Document for Juanita Olson vs Lidia Ryan

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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

NOTICE OF MOTION AND MOTION

12/5/2022
8:30 a.m.
5

COUNTY OF SANTA CRUZ
JUANITA OLSON, ) Case No: 21CV00921
)
Plaintiff, )
)
v. ) FOR LEAVE TO FILE FIRST
) FIRST AMENDED COMPLAINT
LIDIA RYAN, )
)
Defendant, )
) Hearing Date:
) Time:
AND RELATED CROSS-ACTION ) Dept.:
) Judge:

TO: All Defendants and their attorney of record:

T. Volkmann

Please take note that on December 5, 2022, at the hour of 8:30 a.m., in department 5 of the

above-entitled court located at 701 Ocean Street, Santa Cruz, California, Plaintiff, Juanita Olson,

will move for an order allowing for the filing of a first amended complaint in the form as set forth

in Exhibit C to the declaration of John P. Hannon II which accompanies this notice of motion.

This motion will be based upon the grounds that after the action was filed other conduct and

actions of Defendant have violated the rights of Plaintiff. Further, this motion is based upon the

fact that during the course of discovery in the present matter Defendant has admitted that she acted

to harm Plaintiff and that such actions were wilfull. Adding a cause of action to address the

conduct of Defendant is both appropriate and necessary.This motion will be based upon this notice, the attached memorandum of points and
authorities, the declaration of John P. Hannon II and upon such other and further evidence and

argument as the court may consider at the time and place for the hearing of this motion.

{ —— a
Dated: _/o/ 3/22 —y EE
<—JOHN P. HANNON I
Attorney for Plaintiff:
CANDACE DEKKERTPROOF 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):
Notice of Motion and Motion For Leave to File First Amended Complaint
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: lol 3 { 2. ee
OHN P. HANNON II