Preview
O'BRIEN WAITERS & DAVIS,LLP
Michael G. Watters, Esq.(CSB No. 63140)
Graden R. Tapley, Esq.(CSB No. 222636)
1550 Airport Blvd., Suite 201
Santa Rosa, CA 95403
(707)545-7010
Attorneys for Mitchell G. Black and Deanne G. Black
dba Black Knight Vineyards.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SONOMA
BARRY BRILLIANT,an individual; and Case No. SCV-267406
DAGMAR K. HOHENECK-SMITH,an
individual and as trustee ofTHE DAGMAR DECLARATION OF JOYCE
HOHENECK-SMITH TRUST dtd December WHITAKER IN SUPPORT OF
5"S 2 14,2010,
"5 m-O
!« g S 'r
DEFENDANT'S POST-TRIAL
Plaintiffs, MOTIONS RE FIRE
vs.
c ul.ic
k. *-> 5k' MITCHELL G. BLACK,an individual and dba
CQtCO BLACK KNIGHT VINEYARDS;DEANNE G.
BLACK,an individual and dba BLACK
KNIGHT VINEYARDS;and DOES 1-20,
Defendants
20
21 1, Joyce Whitaker, declare as follows:
22 1. I am the significant other ofDefendant Mitchell G. Black. I make this declaration in
23 support of Defendant Black's post-trial motions.
24 2. I am over the age of 18 and,except as otherwise stated, have personal knowledge of
25
the matters set forth herein and am competent to testify thereto if called upon as a witness.
26 Mitch's Whereabouts at the time of the fire
27
3. On July 7, 2021 (day offire), I was with Mitch Black at our house on Inverness Ave.,
28
Santa Rosa, CA 95404 from 11:30 a.m. until approximately 2:15.1 got on a work call at 2 pm. Mitch
DECLARATION OF JOYCE WHITAKER IN SUPPORT OF DEFENDANT'S POST-TRIAL MOTIONS RF FIRF
Brilliant, et al, v. Black, et al., Sonoma County Superior Court Case No.SCV267406
1 brought me my lunch while I was on the call and kissed me good-bye around 2:15 to 2:30. 1 later saw
2 him go outside and stop and talk for a while with our landscaping crew in the driveway. I do not
3 know THE EXACT time he left our house to return to the vineyard.
4 4. Any witness who says they saw or heard him on tractors in the afternoon are mistaken. He
5 was not at the vineyard; he was with me.
6 5. Mr. McGee testified that he assumed Mitch was lying about when he was mowing at the
7 vineyard property that day. Mitch was not lying.
8 Witness at Fire on July 7,2021
9 6. Around 3:30, my landscaper, Luis Cruz, knocked on the door of my residence. I answered
10 and he showed me smoke that was rising in the area of the vineyard. Luis told me that he and the crew
11 had been hearing lots of sirens. Luis had been to 4889 Grange vineyard many times to pick up wood
g
^ 12 chips for our home property on Inverness eind said there might be a fire in the vineyard.
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7. I got in my car and immediately drove to the vineyard. No more than a 5-minute drive at
T3 c „-o
2.115; 14 most.
E<^ 5.
iijj_i5 8. When I got there, I saw at least a dozen fire trucks from various fire departments (Cotati,
iP. 16
u <->
Rohnert Park, Santa Rosa). 1 did not see Cal Fire at that time. I could see firefighters uphill toward the
cottage (the apparent point of origin of the fire) and stretched across the field with hoses all the way
18 toward Guenza Road.
19 9. I saw members of Mitch's crew and asked where Mitch was. Blanca told me that she was
20 worried because Mitch was trying to fight the fire with the tractor.
21 10. Just a few moments later, Mitch came down the hill from the fire on the ATV. His face was
22 scorched and red, his hands and face were covered with soot and his eyebrows had been bumed off. I
23 asked him if he was okay and what happened, and he said he did not know. I got in the ATV with him,
24 and we drove back up the hill toward the fire which was mostly out on the Grange Road portion of the
25 property but still low, buming in the direction of Plaintiffs' property. As soon as we got up the hill, a
26 firefighter yelled at us to take cover as there was an airdrop coming in. We ran inside the cottage and an
27 airtanker immediately came overhead and dropped retardant on the field between the vineyard and
28 Guenza Road.
DECLARATION OF JOYCE WHITAKER IN SUPPORT OF DEFENDANT'S POST-TRIAL MOTIONS RE FIRE
Brilliant, et al. v. Black, et ai, Sonoma County Superior Court Case No. SCV267406
1 11. When we came out of the cottage, the fire was almost completely extinguished as far as 1
2 could see. The fire fighters were walking not running and hoses were all the way over to Guenza Road.
