Motion-Secondary: JOE E COLLINS, III VS DEAN C LOGAN, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 06/18/2021 11:43 AM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Bolden,Deputy Clerk



                                                                                                                                                                            CIV-141
           ATTORNEY OR PARTY WITHOUT ATTORNEY:                         STATE BAR NO:   299794                                                  FOR COURT USE ONLY
           NAME:  Taylor J. Pohle
           FIRM NAME: Collins + Collins LLP                                                       Fee Exempt Pursuant to Gov. Code § 6103
           STREET ADDRESS: 790 E. Colorado Boulevard, Suite 600
           CITY: Pasadena                                      STATE: CA     ZIP CODE: 91101
           TELEPHONE NO.: 626-243-1100                        FAX NO.: 626-243-1111

           E-MAIL ADDRESS: tpohle@ccllp.law

           ATTORNEY FOR (Name): County of Los Angeles; Registrar-Recorder/County Clerk Dean Logan

           SUPERIOR COURT OF CALIFORNIA, COUNTY OF Los Angeles
            STREET ADDRESS: 111 North Hill Street
            MAILING ADDRESS: 111 North Hill Street
           CITY AND ZIP CODE:  Los Angeles 90012
               BRANCH NAME: Stanley Mosk Courthouse

                 PLAINTIFF/PETITIONER: Joe E. Collins III
            DEFENDANT/RESPONDENT: Dean C. Logan, et al.

                                                                                                                              CASE NUMBER:
                              DECLARATION OF DEMURRING OR MOVING PARTY                                                        20STCV49928
                                       IN SUPPORT OF AUTOMATIC EXTENSION

          1. (Name of party): County of Los Angeles; Registrar-Recorder/County Clerk Dean Logan was served with

                      a complaint                  an amended complaint                            a cross-complaint
                      an answer                    other (specify):
              in the above-titled action.
          2. For a demurrer or motion to strike, a responsive pleading is due on (date): June 18, 2021

                                                                           DECLARATION
           I intend to file a demurrer, motion to strike, or motion for judgment on the pleadings in this action. Before I can do so, I am required to
           meet and confer with the party who filed the pleading that I am responding to at least five days before the date when the responsive
           pleading is due (if I am filing a demurrer or motion to strike) and at least five days before the last day a motion for judgment on the
           pleadings may be filed (if I am filing a motion for judgment on the pleadings). We have not been able to meet and confer. I have not
           previously requested an automatic extension of time. Therefore, on timely filing and serving a declaration that meets the requirements
           of Code of Civil Procedure sections 430.41, 435.5, or 439, I am entitled to an automatic 30-day extension of time within which to file a
           responsive pleading or motion for judgment on the pleadings.
           I made a good faith attempt to meet and confer with the party who filed the pleading at least five days before the date the responsive
           pleading was due (if I am filing a demurrer or motion to strike) and at least five days before the last day a motion for judgment on the
           pleadings may be filed (if I am filing a motion for judgment on the pleadings). I was unable to meet with that party because
           (the reasons why the parties could not meet and confer are stated):
                          below              on form MC-031, Attached Declaration
                   On May 13, 2021, I e-mailed Plaintiff's attorney Donna Bullock and stated that the Complaint was untimely and that I wished to
                   meet and confer. On May 17, 2021, Ms. Bullock responded by e-mail stating she would get back to me "next week" because she
                   had not received directions from her client and because she taking a short bereavement leave. On May, 26, 2021, after not
                   hearing any response, I again e-mailed Ms. Bullock. On May 27, 2021, Ms. Bullock e-mailed me stating that she was out on
                   bereavement leave, that she had not had the opportunity to discuss the case, and that she had not performed the "required
                   research." On June 2, 2021, Ms. Bullock agreed to extend my clients' responsive pleading deadline to June 18, 2021. On June 15,
                   2021, still having heard no response, I again e-mailed Ms. Bullock. On June 17, 2021, I left Ms. Bullock a voicemail and sent her
                   an e-mail requesting that she respond to my earlier e-mails and provide Plaintiff's position on the viability of the Complaint. As of
                   the date I execute this declaration, Ms. Bullock has not found time to meet and confer with me by telephone or in person.




                   I declare under penalty of perjury under the laws of the State of California that the information above is true and correct.
                 Date: June 18, 2021

                 Taylor J. Pohle
                                      (NAME OF PARTY OR ATTORNEY FOR PARTY)                                  (SIGNATURE OF PARTY OR ATTORNEY FOR PARTY)

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          Form Approved for Optional Use
          Judicial Council of California
                                                        DECLARATION OF DEMURRING OR MOVING PARTY                                                                  Code of Civil Procedure,
                                                                                                                                                                    §§ 430.41, 435.5, 439
          CIV-141 [Rev. January 1, 2019]                                                                                                                               www.courts.ca.gov
                                                                IN SUPPORT OF AUTOMATIC EXTENSION