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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 Ravi K. Lally, State Bar No. 225687
rlally@mortensontaggart.com
4 MORTENSON TAGGART ADAMS LLP
300 Spectrum Center Dr., Suite 1200
5 Irvine, CA 92618
Telephone: (949) 774-2224
6 Facsimile: (949) 774-2545
7 Attorneys for Defendants
FORD MOTOR COMPANY and
8 JIM BURKE FORD
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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FOR THE COUNTY OF KERN
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12 KARINA VARGAS, GONZALO VARGAS, Case No. BCV-22-101682-JEB
and LIVIER VARGAS,
13 DECLARATION OF RAVI K. LALLY
Plaintiffs, PURSUANT TO C.C.P. § 430.41(A)(2)
14 REGARDING DEFENDANTS’ GOOD
vs. FAITH ATTEMPT TO MEET AND
15 CONFER IN ADVANCE OF
FORD MOTOR COMPANY; JIM BURKE DEMURRER
16 FORD; and DOES 1 through 10, inclusive,
Complaint Filed: July 7, 2022
17 Defendants. Trial Date: Not Assigned
18 Judge: Hon. J. Eric Bradshaw
Dept.: J
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DECLARATION OF RAVI K. LALLY PURSUANT TO C.C.P. § 430.41(A)(2)
1 DECLARATION OF RAVI K. LALLY
2 I, Ravi K. Lally, 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 if called upon as a witness, I could and
8 would testify competently as to the matters discussed herein.
9 2. On January 20, 2023, Plaintiffs Karina Vargas, Gonzalo Vargas, and Livier
10 Vargas (“Plaintiffs”) served their Second Amended Complaint. Defendants’ deadline to
11 respond to the Complaint is February 22, 2023. Pursuant to C.C.P. § 430.41, Defendants must
12 meet and confer prior to filing a demurrer.
13 3. On February 14, 2023, I called Plaintiffs’ counsel to meet and confer regarding
14 Defendants’ intent to file a Demurrer to Plaintiffs’ Second Amended Complaint. I was not
15 able to reach Plaintiffs’ counsel. On February 21, 2023, I sent Plaintiffs’ counsel a meet and
16 confer email. No response was received. On February 22, 2023, I called Plaintiffs’ counsel
17 and emailed Plaintiffs’ counsel to meet and confer. No response was received.
18 4. This declaration is being filed following Defendants’ good faith attempt, but
19 inability, to meet and confer with Plaintiffs’ counsel prior to the filing of a demurrer.
20 5. Pursuant to section 430.41, Defendants are entitled to an automatic 30-day
21 extension of their deadline to respond to the Second Amended Complaint. Defendants’
22 deadline to file a responsive pleading is now March 24, 2022.
23 I declare under penalty of perjury pursuant to the laws of the State of California that the
24 foregoing is true and correct.
25 Executed on February 22, 2023, at Irvine, California.
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DECLARATION OF RAVI K. LALLY PURSUANT TO C.C.P. § 430.41(A)(2)
PROOF OF SERVICE
1
STATE OF CALIFORNIA )
2 ) ss
COUNTY OF ORANGE )
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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 February 22, 2023, I
5 served the within documents:
6 DECLARATION OF RAVI K. LALLY PURSUANT TO C.C.P. § 430.41(A)(2)
REGARDING DEFENDANTS’ GOOD FAITH ATTEMPT TO MEET AND CONFER
7 IN ADVANCE OF DEMURRER
8 BY ELECTRONIC SERVICE by transmitting via my electronic service address
(crobertson@mortensontaggart.com) the document(s) listed above to the person(s) at the e-
9 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
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ATTORNEY FOR PLAINTIFF
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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 February 22, 2023, at Irvine, California.
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lf}0140 1~1 =utS}v?D'°2)
Chevalier Robertson
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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 Ravi K. Lally, State Bar No. 225687 rlally@mortensontaggart.com 4 MORTENSON TAGGART ADAMS LLP 300 Spectrum Center Dr., Suite 1200 5 Irvine, CA 92618 Telephone: (949) 774-2224 6 Facsimile: (949) 774-2545 7 Attorneys for Defendants FORD MOTOR COMPANY and 8 JIM BURKE FORD 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 FOR THE COUNTY OF KERN 11 12 KARINA VARGAS, GONZALO VARGAS, Case No. BCV-22-101682-JEB and LIVIER VARGAS, 13 DECLARATION OF RAVI K. LALLY Plaintiffs, PURSUANT TO C.C.P. § 430.41(A)(2) 14 REGARDING DEFENDANTS’ GOOD vs. FAITH ATTEMPT TO MEET AND 15 CONFER IN ADVANCE OF FORD MOTOR COMPANY; JIM BURKE DEMURRER 16 FORD; and DOES 1 through 10, inclusive, Complaint Filed: July 7, 2022 17 Defendants. Trial Date: Not Assigned 18 Judge: Hon. J. Eric Bradshaw Dept.: J 19 20 21 22 23 24 25 26 27 28 DECLARATION OF RAVI K. LALLY PURSUANT TO C.C.P. § 430.41(A)(2) 1 DECLARATION OF RAVI K. LALLY 2 I, Ravi K. Lally, 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 if called upon as a witness, I could and 8 would testify competently as to the matters discussed herein. 9 2. On January 20, 2023, Plaintiffs Karina Vargas, Gonzalo Vargas, and Livier 10 Vargas (“Plaintiffs”) served their Second Amended Complaint. Defendants’ deadline to 11 respond to the Complaint is February 22, 2023. Pursuant to C.C.P. § 430.41, Defendants must 12 meet and confer prior to filing a demurrer. 13 3. On February 14, 2023, I called Plaintiffs’ counsel to meet and confer regarding 14 Defendants’ intent to file a Demurrer to Plaintiffs’ Second Amended Complaint. I was not 15 able to reach Plaintiffs’ counsel. On February 21, 2023, I sent Plaintiffs’ counsel a meet and 16 confer email. No response was received. On February 22, 2023, I called Plaintiffs’ counsel 17 and emailed Plaintiffs’ counsel to meet and confer. No response was received. 18 4. This declaration is being filed following Defendants’ good faith attempt, but 19 inability, to meet and confer with Plaintiffs’ counsel prior to the filing of a demurrer. 20 5. Pursuant to section 430.41, Defendants are entitled to an automatic 30-day 21 extension of their deadline to respond to the Second Amended Complaint. Defendants’ 22 deadline to file a responsive pleading is now March 24, 2022. 23 I declare under penalty of perjury pursuant to the laws of the State of California that the 24 foregoing is true and correct. 25 Executed on February 22, 2023, at Irvine, California. 26 27 28 Ravi K. Lally -1- DECLARATION OF RAVI K. LALLY 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 February 22, 2023, I 5 served the within documents: 6 DECLARATION OF RAVI K. LALLY PURSUANT TO C.C.P. § 430.41(A)(2) REGARDING DEFENDANTS’ GOOD FAITH ATTEMPT TO MEET AND CONFER 7 IN ADVANCE OF DEMURRER 8 BY ELECTRONIC SERVICE by transmitting via my electronic service address (crobertson@mortensontaggart.com) the document(s) listed above to the person(s) at the e- 9 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 February 22, 2023, at Irvine, California. 19 20 lf}0140 1~1 =utS}v?D'°2) Chevalier Robertson 21 22 23 24 25 26 27 28 PROOF OF SERVICE