Motion-Secondary: VICTOR MATHIS VS SPEEDY CASH, A CORPORATION, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 03/23/2021 01:03 PM Sherri R. Carter, Executive Officer/Clerk of Court, by L. Coreas,Deputy Clerk



                     I      LAW OFFICES OF
                            WILLIAM GREEN A ASSOCIATES
                     2      Michael P. O'ullivan, Esq. S/B 171952
                            3419 Via Lido, ¹607
                     3      Newport Beach, California 92663-3908
                            Tel: (714) 282-9000
                    4       Fax: (714) 282-9067
                            Email: mosullivan aetereenlaw.corn
                     5      Attorneys for Plaintiff,
                            VICTOR MATHIS
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                                                             SUPERIOR COURT OF THE STATE OF CALIFORNIA
                                                                                    COUNTY OF LOS ANGELES
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                   11         VICTOR MATHIS,                                                                   CASE NO. 20STCV31696

                   12                                                                                          DECLARATION OF MICHAEL P.
                                                                      Plaintiff,                               O'ULLIVAN ESQ IN OPPOSITION
                   13                                                                                          TO DEFENDANT'S MOTION TO
                              vs.                                                                              COMPEL RESPONSES TO SPECIAL
                   14                                                                                          INTERROGATORIES AND
                                                                                                               REQUEST FOR SANCTIONS
                   15         SPEEDY CASH, et al.,
                                                                                                               DATE: May 25, 2021
                   16                                                                                          TIME: 8:30 AM
                                                                      Defendants                               DEPT "31"
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                                                               DECLARATION OF MICHAEL P. O'ULLIVAN
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                            I, MICHAEL P.             O'ULLIVAN, Esq., declare as follows:

                  22                    1. I am an attorney at law duly licensed to practice before all the Courts in the State                                            of
                  23        California and an Associate of the law firm of William W. Green and Associates, the attorneys of
                  24        record for Plaintiff, Sharon Holloway. As such, I have personal knowledge of the file and
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                            pleadings in this matter and facts stated herein. If called upon as a witness, I could and would
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                            competently testify to the following:
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                                       2. This matter arises out of a slip and fall incident that occurred on
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                                 OPPOSITION TO MOTIONS TO COMPELI RESPONSES TO WRITTEN DISCOVERY