Motion-Secondary: Schmid vs Two Rock Fire Dept

• 
• 
• 
• 

						
                                
Preview
                                1   William L. Adams SBN 166027
     WILLIAM L. ADAMS, PC
 2   P.O. Box 1050
     Windsor, CA 95492-1050
 3   Telephone:    (707) 236-2176
     Email:        wbill@wladamspc.com
 4
     Attorneys for Defendant
 5   TWO ROCK VOLUNTEER FIRE DEPARTMENT
 6

 7

 8                       SUPERIOR COURT OF THE STATE OF CALIFORNIA
 9                               IN AND FOR THE COUNTY OF SONOMA

10   FREAR STEPHEN SCHMID AND                           Case No. SCV-266225 and consolidated
     ASTRID SCHMID,                                     actions SCV-266731 and SCV-270339
11
                   Plaintiffs,
12                                                      DECLARATION OF WILLIAM L.
            v.                                          ADAMS IN SUPPORT OF DEFENDANT
13                                                      TWO ROCK VOLUNTEER FIRE
                                                        DEPARTMENT’S REPLY IN SUPPORT
14   TWO ROCK VOLUNTEER FIRE                            OF ITS MOTION TO COMPEL
     DEPARTMENT,                                        ANSWERS AND PRODUCTION OF
15                                                      DOCUMENTS AT THE CONTINUED
                   Defendant.                           DEPOSITION OF PLAINTIFF ASTRID
16                                                      SCHMID: AND FOR SANCTIONS
17                                                      Hearing Date: May 10, 2023
                                                        Time:         3:00 p.m.
18                                                      Department: 19
19                                                      Trial Call:      July 14, 2023
                                                        Time:            8:30 a.m.
20   AND CONSOLIDATED ACTIONS.                          Department:      19
21

22          I, WILLIAM L. ADAMS, declare:

23          1.     I am an attorney duly licensed to practice before all Courts in the State of California

24   and attorney of record for Defendant Two Rock Volunteer Fire Department, also known as Two

25   Rock Fire Department (“Two Rock Fire”) in this consolidated case.

26          2.     I make this Declaration in support of the Two Rock Fire’s Reply to its Motion to

27   Compel Answers and Production of Documents at a Continued Deposition of Plaintiff ASTRID

28   SCHMID (“Plaintiff”). I have personal knowledge of the facts set forth herein and the Reply, which
                                        1
     DECLARATION OF WILLIAM L. ADAMS IN SUPPORT OF TRVFD REPLY IN SUPPORT OF
      ITS MOTION TO COMPEL CONTINUED DEPOSITION OF PLAINTIFF ASTRID SCHMID
 1   are true, and if called upon to testify thereto in a court of law, I could and would do so competently.

 2   Pursuant to Evidence Code section 452(d), I respectfully request the Court take judicial notice of

 3   the entirety of its own files and records in this consolidated matter.

 4          3.      Two Rock Fire objects and moves to strike the joint Response to Separate Statement

 5   document filed by Plaintiffs. It not only does not comply with CRC 3.1345, but is not supported by

 6   party declaration, request for judicial notice or other evidentiary authentication in its purported

 7   references to the record.

 8          I declare under the penalty of perjury under the laws of the State of California that the

 9   foregoing is true and correct. Executed in Windsor, California.

10

11   Dated: May 3, 2023
                                                    William L. Adams
12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28
                                        2
     DECLARATION OF WILLIAM L. ADAMS IN SUPPORT OF TRVFD REPLY IN SUPPORT OF
      ITS MOTION TO COMPEL CONTINUED DEPOSITION OF PLAINTIFF ASTRID SCHMID