3 12.1 went to find Mitch's sister, Laune, to make sure she was okay and to help her evacuate the
4 dogs and cats as we did not want them getting in the way of the firefighters. I stayed at the vineyard
5 while Laurie drove the dogs and cats to the Inverness house.
6 13.1 never saw Mitch spraying water on the wine barrels in the barrel barn. That did not happen
7 while the fire was burning.
8 14. Later, the firefighters were cleaning up and packing up. I was standing with Mitch when a
9 firefighter from a local station (maybe Cotati) came up, shook Mitch's hand and thanked him for all of
10 his help fighting the fire and providing information.
11 15. Later, a Cal Fire person walked up to me and Laurie Black. He introduced himself as the
8
12 CalFire Incident Commander and very rudely asked "where is the guy that started the fire?' I was
s "5 3«
â– d'SuS
13 confused and said that tliere was no guy that started the fire. He then said that the 911 caller said a guy
^ & O 'n 14 on a tractor started the fire. I corrected him and said that there was no one on the tractor when the fire
2^=0:5;
E<
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15 started. He then got very nasty and said, "there was a fire, something started it, what do you think it
= J^.Y!
o o > 16 was, aliens? lightning? a stranger?" I said I didn't know but thought it was his job to figure it out. I
lI ^ ^
b^§" don't recall his name; it was an unusual name. I also have the impression that when he approached us,
18 he had just arrived at the vineyard after being at plaintiffs' property.
19 16. Mitch's sister, Laurie, was there and said that she was the one who called 911 and may have
20 said that Mitch was on the tractor (trving to put it outl in the fire. She also told him that Mitch did not
21 start the fire with the tractor, but the man just turned and walked away. He was very rude, angry,
22 aggressive and patronizing.
23 17.1 never saw this man or anyone from any fire department investigate the fire. I did not see
24 anyone look at the tractor or the mower. I did not see anyone walking the area where the fire started or
25 looking at the PG&E wires that crossed over the property or the transformer nearby. 1 did not see
26 anyone interviewing Laurie who was less than a hundred yards from the point of origin when the fire
27 started. Had she been asked; she could have cleared up any misunderstanding caused by her 911 call.
28
DECLARATION OF JOYCE WHITAKER IN SUPPORT OF DEFENDANT'S POST-TRIAL MOTIONS RE FIRE
Bnliiant, et al. v. Black, eJ al, Sonoma County Superior Court Case No. SCV267406
18.1 observed many neighbors come by to check on the Blacks. I did not ever see the Plaintiffs
2 that day.
3 McGee
4 19.1 was with Mitch and Laurie after the fire. We were approached by a fire fighter who
5 introduced himselfand Brandon McGee. He said,"I am sorry, but I was told that 1 have to give you a
6 citation." I do not recall him looking around, he just walked up and said that. He had a clipboard or
7 binder with some paperwork. I heard him tell Mitch that as the property owner he was required to sign
8 the paperwork. I also heard him ask for Mitch's California driver's license. I heard Milch say he was
9 not comfortable signing it because it did not have any facts/it was more or less blank. I looked at it
10 briefly and saw that was true. McGee wrote some notes on the bottom about the timing of when Mitch
11 was mowing (before 11 in the morning). Laurie tried to tell him that she was the one that called 911 but
a
.. S
lyi
12 McGee did not seem interested. I then saw Mitch sign the form. I saw McGee hand a copy to Mitch,
J35 J5
12 plaintiffs la>vyer claims. I came out of my office and went to my kitchen to make a lunch. Mitch was
J "g cS
el ^ ^
-
13 on Zoom doing his third day of deposition in the dining room which is connected to the kitchen in an
"S
X I
14 open concept house. Mitch's back was to me,and he could not even see me. My back was also to
nil 15 Mitch. I overheard Mr. Bacho asking questions about what Osboume said on his call to me. 1 said to
c £,!2
U sJ 16 myself(and the dogs who were lusting after my lunch)"he wasn't even on the call". Just then, Mitch
'zt:^
17 said,"I wasn't on the call". Mr.Bacho went nuts and accused me of"ethical violations","coaching
18 the witness", etc. I was adamant that he was completely wrong. I told him I was not in any way
19 coaching Mitch, At that point he stated on the record,"thank you for admitting that you just coached
20 the witness." Mr. Bacho has a custom and practice of misstating things that people have just said. I told
21 him he was wrong and misstating what I had said. He insisted I leave the house(my house) and I said
22 no,I would finish making my lunch and go back to my office. I assured him that once in my office, I
23 wear noise cancelling earphones and cannot hear anything. That is what I did. It was not a "stunt", and I
24 was not"coaching the witness". I did speak but not to Mitch. I spoke to myselfand my dogs. Mitch
25 may have heard me, Mr. Bacho did. I did not think about the fact that Mitch could hear me. Excluding
26 my critical testimony on this basis of Mr. Bacho's lies is patently wrong as I am the only person that
27 spoke with Osboume. Interestingly, I understand that Dagmar did the same thing (answered out loud)
28 when Barry was on the stand.
