Motion-Secondary: GRAHAM RIDINGER, ET AL. VS ATRIA SENIOR LIVING, INC., ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 03/16/2021 01:35 PM Sherri R. Carter, Executive Officer/Clerk of Court, by J. Gonzalez,Deputy Clerk




                                        1 GLENN STERN LAW
                                          Glenn E. Stern SB # 84485
                                        2 Matthew P. Malczynski SB # 271258
                                        3 829 East Route 66
                                          Glendora, CA 91740
                                        4 Telephone: 626-335-6844
                                          Facsimile: 213-232-7111
                                        5
                                        6 Attorneys for Plaintiffs THE ESTATE OF NANCY VEZINA, by and through its Successor-
                                          in-Interest, GRAHAM RIDINGER, and GRAHAM RIDINGER, an individual and
                                        7 Successor-in-Interest to THE ESTATE OF NANCY VEZINA
                                        8
                                                       SUPERIOR COURT OF THE STATE OF CALIFORNIA
                                        9           COUNTY OF LOS ANGELES – POMONA COURTHOUSE SOUTH

                                       10
                                            THE ESTATE OF NANCY VEZINA, by                   )       Case No. 20STCV34803
                                       11
                                            and through its Successor-In-Interest,           )
                                       12   GRAHAM RIDINGER; and GRAHAM                      )        DECLARATION OF MATTHEW P.
                                            RIDINGER, individually and as                    )        MALCZYNSKI IN SUPPORT OF
                                       13   Successor-In-Interest to THE ESTATE              )        PLAINTIFFS’ REPLY
  LAW OFFICE OF GLENN E. STERN


  (626) 963-7430, FAX (626) 232-7111




                                       14   OF NANCY VEZINA,                                 )        MEMORANDUM OF POINTS AND
          807 No. Verano Drive
           Glendora, CA 91741




                                                                                             )        AUTHORITIES IN SUPPORT OF
                                       15                        Plaintiffs,                 )        MOTION TO QUASH DEPOSITION
                                                                                             )        SUBPOENAS FOR PRODUCTION
                                       16              vs.                                   )        OF BUSINESS RECORDS AND
                                       17                                                    )        REQUEST FOR MONTEARY
                                            ATRIA SENIOR LIVING, INC., a                     )        SANCTION AGAINST
                                       18   California Corporation; JEN JOHNSON,             )        DEFENDANTS AND THEIR
                                            an individual; SUBASHSANI KUMAR,                 )        COUNSEL
                                       19   an individual; , and DOES 1 through 50,          )
                                       20   inclusive,                                       )        [Filed concurrently with Reply
                                                                                             )         Memorandum of Points and Authorities]
                                       21                        Defendants.                 )
                                                                                             )        Date:          March 23, 2021
                                       22                                                    )        Time:          10:00 a.m.
                                       23                                                    )        Dept.:         J
                                                                                             )
                                       24                                                    )        Judge: Honorable Gloria White-Brown
                                                                                             )
                                       25
                                                                                             )        RESERVATION NO:
                                       26                                                    )        490352681364245405506043
                                                                                             )
                                       27                                                    )
                                       28
                                            DECLARATION OF MATTHEW P. MALCZYNSKI IN SUPPPORT OF REPLY MEMORANDUM OF POINTS AND AUTHORITIES
                                               IN SUPPORT OF MOTION TO QUASH DEPOSITION SUBPOENAS FOR PRODUCTION OF BUSINESS RECORDS AND
                                                                            REQUEST FOR MONETARY SANCTIONS