Dear Ms. Ryan:
| am attaching an amended proposed order after hearing from the matter heard on September 8, 2022. There was an
eror in the caption of the prior order. | am again attaching the tentative ruling.
Please review the Proposed order regarding its accuracy as to the orders made by the court. If you beleive there should
be any changes, please contact me within 5 days. If you believe the order is accurate as to what the judge ordered,
please sign and send me the signature page.
If | do not receive any contact from you, the matter will be submitted direclty to the court.
JOHN P. HANNON II
Attorney at Law
Law Offices of John P. Hannon II
273 Knappton Road
Naselle, WA 98638
E-mail: joh3003@yahoo.c
Phone: (831) 239-4898
PLEASE NOTE NEW ADDRESS.
The information contained in this email message may be privileged, confidential and protected from disclosure. If you
are not the intended recipient of this email, any dissemination or copying of this information is Strictly prohibited. If you
think you received this email in error, please contact the sender at the address or phone number above.
[+] 9.27.22. olson tentative ruling_0001.pdf
402.9kB
[x] order after hearing 9.8,22.pdf
72.1kB
about:blankEXHIBIT
B9/28/22, 5:28 PM Yahoo Mail - Re: order after hearing
Re: order after hearing
From: Lryan Ryan (rriver.ryan@gmail.com)
To: jph3003@yahoo.com
Cc: jmorockon@gmail.com
Date: Wednesday, September 28, 2022 at 02:24 PM PDT
Mr. Hannon,
| have opposed every one of your Motions to Compel and the Tentative Rulings along with this
latest financial demand.
This is quite a business you have going Mr. Hannon.
Your intimidation by flooding my email with threats, lies and bills has benefitted you greatly.
| will need an acknowledgement once the check is received so | will have the check sent to your
Washington address and it will require a signature of acknowledgement.
As | requested prior and you ignored, my doctor requested permission by you Mr. Hannon to send
her correspondences and updates.
Again, does my Doctor have permission to send you letters and to this address?
In the letter, my doctor is asking for a 2 month Pause for my body and mind to heal.
As Judge Volkmann said when he looked your client straight in the eyes 3 times
“the house will be sold.” Hopefully your client is packing and preparing to move.
My husband would like to remove all our personal property asap.
Please select which works for your client as she will need to leave while he is packing our
personal belongings.
Available weekends to pick up personal items etc: October 1,2 October 12,16
October 29, 30 every weekend in November except Thanksgiving weekend.
Kindly notify me which weekend will work for you client.
Regards,
Lidia Ryan
On Wed, Sep 28, 2022 at 11:37 AM John Hannon wrote:
Dear Ms, Ryan:
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about:blank 29/28/22, 5:28 PM
| | am attaching an amended
Please review the proposed
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| |
i |
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| | JOHN P. HANNON II
| | Attorney at Law
| 273 Knappton Road
| Naselle, WA 98638
|
E-mail: jph3003@yahoo.
Phone: (831) 239-4898
Yahoo Mail - Re: order after hearing
proposed order after hearing from the matter heard on September 8, 2022. There
| Was an eror in the caption of the prior order. | am again attaching the tentative ruling.
order regarding its accuracy as to the orders made by the court. If you beleive there
should be any changes, please contact me within 5 days. If you believe the order is accurate as to what the judge
ordered, please sign and send me the signature page.
If | do not receive any contact from you, the matter will be submitted direclty to the court.
Law Offices of John P. Hannon II
PLEASE NOTE NEW ADDRESS.
The information contained in this email message may be privileged, confidential and protected from disclosure. If
| you are not the intended recipient of this email, any dissemination or copying of this information is strictly
prohibited. If you think you re
| | above.
about:blank
eceived this email in error, please contact the sender at the address or phone number
2/2EXHIBIT
C9/28/22, 5:29 PM Yahoo Mail - Order after hearing
Order after hearing
From: John Hannon (jph3003@yahoo.com)
To: triver.ryan@gmail.com
Bcc: jmorockon@gmail.com
Date: Wednesday, September 28, 2022 at 05:28 PM PDT
Dear Ms. Ryan:
| am in receipt of your e-mail of this date.
