Party Statement: Sajida Zaman vs. Liqui-Box Corporation

• 
• 
• 
• 

						
                                
Preview
                                DocuSign Envelope ID: 1F7D220D-80FF-4C28-BA95-9CE2F8263072




                 JOSHUA S. FALAKASSA (SBN: 295045)
               1 FALAKASSA LAW, P.C.
               2 1901 Avenue ofthe Stars Suite # 450
                 Los Angeles, Caiifomia 90067
               3 Tel.: (818) 456-6168; Fax: (888) 505-0868
                 Email: josh@falakassalaw.com
               4
                 ARASH S. KHOSROWSHAHI (SBN: 293246)
               5 LIBERTY MAN LAW, P.C.
               6 1010 F Street, Ste. 300
                 Sacramento, Caiifomia 95814
               7 Tel.: (916) 573-0469; Fax: (866) 700-0787
                 Email: ash@libertymanlaw.com
               8
                 Attomeys for Plaintiff,
               9 SAJIDA ZAMAN
              10
                                              SUPERIOR COURT OF CALIFORNIA
              11
                                                  COUNTY OF SACRAMENTO
              12
                 SAHDA ZAMAN,                                 CASE NO.: 34-2019-00252121
              13
                                                              RESERVATION ID: 2644651
              14          Plaintiff,
                 vs.                                          DECLARATION OF LICH L E IN
              15                                              SUPPORT OF PLAINTIFF'S
                 LIQUI-BOX CORPORATION, and DOES 1            OPPOSITION TO DEFENDANT
              16 through 20, inclusive.                       LIQUI-BOX CORPORATION'S
                                                              MOTION FOR SUMMARY
              17                                              JUDGMENT AND/OR SUMMARY
                          Defendants.
              18                                              ADJUDICATION OF ISSUES.

              19                                                       Date: August 10, 2022
                                                                       Time: 1:30pm                   BY FAX
              20                                                       Dept.: 53
                                                                       Trial Date: September 12, 2022
              21
              22 I, LICH LE, hereby declare as follows:
              23        1.     I am over 18 years of age. I was a former Machine Operator employee of Defendant
              24 Liqui-Box Corporation ("Defendant"). I have personal knowledge of the facts stated herein and can
              25 testify competently thereto.
              26            2.      Management never trained me that I could report hazards or injuries without fear of
              27 retaliation in relation to the Critical Safety Behaviors ("CSB") policy. I was in fear and felt
              28
DocuSign Envelope ID: 1F7D220D-80FF^C28-BA95-9CE2F8263072




               1 discouraged in reporting any injury for fear that such a report would be used against me to discipline
               2 me.
               3           3.      Management never trained me how to recognize or report the symptoms of any

               4 repetitive strain injury, including pain, swelling or other such symptoms.
               5           4.      Management never trained me that any discomfort or pain was a "near miss" or any

               6 other "incident" requiring "reporting" under any policy.
               7           5.      Unlike a cut or other first aid injury that I could immediately recognize, I did not

               8 know how to recognize a symptom of a repetitive strain injury.
               9           I declare under penalty of perjury that under the laws of the State of Caiifomia that the

              10 foregoing is true and correct.
              11 Executed on this 27"' Day of July 2022, at Sacramento, Caiifomia.
                                                                                              -DocuSlgned by:
              12
              13                                                                      Lich Le,Declarant

              14
              15
              16
              17
              18
              19
              20
              21
              22
              23
              24
              25
              26
              27
              28