Preview
1 PAUL CALEO (SBN 153925)
pcaleo@grsm.com
2 MARK HEISEY (SBN 300141)
mheisey@grsm.com
3 GORDON REES SCULLY MANSUKHANI, LLP
1111 Broadway, Suite 1700
4 Oakland, CA 94607
Telephone: (510) 463-8600
5 Facsimile: (510) 984-1721
6 Attorneys for Defendant
BOYS & GIRLS CLUBS OF MONTEREY COUNTY
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8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 IN AND FOR THE COUNTY OF MONTEREY
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11 JANE BE DOE, and individual; Case No.: 21CV000805
Gordon Rees Scully Mansukhani, LLP
12 Plaintiff,
1111 Broadway, Suite 1700
DECLARATION OF MARK HEISEY IN
Oakland, CA 94607
13 v. SUPPORT OF BOYS & GIRLS CLUBs OF
MONTEREY COUNTY’S MOTION FOR
14 BIG BROTHERS BIG SISTERS OF SUMMARY JUDGMENT.
AMERICA, a California Corporation; BIG
15 BROTHERS BIG SISTERS OF MONTEREY
COUNTY, a California Corporation; BOYS & Date: August 4, 2023
16 GIRLS CLUB OF MONTEREY COUNTY, a Time: 8:30 a.m.
California Corporation; JON DAVID Dept.: 15
17 WOODY, an individual; and DOES 1 to 50;
18 Defendants.
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20 I, Mark Heisey, hereby declare as follows:
21 1. I am an attorney at law licensed to practice before the Courts of the State of
22 California and before this Court. I am an attorney with the law firm of Gordon & Rees LLP,
23 attorneys of record for Defendant Boys and Girls Clubs of Monterey County. If called as a
24 witness, I would and could competently testify thereto to all facts herein within my personal
25 knowledge except where stated upon information and belief.
26 2. Attached as Exhibit “A” is a true and correct copy of relevant portions of
27 Defendant Boys and Girls Clubs of Monterey County’s verified responses to Special
28 Interrogatories , set one,
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DECLARATION OF MARK HEISEY IN SUPPORT OF BOYS & GIRLS CLUBs OF MONTEREY
COUNTY’S MOTION FOR SUMMARY JUDGMENT.
1 I declare the following under the penalty of perjury under the laws of the State of
2 California and the United States of America that the foregoing is true and correct. Executed this
3 16th day of May, 2023, at San Rafael, California.
4
5 By:
Mark Heisey
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Gordon Rees Scully Mansukhani, LLP
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1111 Broadway, Suite 1700
Oakland, CA 94607
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DECLARATION OF MARK HEISEY IN SUPPORT OF BOYS & GIRLS CLUBs OF MONTEREY
COUNTY’S MOTION FOR SUMMARY JUDGMENT.
EXHIBIT A
1 PAUL CALEO (SBN 153925)
pcaleo@grsm.com
2 MARK HEISEY (SBN 300141)
mheisey@grsm.com
3 GORDON REES SCULLY MANSUKHANI, LLP
1111 Broadway, Suite 1700
4 Oakland, CA 94607
Telephone: (510) 463-8600
5 Facsimile: (510) 984-1721
6 Attorneys for Defendant
BOYS & GIRLS CLUB OF MONTEREY COUNTY
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 IN AND FOR THE COUNTY OF MONTEREY