DECLARATION OF JOYCE WHITAKER IN SUPPORT OF DEFENDANT'S POST-TRIAL MOTIONS RE FIRE
Brilliant, et al. v. Black, et al., Sonoma County Superior Court Case No. SCV267406
1 29.1 would have testified at trial in accordance with the testimony in this Declaration.
2 30. In my opinion, I strongly feel that excluding my testimony is irreparable harm to
3 Defendants and worthy in and of itself, of granting a new trial.
4 I declare under penalty of perjury under the laws ofthe State of California the foregoing is
5 true and correct.
6 Dated; 4-13-23
7
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DECLARATION OF JOYCE VraiTAKER IN SUPPORT OF DEFENDANT'S POST-TRIAL MOTIONS RE FIRE
Brilliant, et aJ. v. Black, et al.y Sonoma County Supenor Court Case No. SCV267406
EXHIBIT A
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Sonoma County Fire District
Ryan Osbome
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CeW: 707-r)08-^
8200 old RccIhoocI Hwy onice; 7(li-Hy2-'i44i
Windsor, C;A 95492
sonomacouiuyfd.ovg rosbon.e@soi.oinaroumyfd.org
.'■•SI
■«f-l
Vision Statement
\Vc will position the fire district to provide Hsca'
siislainability while providing excellence in
emergency response and community preparedness.
Mission Statement
To compassionately care for the safety of
our communities and our visitors through
progressive professional emergency
preparedness and response.
EXHIBIT B
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O'BRIEN WAITERS & DAVIS,LLP Michael G. Watters, Esq.(CSB No. 63140) Graden R. Tapley, Esq.(CSB No. 222636) 1550 Airport Blvd., Suite 201 Santa Rosa, CA 95403 (707)545-7010 Attorneys for Mitchell G. Black and Deanne G. Black dba Black Knight Vineyards. SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SONOMA BARRY BRILLIANT,an individual; and Case No. SCV-267406 DAGMAR K. HOHENECK-SMITH,an individual and as trustee ofTHE DAGMAR DECLARATION OF JOYCE HOHENECK-SMITH TRUST dtd December WHITAKER IN SUPPORT OF 5"S 2 14,2010, "5 m-O !« g S 'r DEFENDANT'S POST-TRIAL Plaintiffs, MOTIONS RE FIRE vs. c ul.ic k. *-> 5k' MITCHELL G. BLACK,an individual and dba CQtCO BLACK KNIGHT VINEYARDS;DEANNE G. BLACK,an individual and dba BLACK KNIGHT VINEYARDS;and DOES 1-20, Defendants 20 21 1, Joyce Whitaker, declare as follows: 22 1. I am the significant other ofDefendant Mitchell G. Black. I make this declaration in 23 support of Defendant Black's post-trial motions. 24 2. I am over the age of 18 and,except as otherwise stated, have personal knowledge of 25 the matters set forth herein and am competent to testify thereto if called upon as a witness. 26 Mitch's Whereabouts at the time of the fire 27 3. On July 7, 2021 (day offire), I was with Mitch Black at our house on Inverness Ave., 28 Santa Rosa, CA 95404 from 11:30 a.m. until approximately 2:15.1 got on a work call at 2 pm. Mitch DECLARATION OF JOYCE WHITAKER IN SUPPORT OF DEFENDANT'S POST-TRIAL MOTIONS RF FIRF Brilliant, et al, v. Black, et al., Sonoma County Superior Court Case No.SCV267406 1 brought me my lunch while I was on the call and kissed me good-bye around 2:15 to 2:30. 1 later saw 2 him go outside and stop and talk for a while with our landscaping crew in the driveway. I do not 3 know THE EXACT time he left our house to return to the vineyard. 4 4. Any witness who says they saw or heard him on tractors in the afternoon are mistaken. He 5 was not at the vineyard; he was with me. 6 5. Mr. McGee testified that he assumed Mitch was lying about when he was mowing at the 7 vineyard property that day. Mitch was not lying. 8 Witness at Fire on July 7,2021 9 6. Around 3:30, my landscaper, Luis Cruz, knocked on the door of my residence. I answered 10 and he showed me smoke that was rising in the area of the vineyard. Luis told me that he and the crew 11 had been hearing lots of sirens. Luis had been to 4889 Grange vineyard many times to pick up wood g ^ 12 chips for our home property on Inverness eind said there might be a fire in the vineyard. »-g'S ,- ■3 = < ^ 13 "u 2 7. I got in my car and immediately drove to the vineyard. No more than a 5-minute drive at T3 c „-o 2.115; 14 most. E<^ 5. iijj_i5 8. When I got there, I saw at least a dozen fire trucks from various fire departments (Cotati, iP. 16 u <-> Rohnert Park, Santa Rosa). 