Motion-Secondary: Sajida Zaman vs. Liqui-Box Corporation

• 
• 
• 
• 

						
                                
Preview
                                DocuSign Envelope ID: 824DB138-70C1-4A59-B125-FF3E066BA298




                                                                      FILED/ENDORSED
        1   JOSHUA S. FALAKASSA (SBN: 295045)
            FALAKASSA LAW, P.C.                                              SEP-6 2022
        2   1901 Avenue of the Stars Suite # 450
        3   Los Angeles, Califomia 90067                              By:.     _A. TurneL
                                                                               Deputy Clerk
            Tel.: (818) 456-6168; Fax: (888) 505-0868
        4   Email: josh@falakassalaw.com
        5   ARASH S. KHOSROWSHAHI (SBN: 293246)
        6   L I B E R T Y MAN LAW, P.C.
            1010 F Street, Ste. 300    .
        7   Sacramento, Califomia 95814
            Tel.: (916) 573-0469; Fax: (866) 700-0787
        8   Email: ash@libertymanlaw.coni
        9
            Attomeys for Plaintiff,
       10   SAJIDAZAMAN

       11                                    SUPERIOR COURT OF CALIFORNIA
       12
                                                  COUNTY OF SACRAMENTO
                                                                                              BY FAX
       13
       14
             SAJIDA ZAMAN,                                        CASE NO.: 34-2019-00252121
       15
                      Plaintiff,                                  DECLARATION OF ANGELA BEARD
       16                                                         IN SUPPORT OF OPPOSITION T O
             vs.
                                                                  DEFENDANT           LIQUI-BOX
       17                                                         CORPORATION'S    MOTION    TO
             LIQUI-BOX CORPORATION, and DOES I
       18    through 20, inclusive.                               CONTINUE TRIAL DATE

       19             Defendants.                                 Date: September 9, 2022
                                                                  Time: 9:30am
      20                                                          Dept.: 47
                                                                  Trial Date: September 12, 2022
      21
      22
      23
      24     I , ANGELA BEARD, declare as follows:
      25           1. I am over 18 years of age. I have knowledge of the facts stated herein and can testify
      26              competently thereto.
      27           2. On or about August 11, 2022, Defendant Liqui-Box Corporation ("Defendanf) served
      28              upon me a deposition subpoena at my home. Defendant's law firm Jackson Lewis, P.C.


                                   DECLARATION OF ANGELA BEARD IN SUPPORT OF OPPOSITION
                                                             1 of 2
DocuSign Envelope ID: 824DB138-70C1-4A59-B125-FF3E066BA298




                     ("Jackson Lewis"), by and through paralegal Mr. Ed Puchi, communicated to me that they

       .2            wanted me to appear for deposition the very next day, August 12, 2022. Neither

        3            Defendant's attomey Mr. James T. Jones, Mr. Puchi, nor anyone at Jackson Le\vis, P.C.

        4            informed me that I had a due process right of 10 days' notice between when I was served

        5            with a subpoena and when I was to appear subject to the subpoena.

        6        3. Thereafter, I agreed to apjjear for deposition on or about August 18, 2022, with Mr. Jones,

        7            Mr. Puchi, nor anyone at Jacksoti Lewis informing me that the discovery cutoff was

        8            August 12, 2022. OnceJ leamed that there was a cutoff and that no further non-expert

        9            discovery could be conducted, 1 informed Jackson Lewis that I would not appear.

       10        4. At no point did Plaintiff Sajida Zaman ("Plaintiff") nor her son Abdul Majid threaten me

       11            not to appear at a second deposition. Instead, I was simply informed of my rights and of

       12            the discovery cutoff, and freely made the decision not to appear for the second deposition.

       13            I was unrepresented during this time period, which I repeatedly told Jackson Lewis.

       14        5. Jackson Lewis, by and through Mr. Puchi, has gone so far as to even have me attempt to

       15            sign a declaration contradicting my past testimony that I recalled approximately 20

       16            violations of Defendant's Critical Safety Behaviors Policy. Indeed, I feel tricked by Mr.

       17            Jones, Mr. Puchi, and Jackson Lewis in this case.

       18            I declare under penalty of peijury under the laws of the State of Califomia that the

       19 foregoing is tme and correct.
                                                               /,   DocuSigned by:
      20 Dated: September 6,2022                               |           ^SJu..
                                                                    7D3BCA8BCP0617E..
      21                                               Angela Beard
      22
      23
      24
      25
      26
      27
      28

                                DECLARATION OF ANGELA BEARD IN SUPPORT OF OPPOSITION
                                                              2 of 2