10
11 JANE BE DOE, and individual; Case No.: 21CV000805
Gordon Rees Scully Mansukhani, LLP
12 Plaintiff,
1111 Broadway, Suite 1700
DEFENDANT BOYS & GIRLS CLUB OF
Oakland, CA 94607
13 v. MONTEREY COUNTY’S RESPONSES TO
PLAINTIFF’S SPECIAL
14 BIG BROTHERS BIG SISTERS OF INTERROGATORIES, SET ONE
AMERICA, a California Corporation; BIG
15 BROTHERS BIG SISTERS OF MONTEREY
COUNTY, a California Corporation; BOYS &
16 GIRLS CLUB OF MONTEREY COUNTY, a
California Corporation; JON DAVID Complaint Filed: March 12, 2021
17 WOODY, an individual; and DOES 1 to 50; FAC Filed: December 13, 2021
18 Defendants.
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PROPOUNDING PARTY: Plaintiff JANE BE DOE
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RESPONDING PARTY: Defendant BOYS & GIRLS CLUB OF MONTEREY
21 COUNTY
22 SET NO.: One
23 Pursuant to section 2030.010, et seq. of the California Code of Civil Procedure,
24 Defendant BOYS & GIRLS CLUB OF MONTEREY COUNTY (“Defendant”) hereby responds
25 to Plaintiff JANE BE DOE’s (“Plaintiff”) Special Interrogatories, Set One as follows:
26 RESPONSES TO SPECIAL INTERROGATORIES
27 SPECIAL INTERROGATORY NO. 1:
28 IDENTIFY ALL DOCUMENTS that EVIDENCE complaints of SEXUAL
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DEFENDANT BOYS & GIRLS CLUB OF MONTEREY COUNTY’S RESPONSES TO PLAINTIFF’S
SPECIAL INTERROGATORIES, SET ONE_
1 MISCONDUCT regarding WOODY.
2 RESPONSE TO REQUEST NO. 1:
3 Responding Party objects to this request on the ground that the information sought is
4 equally available to all parties involved in this matter. Responding Party objects to this request
5 on the ground it is vague and ambiguous, specifically in the use of the terms “complaints of
6 SEXUAL MISCONDUCT regarding WOODY.”
7 Subject to and without waiving said objections, Responding Party is aware only of the
8 public law enforcement records and criminal proceedings against Defendant WOODY which are
9 equally available to Plaintiff.
10 SPECIAL INTERROGATORY NO. 2:
11 IDENTIFY the DATE on which YOU learned that WOODY had sexually abused
Gordon Rees Scully Mansukhani, LLP
12 Plaintiff.
1111 Broadway, Suite 1700
Oakland, CA 94607
13 RESPONSE TO REQUEST NO. 2:
14 Responding Party objects to this request because in accordance with California Code of
15 Civil Procedure section 2030.220, it does not have personal knowledge sufficient to respond
16 fully to this request.
17 Subject to and without waiving said objection, Responding Party states that to the best of
18 its recollection, BGCMC became aware of the allegations against Woody in late 2010 or early
19 2011 after WOODY was criminally convicted. Because neither Plaintiff nor Defendant
20 WOODY were ever participants in BGCMC’s programs, Responding Party has never had
21 personal knowledge of any allegation that WOODY had sexually abused Plaintiff.
22 SPECIAL INTERROGATORY NO. 3:
23 IDENTIFY the DATE on which YOU learned that WOODY had sexually abused ANY
24 participant of Big Brothers Big Sisters of Monterey County.
25 RESPONSE TO REQUEST NO. 3:
26 Responding Party objects to this request because in accordance with California Code of
27 Civil Procedure section 2030.220, it does not have personal knowledge sufficient to respond
28 fully to this request. Responding Party objects to this request on the ground it is vague and
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DEFENDANT BOYS & GIRLS CLUB OF MONTEREY COUNTY’S RESPONSES TO PLAINTIFF’S
SPECIAL INTERROGATORIES, SET ONE_
1 ambiguous, specifically in the use of the terms “sexually abused ANY participant of Big
2 Brothers Big Sisters of Monterey County.”
3 Subject to and without waiving said objection, Responding Party states that to the best of
4 its recollection, BGCMC became aware of the allegations against Woody in late 2010 or early
5 2011 after WOODY was criminally convicted. Because neither Plaintiff nor Defendant
6 WOODY were ever participants in BGCMC’s programs, Responding Party has never had
7 personal knowledge of any allegation that WOODY had sexually abused ANY participant(s) of
8 Big Brothers Big Sisters of Monterey County.
9 SPECIAL INTERROGATORY NO. 4:
10 IDENTIFY the DATE on which YOU learned that WOODY was engaging in SEXUAL
11 MISCONDUCT with ANY minor.
Gordon Rees Scully Mansukhani, LLP
12 RESPONSE TO REQUEST NO. 4:
1111 Broadway, Suite 1700
Oakland, CA 94607
13 Responding Party objects to this request because in accordance with California Code of
14 Civil Procedure section 2030.220, it does not have personal knowledge sufficient to respond
15 fully to this request. Responding Party objects to this request on the ground it is vague and
16 ambiguous, specifically in the use of the terms “SEXUAL MISCONDUCT.”
