Motion-Secondary: CITY OF SANTA MONICA VS ALANNA ZABEL

• 
• 

						
                                
Preview
                                Electronically FILED by Superior Court of California, County of Los Angeles on 04/27/2022 03:53 PM Sherri R. Carter, Executive Officer/Clerk of Court, by L. Kulkin,Deputy Clerk


                           SUSAN COLA
                   1       Interim City Attorney
                           EDA SUH, State Bar No. 161881
                   2       Chief Deputy City Attorney
                           eda.suh@smgov.net
                   3       JONATHAN FRANK, State Bar No. 308584
                           Deputy City Attorney
                   4       jonathan.erwin-frank@smgov.net
                           1685 Main Street, Room 310
                   5       Santa Monica, California 90401
                           Telephone: (310) 458-8336
                   6       Facsimile: (310) 395-6727
                   7       Attorneys for Plaintiff                                                                     Exempt from filing fee pursuant
                           CITY OF SANTA MONICA                                                                        to Government Code §6103
                   8
                   9
                                                        SUPERIOR COURT OF THE STATE OF CALIFORNIA
                 10
                                                                     FOR THE COUNTY OF LOS ANGELES
                 11
                 12
                           CITY OF SANTA MONICA,                                                               Case No. 21SMCV01722
                 13
                                                  Plaintiff,                                                   Honorable Mark H. Epstein; Judge –
                 14                                                                                            Department R
                              v.
                 15                                          DECLARATION OF EDA SUH IN
                           ALANNA ZABEL aka ALANNA ZABIELSKI SUPPORT OF PLAINTIFF’S
                 16
                           and DOES 1-10,                    OPPOSITION TO DEFENDANT’S
                                                             MOTION TO RECUSE PLAINTIFF’S
                 17                                          COUNSEL
                                      Defendants.
                 18
                 19
                 20                                                               DECLARATION OF EDA SUH
                 21
                 22                   I, Eda Suh, declare as follows.
                 23
                 24                   1.          I am a deputy city attorney with the Santa Monica City Attorney’s Office and
                 25        the chief of the Public Rights Division.
                 26                   2.          I have worked as a deputy city attorney in Santa Monica since 1999.
                 27                   3.          Since 2020 I have acted as the supervisor of deputy city attorney Jonathan
                 28                                                                                     1
                                                                                DECLARATION OF EDA SUH