First, you have copied this e-mail to my client. As | have repeatedly stated to you, the copying of documents to my client
is a violation of the existing restraining order. In particular, Paragraph 9 of the restraining order states:that you may not
contact Ms. Olson either "directly or indirectly, by an means, includigby telephone, mail, email, or other electronic
process."
This is the last time | am going to warn you about your sending courtesy copies of e-mails to Ms. Olson. The next time
that you violate the court order the appropriate action will be taken.
If you have personal possions in the home, please provide a list. My client will examinje this list and send to you those
items which she believes are legitimately your Property. As to the matters over which there is a dispute, we can take
these items up with the judge.
Again, | want to reiterate that the existing order prevents you or anyone on your behalf from contacting Ms. Olson. If
your husband, or some other perosn woerking on your behalf, shows up at Ms. Olson's door such action would be a
violation jof the existing restraining order.
Second, to claim that your doctors need my approval to send me letters is another silly position. First, under the medical
Privacy act, the privilege belongs to you. Second, you affirmatively represented to the court that you had doctor letters
in your possession and that you would provide these letters by the end of the day on September 8, 2022. In fact, the
court ordered you to provide me iwth copies of these letters by the close of business on
Third, you were ordered to pay sanctions in both the restraining order matter as well as the two discovery motions. | do
not have to jump through a series of hoops for you to obeys these orders. | suggrest that you put as much time into
complying with your obligations under the law as you put into sending me belitting and false statements.
The purpose of sending you a draft Copy of the proposed order is for you to provide corrections or additions to the order
so that the order reflects what happened in court. It is not an excuse for you to create issues or personally attack me.
| will submit the order after heairng along with a copy of your e-mail and this responsive e-mail at this time.
Your attention to this matter is appreciated.
JOHN P. HANNON II
Attorney at Law
Law Offices of John P. Hannon II
273 Knappton Road
Naselle, WA 98638
E-mail: jph3003@yahoo.com
Phone: (831) 239-4898
about:blank9/28/22, 5:29 PM
PLEASE NOTE NEW ADDRESS.
The information contained in this email messa
are not the intended recipient of this email, an
think you received this email in error, please c
about:blank
Yahoo Mail - Order after hearing
ge may be privileged, confidential and protected from disclosure. If you
y dissemination or copying of this information is strictly prohibited. If you
‘ontact the sender at the address or phone number above.
2/2PROOF OF SERVICE BY MAIL AND E-MAIL
The undersigned hereby declares that he/she is over the age of 18 years and not a party
to the action. The undersigned’s business address is 273 Knappton Road, Naselle, WA 98638.
On the date last written, the undersigned delivered the following document(s):
Declaration Regarding Compliance with CRC 3.1312
by personally mailing, by first class mail, postage prepaid, and by e-mailing the above listed
document(s) on the same date of signature hereto to the address(es) and e-mail(s) set forth:
Lidia Ryan
3970 Harney Street
San Diego, CA 92110
E-mail: rriver.ryan@gmail.com
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
Dated: qlee 2e BY:
JOHN P. HANNON II
Preview
JOHN P. HANNON II Law Offices of John P. Hannon II SB No: 111692 273 Knappton Road Naselle, WA 98638 PH: (831) 239-4898 E-Mail: jph3003@yahoo.com Attorney for Plaintiff: JUANITA OLSON IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CRUZ JUANITA OLSON, ) Case No: 21CV00921 ) Plaintiffs, ) ) DECLARATION REGARDING v. ) COMPLIANCE WITH CRC 3.1312 ) LIDIA RYAN, ) ) Defendant, ) ) Hearing Date: 9/8/2022 ) Time: 8:30 a.m. AND RELATED CROSS-ACTION ) Dept.: 5 ) Judge: T. Volkmann I, John P. Hannon II, hereby declare: 1. Concurrent with the filing of this declaration, I am submitting to this court a proposed order from the hearing held on September 8, 2022. 2. The court should note that I sent a standard e-mail to Defendant, Lidia Ryan, on September 28, 2022, in compliance with California Rules of Court, Rule 3.1312, seeking her comments on the proposed order. (A true and correct copy of this transmittal e-mail is attached hereto as Exhibit A.) Along with the proposed order I sent a copy of the tentative ruling of this court. 