17 Subject to and without waiving said objection, Responding Party states that to the best of
18 its recollection, BGCMC became aware of the allegations against Woody in late 2010 or early
19 2011 after WOODY was criminally convicted. Because Defendant WOODY was never a
20 volunteer or participant in BGCMC’s programs, Responding Party has never had personal
21 knowledge of any allegation that WOODY was engaging in SEXUAL MISCONDUCT with
22 ANY minor.
23 SPECIAL INTERROGATORY NO. 5:
24 IDENTIFY the DATE that WOODY became involved with YOU.
25 RESPONSE TO REQUEST NO. 5:
26 Responding Party objects to this request on the ground it is vague and ambiguous,
27 specifically in the use of the terms “became involved.”
28 Subject to and without waiving said objections, Responding Party is not aware of any
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DEFENDANT BOYS & GIRLS CLUB OF MONTEREY COUNTY’S RESPONSES TO PLAINTIFF’S
SPECIAL INTERROGATORIES, SET ONE_
1 relationship between Defendant Jon David Woody and BGCMC, in any capacity, at any time.
2 SPECIAL INTERROGATORY NO. 6:
3 IDENTIFY the DATE that WOODY became involved with Big Brothers Big Sisters
4 Monterey County.
5 RESPONSE TO REQUEST NO. 6:
6 Responding Party objects to this request because in accordance with California Code of
7 Civil Procedure section 2030.220, it does not have personal knowledge sufficient to respond
8 fully to this request. Responding Party objects to this request on the ground it is vague and
9 ambiguous, specifically in the use of the terms “became involved.”
10 Subject to and without waiving said objections, unknown as to Responding Party.
11 SPECIAL INTERROGATORY NO. 7:
Gordon Rees Scully Mansukhani, LLP
12 Do YOU contend that Big Brothers Big Sisters Monterey County conducted a
1111 Broadway, Suite 1700
Oakland, CA 94607
13 background check on WOODY prior to his involvement with Big Brothers Big Sisters Monterey
14 County?
15 RESPONSE TO REQUEST NO. 7:
16 Responding Party objects to this request on the ground it is vague and ambiguous,
17 specifically in the use of the terms “prior to [WOODY’s] involvement with Big Brothers Big
18 Sisters Monterey County.” Responding Party objects to this request because in accordance with
19 California Code of Civil Procedure section 2030.220, it does not have personal knowledge
20 sufficient to respond fully to this request. Responding Party objects to this request on the ground
21 it is premature, as it has not had sufficient time to conduct its own investigation.
22 Subject to and without waiving said objections, Not at this time. Responding Party
23 reserves the right to supplement this response at a later time.
24 SPECIAL INTERROGATORY NO. 8:
25 If YOU contend that Big Brothers Big Sisters Monterey County conducted a background
26 check on WOODY prior to his involvement with Big Brothers Big Sisters Monterey County,
27 state EACH fact upon which YOU base this contention.
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DEFENDANT BOYS & GIRLS CLUB OF MONTEREY COUNTY’S RESPONSES TO PLAINTIFF’S
SPECIAL INTERROGATORIES, SET ONE_
1 PROOF OF SERVICE
Doe, Jane (B.E.) v. Boys & Girls Clubs of Monterey
2 Monterey Superior Court, Case No.: 21CV000805
3 I am a resident of the State of California, over the age of eighteen years, and not a party
to the within action. My business address is: Gordon Rees Scully Mansukhani, LLP 275 Battery
4 Street, Suite 2000 San Francisco, CA 94111. On the date set forth below, I served the within
documents:
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DECLARATION OF MARK HEISEY IN SUPPORT OF BOYS & GIRLS CLUBS OF
6 MONTEREY COUNTY’S MOTION FOR SUMMARY JUDGMENT.
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by transmitting via facsimile the document(s) listed above to the fax number(s) set
forth below on this date before 5:00 p.m.
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VIA E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the
document(s) to be sent by electronically mailing a true and correct copy through the
9 Gordon Rees Scully Mansukhani, LLP electronic mail system from my email address:
khernandez@grsm.com, to the email address(s) set forth herein.
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by having Nationwide PERSONALLY DELIVER the document(s) listed above to the
person(s) at the address(es) set forth below.