1 did not see Cal Fire at that time. I could see firefighters uphill toward the cottage (the apparent point of origin of the fire) and stretched across the field with hoses all the way 18 toward Guenza Road. 19 9. I saw members of Mitch's crew and asked where Mitch was. Blanca told me that she was 20 worried because Mitch was trying to fight the fire with the tractor. 21 10. Just a few moments later, Mitch came down the hill from the fire on the ATV. His face was 22 scorched and red, his hands and face were covered with soot and his eyebrows had been bumed off. I 23 asked him if he was okay and what happened, and he said he did not know. I got in the ATV with him, 24 and we drove back up the hill toward the fire which was mostly out on the Grange Road portion of the 25 property but still low, buming in the direction of Plaintiffs' property. As soon as we got up the hill, a 26 firefighter yelled at us to take cover as there was an airdrop coming in. We ran inside the cottage and an 27 airtanker immediately came overhead and dropped retardant on the field between the vineyard and 28 Guenza Road. DECLARATION OF JOYCE WHITAKER IN SUPPORT OF DEFENDANT'S POST-TRIAL MOTIONS RE FIRE Brilliant, et al. v. Black, et ai, Sonoma County Superior Court Case No. SCV267406 1 11. When we came out of the cottage, the fire was almost completely extinguished as far as 1 2 could see. The fire fighters were walking not running and hoses were all the way over to Guenza Road. 3 12.1 went to find Mitch's sister, Laune, to make sure she was okay and to help her evacuate the 4 dogs and cats as we did not want them getting in the way of the firefighters. I stayed at the vineyard 5 while Laurie drove the dogs and cats to the Inverness house. 6 13.1 never saw Mitch spraying water on the wine barrels in the barrel barn. That did not happen 7 while the fire was burning. 8 14. Later, the firefighters were cleaning up and packing up. I was standing with Mitch when a 9 firefighter from a local station (maybe Cotati) came up, shook Mitch's hand and thanked him for all of 10 his help fighting the fire and providing information. 11 15. Later, a Cal Fire person walked up to me and Laurie Black. He introduced himself as the 8 12 CalFire Incident Commander and very rudely asked "where is the guy that started the fire?' I was s "5 3« ■d'SuS 13 confused and said that tliere was no guy that started the fire. He then said that the 911 caller said a guy ^ & O 'n 14 on a tractor started the fire. I corrected him and said that there was no one on the tractor when the fire 2^=0:5; E< 2S c 15 started. He then got very nasty and said, "there was a fire, something started it, what do you think it = J^.Y! o o > 16 was, aliens? lightning? a stranger?" I said I didn't know but thought it was his job to figure it out. I lI ^ ^ b^§" don't recall his name; it was an unusual name. I also have the impression that when he approached us, 18 he had just arrived at the vineyard after being at plaintiffs' property. 19 16. Mitch's sister, Laurie, was there and said that she was the one who called 911 and may have 20 said that Mitch was on the tractor (trving to put it outl in the fire. She also told him that Mitch did not 21 start the fire with the tractor, but the man just turned and walked away. He was very rude, angry, 22 aggressive and patronizing. 23 17.1 never saw this man or anyone from any fire department investigate the fire. I did not see 24 anyone look at the tractor or the mower. I did not see anyone walking the area where the fire started or 25 looking at the PG&E wires that crossed over the property or the transformer nearby. 