3. Ms. Ryan responded by e-mail on September 28, 2022. (A true and correct copy of this e-mail from Ms. Ryan to me dated September 28, 2022, is attached hereto as Exhibit B.)4. I responded to the e-mail of Ms. Ryan also on September 28, 2022. (A true and correct copy of my e-mail to Ms. Ryan of September 28, 2022, is attached hereto as Exhibit C) 5. Given the position of Ms. Ryan that she objects to all proceedings before this court, I do not believe any more efforts to meet and confer would be fruitful. I ask the court to sign the order after hearing in its current form. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. pea, Dated: Sa / 25 JOHN P. HANNON IT Attorney for Plaintiff: JUANITA OLSONEXHIBIT A9/28/22, 5:29 PM Yahoo Mail - order after hearing order after hearing From: John Hannon (jph3003@yahoo.com) To: triver.ryan@gmail.com Cc: jmorockon@gmail.com Date: Wednesday, September 28, 2022 at 11:37 AM PDT Dear Ms. Ryan: | am attaching an amended proposed order after hearing from the matter heard on September 8, 2022. There was an eror in the caption of the prior order. | am again attaching the tentative ruling. Please review the Proposed order regarding its accuracy as to the orders made by the court. If you beleive there should be any changes, please contact me within 5 days. If you believe the order is accurate as to what the judge ordered, please sign and send me the signature page. If | do not receive any contact from you, the matter will be submitted direclty to the court. JOHN P. HANNON II Attorney at Law Law Offices of John P. Hannon II 273 Knappton Road Naselle, WA 98638 E-mail: joh3003@yahoo.c Phone: (831) 239-4898 PLEASE NOTE NEW ADDRESS. The information contained in this email message may be privileged, confidential and protected from disclosure. If you are not the intended recipient of this email, any dissemination or copying of this information is Strictly prohibited. If you think you received this email in error, please contact the sender at the address or phone number above. [+] 9.27.22. olson tentative ruling_0001.pdf 402.9kB [x] order after hearing 9.8,22.pdf 72.1kB about:blankEXHIBIT B9/28/22, 5:28 PM Yahoo Mail - Re: order after hearing Re: order after hearing From: Lryan Ryan (rriver.ryan@gmail.com) To: jph3003@yahoo.com Cc: jmorockon@gmail.com Date: Wednesday, September 28, 2022 at 02:24 PM PDT Mr. Hannon, | have opposed every one of your Motions to Compel and the Tentative Rulings along with this latest financial demand. This is quite a business you have going Mr. Hannon. Your intimidation by flooding my email with threats, lies and bills has benefitted you greatly. | will need an acknowledgement once the check is received so | will have the check sent to your Washington address and it will require a signature of acknowledgement. As | requested prior and you ignored, my doctor requested permission by you Mr. Hannon to send her correspondences and updates. Again, does my Doctor have permission to send you letters and to this address? In the letter, my doctor is asking for a 2 month Pause for my body and mind to heal. As Judge Volkmann said when he looked your client straight in the eyes 3 times “the house will be sold.” Hopefully your client is packing and preparing to move. My husband would like to remove all our personal property asap. Please select which works for your client as she will need to leave while he is packing our personal belongings. Available weekends to pick up personal items etc: October 1,2 October 12,16 October 29, 30 every weekend in November except Thanksgiving weekend. Kindly notify me which weekend will work for you client. Regards, Lidia Ryan On Wed, Sep 28, 2022 at 11:37 AM John Hannon wrote: Dear Ms, Ryan: | | | | about:blank 29/28/22, 5:28 PM | | am attaching an amended Please review the proposed | | | | i | | | | | | | | | | JOHN P. HANNON II | | Attorney at Law | 273 Knappton Road | Naselle, WA 98638 | E-mail: jph3003@yahoo. Phone: (831) 239-4898 Yahoo Mail - Re: order after hearing proposed order after hearing from the matter heard on September 8, 2022. There | Was an eror in the caption of the prior order. | am again attaching the tentative ruling. order regarding its accuracy as to the orders made by the court. If you beleive there should be any changes, please contact me within 5 days. If you believe the order