Gordon Rees Scully Mansukhani, LLP
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by placing the document(s) listed above in a sealed envelope with postage thereon
1111 Broadway, Suite 1700
fully prepaid, in United States mail in the State of California at San Francisco,
Oakland, CA 94607
13 addressed as set forth below.
by placing a true copy thereof enclosed in a sealed envelope, at a station designated
14 for collection and processing of envelopes and packages for overnight delivery by
FEDEX as part of the ordinary business practices of Gordon Rees Scully Mansukhani,
15 LLP described below, addressed as follows:
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Attorneys for Plaintiff Attorneys for Defendant
17 JANE BE DOE BIG BROTHERS BIG SISTERS OF AMERICA
18 John C. Manly, Esq. Alison M. Crane, Esq.
Vince W. Finaldi, Esq. BLEDSOE, DIESTEL, TREPPA & CRANE
19 Alex E. Cunny, Esq. LLP
Courtney P. Pendry, Esq.
20 MANLY, STEWART & FINALDI 180 Sansome, 5th Floor
19100 Von Karman Ave., Suite 800 San Francisco, CA 94104
21 Irvine, CA 92612 Tel: (415) 981-5411
Tel: (949) 252-9990. Fax: (415) 981-0352
22 Fax: (949) 252-9991 Email: acrane@bledsoelaw.com
Email: jmanly@manlystewart.com tmurray@bledsoelaw.com
23 vfinaldi@manlystewart.com calendar@bledsoelaw.com
cpendry@manlystewart.com lkettle@bledsoelaw.com
24 kfrederiksen@manlystewart.com
sanwar@manlystewart.com
25 sanwar@manlystewart.com
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DECLARATION OF MARK HEISEY IN SUPPORT OF BOYS & GIRLS CLUBs OF MONTEREY
COUNTY’S MOTION FOR SUMMARY JUDGMENT.
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I declare under penalty of perjury under the laws of the State of California that the above
2 is true and correct.
3 Executed on May 16, 2023 at San Francisco, California.
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Kristie Hernandez
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Gordon Rees Scully Mansukhani, LLP
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1111 Broadway, Suite 1700
Oakland, CA 94607
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DECLARATION OF MARK HEISEY IN SUPPORT OF BOYS & GIRLS CLUBs OF MONTEREY
COUNTY’S MOTION FOR SUMMARY JUDGMENT.
Preview
1 PAUL CALEO (SBN 153925) pcaleo@grsm.com 2 MARK HEISEY (SBN 300141) mheisey@grsm.com 3 GORDON REES SCULLY MANSUKHANI, LLP 1111 Broadway, Suite 1700 4 Oakland, CA 94607 Telephone: (510) 463-8600 5 Facsimile: (510) 984-1721 6 Attorneys for Defendant BOYS & GIRLS CLUBS OF MONTEREY COUNTY 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FOR THE COUNTY OF MONTEREY 10 11 JANE BE DOE, and individual; Case No.: 21CV000805 Gordon Rees Scully Mansukhani, LLP 12 Plaintiff, 1111 Broadway, Suite 1700 DECLARATION OF MARK HEISEY IN Oakland, CA 94607 13 v. SUPPORT OF BOYS & GIRLS CLUBs OF MONTEREY COUNTY’S MOTION FOR 14 BIG BROTHERS BIG SISTERS OF SUMMARY JUDGMENT. AMERICA, a California Corporation; BIG 15 BROTHERS BIG SISTERS OF MONTEREY COUNTY, a California Corporation; BOYS & Date: August 4, 2023 16 GIRLS CLUB OF MONTEREY COUNTY, a Time: 8:30 a.m. California Corporation; JON DAVID Dept.: 15 17 WOODY, an individual; and DOES 1 to 50; 18 Defendants. 19 20 I, Mark Heisey, hereby declare as follows: 21 1. I am an attorney at law licensed to practice before the Courts of the State of 22 California and before this Court. I am an attorney with the law firm of Gordon & Rees LLP, 23 attorneys of record for Defendant Boys and Girls Clubs of Monterey County. If called as a 24 witness, I would and could competently testify thereto to all facts herein within my personal 25 knowledge except where stated upon information and belief. 26 2. Attached as Exhibit “A” is a true and correct copy of relevant portions of 27 Defendant Boys and Girls Clubs of Monterey County’s verified responses to Special 28 Interrogatories , set one, -1- DECLARATION OF MARK HEISEY IN SUPPORT OF BOYS & GIRLS CLUBs OF MONTEREY COUNTY’S MOTION FOR SUMMARY JUDGMENT. 