Document for Juanita Olson vs Lidia Ryan

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                                1    JOHN P. HANNON II
     Law Offices of John P. Hannon II
2    SBNo: 111692
     273 Knappton Road
3    Naselle, WA 98638
     PH: (831) 239-4809
4    E-Mail: jph3003@yahoo.com
5    Attorney for Plaintiff:
     JUANITA OLSON
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 7
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 9                  IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
10                                     COUNTY OF SANTA CRUZ
11
12   JUANITA OLSON,                                )         CASE NO.: 21CV00921
                                                   )
13                  Plaintiff,                     )
                                                   )         DECLARATION OF JUANITA OLSON
14   V.                                            )         IN SUPPORT OF MOTION FOR
                                                   )         SUMMARY JUDGMENT AND
15   LIDIA RYAN, et al.,                           )         SUMMARY ADJUDICATION OF FACT
                                                   )
16                   Defendants.                   )
                                                             Hearing Date:       7/10/2023
17                                                 )         Time:               8:30 a.m.
     AND RELATED CROSS-ACTION,                     )         Dept.:              5
18                                                           Judge:              T. Volkmann
19           I, Juanita Olson, hereby declare:
20           1. The Amendment for the Partition for the Santa Cruz Mobile home is about the on-going
21   abuse suffered by Juanita Olson, a Person of Disability, caused by Lidia Ryan ever since the day
22   Ms. Ryan and Ms. Olson purchased the Santa Cruz Mobile Home, August 2012. This includes the
23   unthinkable abuses caused by Ms. Ryan with the SSF house that we inherited, August 2018.
24           2. Ms. Ryan's response to the Amended lawsuit for Partition does not address any of the
25   multiple abuses she has committed on a Person of Disability outlined in the Amendment. Instead
26   Ms. Ryan sends her "exhibit emails" that only shows her defiance in abiding by the Law and
27   trying to build a fictitious case that she is the one who is being abused, harassed and threatened by
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ATTACHMENTS
• Palo Alto Medical Foundation
       A Sutter Health Affiliate

       Santa Cruz
                                                                  MAIN RHEUMATOLOGY
2025 Soquel A venue                                                    2025 SOQUEL AVE
Santa Cruz, CA 95062                                               SANTA CRUZ CA 95062
(831) 423-4111                                                               831-423-4111
www.pamf.org



November 2, 2021

To Whom It May Concern:

        Juanita Olson is under my care for management of systemic lupus erythematosus. In
July of 2021 she required prolonged hospitalization for severe and life-threatening
complications stemming from underlying herpes simplex virus infection.

        She has a complex medical history contributing to her increased risk for severe
infections including chronic immunosuppressive medication use for management of her
underlying lupus. Additionally prior to her hospitalization she was experiencing severe stress,
which may precipitate HSV reactivation, and contribute to this subsequent complications she
experienced.

Please feel free to contact me with any questions or concerns.


Matthew Reimert, MD



�
...__,,,__ :-?
          PROOF OF SERVICE BY OVERNIGHT DELIVERY AND E-MAIL


        The undersigned hereby declares that he/she is over the age of 18 years and not a party
to the action. The undersigned's business address is 273 Knappton Road, Naselle, WA 98638.

       On the date last written, the undersigned delivered the following document(s):

Declaration of Juanita Olson in Support of Motion for Summary Judgment and
Summary Adjudication of Fact.


by personally sending by overnight mail through United Postal Service and by e-mailing the
above listed document(s) on the same date of signature hereto to the address(es) and e-mail(s)
set forth:

Lidia Ryan
3970 Harney Road
San Diego, CA 92110

               Also via e-mail: rriver.ryan@gmail.com




       I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.

                                                             BY:-.:::--__
                                                                       -  -�/  .        -
                                                                   JOHN P. HANNON II