is accurate as to what the judge ordered, please sign and send me the signature page. If | do not receive any contact from you, the matter will be submitted direclty to the court. Law Offices of John P. Hannon II PLEASE NOTE NEW ADDRESS. The information contained in this email message may be privileged, confidential and protected from disclosure. If | you are not the intended recipient of this email, any dissemination or copying of this information is strictly prohibited. If you think you re | | above. about:blank eceived this email in error, please contact the sender at the address or phone number 2/2EXHIBIT C9/28/22, 5:29 PM Yahoo Mail - Order after hearing Order after hearing From: John Hannon (jph3003@yahoo.com) To: triver.ryan@gmail.com Bcc: jmorockon@gmail.com Date: Wednesday, September 28, 2022 at 05:28 PM PDT Dear Ms. Ryan: | am in receipt of your e-mail of this date. First, you have copied this e-mail to my client. As | have repeatedly stated to you, the copying of documents to my client is a violation of the existing restraining order. In particular, Paragraph 9 of the restraining order states:that you may not contact Ms. Olson either "directly or indirectly, by an means, includigby telephone, mail, email, or other electronic process." This is the last time | am going to warn you about your sending courtesy copies of e-mails to Ms. Olson. The next time that you violate the court order the appropriate action will be taken. If you have personal possions in the home, please provide a list. My client will examinje this list and send to you those items which she believes are legitimately your Property. As to the matters over which there is a dispute, we can take these items up with the judge. Again, | want to reiterate that the existing order prevents you or anyone on your behalf from contacting Ms. Olson. If your husband, or some other perosn woerking on your behalf, shows up at Ms. Olson's door such action would be a violation jof the existing restraining order. Second, to claim that your doctors need my approval to send me letters is another silly position. First, under the medical Privacy act, the privilege belongs to you. Second, you affirmatively represented to the court that you had doctor letters in your possession and that you would provide these letters by the end of the day on September 8, 2022. In fact, the court ordered you to provide me iwth copies of these letters by the close of business on Third, you were ordered to pay sanctions in both the restraining order matter as well as the two discovery motions. | do not have to jump through a series of hoops for you to obeys these orders. | suggrest that you put as much time into complying with your obligations under the law as you put into sending me belitting and false statements. The purpose of sending you a draft Copy of the proposed order is for you to provide corrections or additions to the order so that the order reflects what happened in court. It is not an excuse for you to create issues or personally attack me. | will submit the order after heairng along with a copy of your e-mail and this responsive e-mail at this time. Your attention to this matter is appreciated. JOHN P. HANNON II Attorney at Law Law Offices of John P. Hannon II 273 Knappton Road Naselle, WA 98638 E-mail: jph3003@yahoo.com Phone: (831) 239-4898 about:blank9/28/22, 5:29 PM PLEASE NOTE NEW ADDRESS. The information contained in this email messa are not the intended recipient of this email, an think you received this email in error, please c about:blank Yahoo Mail - Order after hearing ge may be privileged, confidential and protected from disclosure. If you y dissemination or copying of this information is strictly prohibited. If you ‘ontact the sender at the address or phone number above. 2/2PROOF OF SERVICE BY MAIL AND E-MAIL The undersigned hereby declares that he/she is over the age of 18 years and not a party to the action. The undersigned’s business address is 273 Knappton Road, Naselle, WA 98638. On the date last written, the undersigned delivered the following document(s): Declaration Regarding Compliance with CRC 3.1312 by personally mailing, by first class mail, postage prepaid, and by e-mailing the above listed document(s) on the same date of signature hereto to the address(es) and e-mail(s) set forth: Lidia Ryan 3970 Harney Street San Diego, CA 92110 E-mail: rriver.ryan@gmail.com I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Dated: qlee 2e BY: JOHN P. HANNON II