1 I declare the following under the penalty of perjury under the laws of the State of 2 California and the United States of America that the foregoing is true and correct. Executed this 3 16th day of May, 2023, at San Rafael, California. 4 5 By: Mark Heisey 6 7 8 9 10 11 Gordon Rees Scully Mansukhani, LLP 12 1111 Broadway, Suite 1700 Oakland, CA 94607 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -2- DECLARATION OF MARK HEISEY IN SUPPORT OF BOYS & GIRLS CLUBs OF MONTEREY COUNTY’S MOTION FOR SUMMARY JUDGMENT. EXHIBIT A 1 PAUL CALEO (SBN 153925) pcaleo@grsm.com 2 MARK HEISEY (SBN 300141) mheisey@grsm.com 3 GORDON REES SCULLY MANSUKHANI, LLP 1111 Broadway, Suite 1700 4 Oakland, CA 94607 Telephone: (510) 463-8600 5 Facsimile: (510) 984-1721 6 Attorneys for Defendant BOYS & GIRLS CLUB OF MONTEREY COUNTY 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FOR THE COUNTY OF MONTEREY 10 11 JANE BE DOE, and individual; Case No.: 21CV000805 Gordon Rees Scully Mansukhani, LLP 12 Plaintiff, 1111 Broadway, Suite 1700 DEFENDANT BOYS & GIRLS CLUB OF Oakland, CA 94607 13 v. MONTEREY COUNTY’S RESPONSES TO PLAINTIFF’S SPECIAL 14 BIG BROTHERS BIG SISTERS OF INTERROGATORIES, SET ONE AMERICA, a California Corporation; BIG 15 BROTHERS BIG SISTERS OF MONTEREY COUNTY, a California Corporation; BOYS & 16 GIRLS CLUB OF MONTEREY COUNTY, a California Corporation; JON DAVID Complaint Filed: March 12, 2021 17 WOODY, an individual; and DOES 1 to 50; FAC Filed: December 13, 2021 18 Defendants. 19 PROPOUNDING PARTY: Plaintiff JANE BE DOE 20 RESPONDING PARTY: Defendant BOYS & GIRLS CLUB OF MONTEREY 21 COUNTY 22 SET NO.: One 23 Pursuant to section 2030.010, et seq. of the California Code of Civil Procedure, 24 Defendant BOYS & GIRLS CLUB OF MONTEREY COUNTY (“Defendant”) hereby responds 25 to Plaintiff JANE BE DOE’s (“Plaintiff”) Special Interrogatories, Set One as follows: 26 RESPONSES TO SPECIAL INTERROGATORIES 27 SPECIAL INTERROGATORY NO. 1: 28 IDENTIFY ALL DOCUMENTS that EVIDENCE complaints of SEXUAL -1- DEFENDANT BOYS & GIRLS CLUB OF MONTEREY COUNTY’S RESPONSES TO PLAINTIFF’S SPECIAL INTERROGATORIES, SET ONE_ 1 MISCONDUCT regarding WOODY. 2 RESPONSE TO REQUEST NO. 1: 3 Responding Party objects to this request on the ground that the information sought is 4 equally available to all parties involved in this matter. Responding Party objects to this request 5 on the ground it is vague and ambiguous, specifically in the use of the terms “complaints of 6 SEXUAL MISCONDUCT regarding WOODY.” 7 Subject to and without waiving said objections, Responding Party is aware only of the 8 public law enforcement records and criminal proceedings against Defendant WOODY which are 9 equally available to Plaintiff. 10 SPECIAL INTERROGATORY NO. 2: 11 IDENTIFY the DATE on which YOU learned that WOODY had sexually abused Gordon Rees Scully Mansukhani, LLP 12 Plaintiff. 1111 Broadway, Suite 1700 Oakland, CA 94607 13 RESPONSE TO REQUEST NO. 2: 14 Responding Party objects to this request because in accordance with California Code of 15 Civil Procedure section 2030.220, it does not have personal knowledge sufficient to respond 16 fully to this request. 17 Subject to and without waiving said objection, Responding Party states that to the best of 18 its recollection, BGCMC became aware of the allegations against Woody in late 2010 or early 19 2011 after WOODY was criminally convicted. Because neither Plaintiff nor Defendant 20 WOODY were ever participants in BGCMC’s programs, Responding Party has never had 21 personal knowledge of any allegation that WOODY had sexually abused Plaintiff. 22 SPECIAL INTERROGATORY NO. 3: 23 IDENTIFY the DATE on which YOU learned that WOODY had sexually abused ANY 24 participant of Big Brothers Big Sisters of Monterey County. 