1 did not see 26 anyone interviewing Laurie who was less than a hundred yards from the point of origin when the fire 27 started. Had she been asked; she could have cleared up any misunderstanding caused by her 911 call. 28 DECLARATION OF JOYCE WHITAKER IN SUPPORT OF DEFENDANT'S POST-TRIAL MOTIONS RE FIRE Bnliiant, et al. v. Black, eJ al, Sonoma County Superior Court Case No. SCV267406 18.1 observed many neighbors come by to check on the Blacks. I did not ever see the Plaintiffs 2 that day. 3 McGee 4 19.1 was with Mitch and Laurie after the fire. We were approached by a fire fighter who 5 introduced himselfand Brandon McGee. He said,"I am sorry, but I was told that 1 have to give you a 6 citation." I do not recall him looking around, he just walked up and said that. He had a clipboard or 7 binder with some paperwork. I heard him tell Mitch that as the property owner he was required to sign 8 the paperwork. I also heard him ask for Mitch's California driver's license. I heard Milch say he was 9 not comfortable signing it because it did not have any facts/it was more or less blank. I looked at it 10 briefly and saw that was true. McGee wrote some notes on the bottom about the timing of when Mitch 11 was mowing (before 11 in the morning). Laurie tried to tell him that she was the one that called 911 but a .. S lyi 12 McGee did not seem interested. I then saw Mitch sign the form. I saw McGee hand a copy to Mitch, J35 J5 12 plaintiffs la>vyer claims. I came out of my office and went to my kitchen to make a lunch. Mitch was J "g cS el ^ ^ - 13 on Zoom doing his third day of deposition in the dining room which is connected to the kitchen in an "S X I 14 open concept house. Mitch's back was to me,and he could not even see me. My back was also to nil 15 Mitch. I overheard Mr. Bacho asking questions about what Osboume said on his call to me. 1 said to c £,!2 U sJ 16 myself(and the dogs who were lusting after my lunch)"he wasn't even on the call". Just then, Mitch 'zt:^ 17 said,"I wasn't on the call". Mr.Bacho went nuts and accused me of"ethical violations","coaching 18 the witness", etc. I was adamant that he was completely wrong. I told him I was not in any way 19 coaching Mitch, At that point he stated on the record,"thank you for admitting that you just coached 20 the witness." Mr. Bacho has a custom and practice of misstating things that people have just said. I told 21 him he was wrong and misstating what I had said. He insisted I leave the house(my house) and I said 22 no,I would finish making my lunch and go back to my office. I assured him that once in my office, I 23 wear noise cancelling earphones and cannot hear anything. That is what I did. It was not a "stunt", and I 24 was not"coaching the witness". I did speak but not to Mitch. I spoke to myselfand my dogs. Mitch 25 may have heard me, Mr. Bacho did. I did not think about the fact that Mitch could hear me. Excluding 26 my critical testimony on this basis of Mr. Bacho's lies is patently wrong as I am the only person that 27 spoke with Osboume. Interestingly, I understand that Dagmar did the same thing (answered out loud) 28 when Barry was on the stand. DECLARATION OF JOYCE WHITAKER IN SUPPORT OF DEFENDANT'S POST-TRIAL MOTIONS RE FIRE Brilliant, et al. v. Black, et al., Sonoma County Superior Court Case No. SCV267406 1 29.1 would have testified at trial in accordance with the testimony in this Declaration. 2 30. In my opinion, I strongly feel that excluding my testimony is irreparable harm to 3 Defendants and worthy in and of itself, of granting a new trial. 4 I declare under penalty of perjury under the laws ofthe State of California the foregoing is 5 true and correct. 6 Dated; 4-13-23 7 8 Joj^eMiUaker 9 10 11 12 CD O a. T? ^ jS• £• o "o 14 pss < — v> C 15 16 •zSrai catg^Q 17 18 19 20 21 22 23 24 25 26 27 28 DECLARATION OF JOYCE VraiTAKER IN SUPPORT OF DEFENDANT'S POST-TRIAL MOTIONS RE FIRE Brilliant, et aJ. v. Black, et al.y Sonoma County Supenor Court Case No. SCV267406 EXHIBIT A ?9 "vji. -r,i . f-fsy/V-" . .' ^2t.* ^ "-''f "9?«':kMt:-- ■: -V.!|t,~-#S Sonoma County Fire District Ryan Osbome InspwUn" CeW: 707-r)08-^ 8200 old RccIhoocI Hwy onice; 7(li-Hy2-'i44i Windsor, C;A 95492 sonomacouiuyfd.ovg rosbon.e@soi.oinaroumyfd.org .'■•SI ■«f-l Vision Statement \Vc will position the fire district to provide Hsca' siislainability while providing excellence in emergency response and community preparedness. Mission Statement To compassionately care for the safety of our communities and our visitors through progressive professional emergency preparedness and response. 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