Motion-Secondary: DAN CONTRACTOR, A SOLE PROPRIETORSHIP VS MARIA SAAVEDRA

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 09/29/2021 02:31 PM Sherri R. Carter, Executive Officer/Clerk of Court, by H. Aldana,Deputy Clerk


                       K. Elizabeth
                       Law Office of K.E. Cronin
                       12503 Ventura Blvd,
                       Studio City, CA 91604
                       Tel.: 323-360-4550
                       Email: kecronin1@gmail.com
                       Attorney for maria saavedra
                       SUPERIOR COURT OF THE STATE OF CALIFORNIA
                       COUNTY OF LOS ANGELES

                                                                                                  Case No.: Number: 20STLC06226
                         DAN CONTRACTOR, a sole proprietorship,
                                                                                                  DECLARATIONS IN SUPPORT OF Notice
                         Plaintiff,
                                                                                                  of motion and motion for summary judgment
                         vs.
                                                            [filed concurrently with memordanum of
                         MARIA SAAVEDRA, AN INDIVIDUAL;
                                                            points and authorities; separate statement of
                         AND DOES 1 THROUGH 50, INCLUSIVE ,
                                                            undisputed material facts;
                         Defendants
                                                            exhibits’ (proposed) order; and proof of
                                                            service]

                                                                                                  date: 12/13/2021
                                                                                                  Time: 10:30
                                                                                                  Dept: 26
                                                                                                  Judge: HON. UPINDER S KALRA

                                                                DECLARATION OF
                       I, _K. Elizabeth Cronin, declare as follows.
                                         1.      I am over the age of 18 years and am not a party to this action. I have
                                         personal
                       knowledge of the facts stated in this declaration, and if called as a witness, could and would
                       testify competently to the truth of the facts as stated herein.
                       2.       I am an active member of the State Bar of California. My California State Bar Number is
                       159922. I am providing services to Defendant on a pro bono basis on an assignment from Public
                       Counsel. I do not maintain a legal office as I am part owner of a family business. I do, however,
                       periodically, assist other attorneys with their cases. As our family business was closed during the
                       shutdown, I decided to undertake pro bono work. I chose to assist Defendant as I have been
                       involved in various construction projects. While I have done my best to provide assistant to
                       Defendant the closure of the law library and other avenues of support have proved difficult.
                       3.       During the course of this controversy, there have been various communication with the
                       Plaintiff’s attorney. The attorney stated that Defendant should bring in the City of Bell as a
                       Defendant. I do not believe it is the job of Defendant to assist in the prosecution of this matter
                       for Plaintiff. In fact, I believe it would have been detrimental to Defendant to do so as it was
                       important to maintain a working relationship with the City to do essential repairs on the installed
                       windows which were leaking. Moreover, until recently the City of Bell had been the owner of the
                       property where Defendant resided and good will with her landlord was important to her.
                       5.       After ongoing communication among the attorney for the City of Bell, the Plaintiff’s
                       attorney and myself, the attorney for the City of Bell proposed a settlement to Plaintiff. A true