25 RESPONSE TO REQUEST NO. 3: 26 Responding Party objects to this request because in accordance with California Code of 27 Civil Procedure section 2030.220, it does not have personal knowledge sufficient to respond 28 fully to this request. Responding Party objects to this request on the ground it is vague and -2- DEFENDANT BOYS & GIRLS CLUB OF MONTEREY COUNTY’S RESPONSES TO PLAINTIFF’S SPECIAL INTERROGATORIES, SET ONE_ 1 ambiguous, specifically in the use of the terms “sexually abused ANY participant of Big 2 Brothers Big Sisters of Monterey County.” 3 Subject to and without waiving said objection, Responding Party states that to the best of 4 its recollection, BGCMC became aware of the allegations against Woody in late 2010 or early 5 2011 after WOODY was criminally convicted. Because neither Plaintiff nor Defendant 6 WOODY were ever participants in BGCMC’s programs, Responding Party has never had 7 personal knowledge of any allegation that WOODY had sexually abused ANY participant(s) of 8 Big Brothers Big Sisters of Monterey County. 9 SPECIAL INTERROGATORY NO. 4: 10 IDENTIFY the DATE on which YOU learned that WOODY was engaging in SEXUAL 11 MISCONDUCT with ANY minor. Gordon Rees Scully Mansukhani, LLP 12 RESPONSE TO REQUEST NO. 4: 1111 Broadway, Suite 1700 Oakland, CA 94607 13 Responding Party objects to this request because in accordance with California Code of 14 Civil Procedure section 2030.220, it does not have personal knowledge sufficient to respond 15 fully to this request. Responding Party objects to this request on the ground it is vague and 16 ambiguous, specifically in the use of the terms “SEXUAL MISCONDUCT.” 17 Subject to and without waiving said objection, Responding Party states that to the best of 18 its recollection, BGCMC became aware of the allegations against Woody in late 2010 or early 19 2011 after WOODY was criminally convicted. Because Defendant WOODY was never a 20 volunteer or participant in BGCMC’s programs, Responding Party has never had personal 21 knowledge of any allegation that WOODY was engaging in SEXUAL MISCONDUCT with 22 ANY minor. 23 SPECIAL INTERROGATORY NO. 5: 24 IDENTIFY the DATE that WOODY became involved with YOU. 25 RESPONSE TO REQUEST NO. 5: 26 Responding Party objects to this request on the ground it is vague and ambiguous, 27 specifically in the use of the terms “became involved.” 28 Subject to and without waiving said objections, Responding Party is not aware of any -3- DEFENDANT BOYS & GIRLS CLUB OF MONTEREY COUNTY’S RESPONSES TO PLAINTIFF’S SPECIAL INTERROGATORIES, SET ONE_ 1 relationship between Defendant Jon David Woody and BGCMC, in any capacity, at any time. 2 SPECIAL INTERROGATORY NO. 6: 3 IDENTIFY the DATE that WOODY became involved with Big Brothers Big Sisters 4 Monterey County. 5 RESPONSE TO REQUEST NO. 6: 6 Responding Party objects to this request because in accordance with California Code of 7 Civil Procedure section 2030.220, it does not have personal knowledge sufficient to respond 8 fully to this request. Responding Party objects to this request on the ground it is vague and 9 ambiguous, specifically in the use of the terms “became involved.” 10 Subject to and without waiving said objections, unknown as to Responding Party. 11 SPECIAL INTERROGATORY NO. 7: Gordon Rees Scully Mansukhani, LLP 12 Do YOU contend that Big Brothers Big Sisters Monterey County conducted a 1111 Broadway, Suite 1700 Oakland, CA 94607 13 background check on WOODY prior to his involvement with Big Brothers Big Sisters Monterey 14 County? 15 RESPONSE TO REQUEST NO. 7: 16 Responding Party objects to this request on the ground it is vague and ambiguous, 17 specifically in the use of the terms “prior to [WOODY’s] involvement with Big Brothers Big 18 Sisters Monterey County.” Responding Party objects to this request because in accordance with 19 California Code of Civil Procedure section 2030.220, it does not have personal knowledge 20 sufficient to respond fully to this request. Responding Party objects to this request on the ground 21 it is premature, as it has not had sufficient time to conduct its own investigation. 22 Subject to and without waiving said objections, Not at this time. Responding Party 23 reserves the right to supplement this response at a later time. 24 SPECIAL INTERROGATORY NO. 8: 25 If YOU contend that Big Brothers Big Sisters Monterey County conducted a background 26 check on WOODY prior to his involvement with Big Brothers Big Sisters Monterey County, 27 state EACH fact upon which YOU base this contention. 28 -4- DEFENDANT BOYS & GIRLS CLUB OF MONTEREY COUNTY’S RESPONSES TO PLAINTIFF’S SPECIAL INTERROGATORIES, SET ONE_ 1 PROOF OF SERVICE Doe, Jane (B.E.) v. Boys & Girls Clubs of Monterey 2 Monterey Superior Court, Case No.: 21CV000805 3 I am a resident of the State of California, over the age of eighteen years, and not a party to the within action. My business address is: Gordon Rees Scully Mansukhani, LLP 275 Battery 4 Street, Suite 2000 San Francisco, CA 94111. On the date set forth below, I served the within documents: 5 DECLARATION OF MARK HEISEY IN SUPPORT OF BOYS & GIRLS CLUBS OF 6 MONTEREY COUNTY’S MOTION FOR SUMMARY JUDGMENT. 7 by transmitting via facsimile the document(s) listed above to the fax number(s) set forth below on this date before 5:00 p.m. 8 VIA E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the document(s) to be sent by electronically mailing a true and correct copy through the 9 Gordon Rees Scully Mansukhani, LLP electronic mail system from my email address: khernandez@grsm.com, to the email address(s) set forth herein. 10 11 by having Nationwide PERSONALLY DELIVER the document(s) listed above to the person(s) at the address(es) set forth below. Gordon Rees Scully Mansukhani, LLP 12 by placing the document(s) listed above in a sealed envelope with postage thereon 1111 Broadway, Suite 1700 fully prepaid, in United States mail in the State of California at San Francisco, Oakland, CA 94607 13 addressed as set forth below. by placing a true copy thereof enclosed in a sealed envelope, at a station designated 14 for collection and processing of envelopes and packages for overnight delivery by FEDEX as part of the ordinary business practices of Gordon Rees Scully Mansukhani, 15 LLP described below, addressed as follows: 16 Attorneys for Plaintiff Attorneys for Defendant 17 JANE BE DOE BIG BROTHERS BIG SISTERS OF AMERICA 18 John C. Manly, Esq. Alison M. Crane, Esq. Vince W. Finaldi, Esq. BLEDSOE, DIESTEL, TREPPA & CRANE 19 Alex E. Cunny, Esq. LLP Courtney P. Pendry, Esq. 20 MANLY, STEWART & FINALDI 180 Sansome, 5th Floor 19100 Von Karman Ave., Suite 800 San Francisco, CA 94104 21 Irvine, CA 92612 Tel: (415) 981-5411 Tel: (949) 252-9990. Fax: (415) 981-0352 22 Fax: (949) 252-9991 Email: acrane@bledsoelaw.com Email: jmanly@manlystewart.com tmurray@bledsoelaw.com 23 vfinaldi@manlystewart.com calendar@bledsoelaw.com cpendry@manlystewart.com lkettle@bledsoelaw.com 24 kfrederiksen@manlystewart.com sanwar@manlystewart.com 25 sanwar@manlystewart.com 26 27 28 -3- DECLARATION OF MARK HEISEY IN SUPPORT OF BOYS & GIRLS CLUBs OF MONTEREY COUNTY’S MOTION FOR SUMMARY JUDGMENT. 1 I declare under penalty of perjury under the laws of the State of California that the above 2 is true and correct. 3 Executed on May 16, 2023 at San Francisco, California. 4 Kristie Hernandez 5 6 7 8 9 10 11 Gordon Rees Scully Mansukhani, LLP 12 1111 Broadway, Suite 1700 Oakland, CA 94607 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -4- DECLARATION OF MARK HEISEY IN SUPPORT OF BOYS & GIRLS CLUBs OF MONTEREY COUNTY’S MOTION FOR SUMMARY JUDGMENT.