Preview
ELECTRONICALLY FILED
Superior Court of California
County of Santa Barbara
Darrel E. Parker, Executive Officer
Pedro “Peter” de la Cerda (SBN 249085) 12/22/2022 11:57 AM
EDWARDS& DE LA CERDA, PLLC By: Narzralli Baksh , Deputy
3500 Maple Ave., Ste 1100
Dallas, TX 75219
P: 214.550.5239
F; 214.722.2101
peter@ edwardsdelacerda.com
ATTORNEY FOR PLAINTIFF
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF ALAMEDA.
JOHN DOE CLG03277 22CV05053
Case No.
Plaintiff,
10 PLAINTIFF’S NOTICE OF FILING
vs.
REDACTED CERTIFICATES OF MERIT
1 PURSUANT TO SECTION 340.1 OF THE
DOE SCHOOL DISTRICT, a business entity } CODE OF CIVIL PROCEDURE
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of form unknown; and DOES 1- 500,
13 [Filed concurrently with Plaintiff's Complaint]
Defendants
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15 aaa
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The following redacted Certificates of Merit are hereby filed pursuant to Section 340.1 of the
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Code of Civil Procedure. The Certificates are being filed in redacted state to protect the privacy of the
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parties to this litigation. Upon an order of this Court, the unredacted Certificates will be lodged under
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seal with the Clerk of Courts and/or filed or lodged in any manner that this Court sees fit. The
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Certificates are as follows
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1 Mental Health Care Provider’s Certificate of Merit, enclosed herewith as Exhibit A
22 2 Declaration of Pedro “Peter” de la Cerda Filed as a Certificate of Merit against Doe
23 School District by an Attorney for the Plaintiff Pursuant to Section 340.1 of the Code of Civil
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Procedure, enclosed herewith as Exhibit B
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PLAINTIFF’S NOTICE OF FILING REDACTED CERTIFICATES OF MERIT PURSUANT TO SECTION 340.1 OF
THE CODE OF CIVIL PROCEDURE
1 Dated: December 16, 2022 Respectfully submitted,
2 EDWARDS& DE LA CERDA, PLLC
3 By: Ee
Pedro “Peter” de la Cerda (SBN 249085)
4
Edwards & de la Cerda, PLLC
3500 Maple Ave., Ste 1100
Dallas, T 75219
P: 214.550.5239
F: 214.722.2101
peter@ edwardsdelacerda.com
ATTORNEY FOR PLAINTIFF
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PLAINTIFF’S NOTICE OF FILING REDACTED CERTIFICATES OF MERIT PURSUANT TO SECTION 340.1 OF
THE CODE OF CIVIL PROCEDURE
Exhibit A
Pedro “Peter” de la Cerda (SBN 249085)
EDWARDS & DE LA CERDA, PLLC
3500 Maple Ave., Ste 1100
Dallas, TX 75219
P: 214.550.5239
F: 214.722.2101
3 peter@edwardsdelacerda.com
ATTORNEY FOR PLAINTIFF
SUPERIOR COURT OF THE STATE OF CALIFORNIA
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IN AND FOR THE COUNTY OF SANTA BARBARA
JOHN DOE CLG03277,
Case No.:
Plaintiff,
MENTAL HEALTH CARE PROVIDER’S
vs. CERTIFICATE OF MERIT
[C.C.P. 340.1]
DOE SCHOOL DISTRICT, a business entity
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of form unknown; and DOES 1-500,
11 Defendants.
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14 CONDITIONALLY SUBMITTED UNDER SEAL PURSUANT TO CALIFORNIA
15 RULES OF COURT RULE 2.551 AND CODE OF CIVIL PROCEDURE SECTION
340.1 2
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This Certificate of Merit and Declaration in Support thereof is submitted by the undersigned
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pursuant to California Code of Civil Procedure section 340.1(g)(2).
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ee:
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a
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a
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CERTIFICATE OF MERIT (MENTAL HEALTH PRACTITIONER)
ee
ee
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I declare under penalty of perjury under the laws of the State of California that the foregoing
is true and correct. As to the foregoing statements made by me upon information and belief, I
believe them to be true.
Executed this 8th day of December, 2022, at Los Angeles, California.
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CKD
12 Corrina Levine, M.A., LMFT, CA #130706
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CERTIFICATE OF MERIT (MENTAL HEALTH PRACTITIONER)
Exhibit B
Pedro “Peter” de la Cerda (SBN 249085)
EDWARDS & DE LA CERDA, PLLC
3500 Maple Ave., Ste 1100
Dallas, T 75219
P: 214.550.5239
F: 214.722.2101
peter@ edwardsdelacerda.com
ATTORNEY FOR PLAINTIFF
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SANTA BARBARA
JOHN DOE CLG03277,
Case No.
10
Plaintiff,
1 vs. CERTIFICATE OF MERIT FOR PLAINTIFF
JOHN DOE CLG03277 VERSUS DEFENDANT
12 DOE SCHOOL DISTRICT, a business entity
of form unknown; and DOES 1-500, DOE SCHOOL DISTRICT, et al., PURSUANT
13 TO CODE OF CIVIL PROCEDURE SECTION
Defendants. 340.1(g)(1)
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Filed Pursuant to C ode of Civil Procedure
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Section 340.1, as amended by Assembly Bill
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LODGED CONFIDENTIALLY FOR INCAMERA REVIEW ONLY
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PURSUANT TO CALIFORNIA RULES OF COURT 2.551 AND 2.585, AND CODE OF
CIVIL PROCEDURE SECTION 340.1(q)(1) AND 340.1(p)
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This Certificate of Merit and Declaration in Support thereof is submitted by the undersigned
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confidentially for in camera review only, pursuant to California Code of Civil Procedure section
340.1(g)(1).
CERTIFICATE OF MERIT AND DECLARATION OF PEDRO “PETER” DE LA CERDA
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CERTIFICATE OF MERIT (ATTORNEY)
I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct.
10 Executed this 16 day of December, 2022, at Dallas, Texas.
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Pedro “Peter” (le la Cerda
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CERTIFICATE OF MERIT (ATTORNEY)
Preview
ELECTRONICALLY FILED Superior Court of California County of Santa Barbara Darrel E. Parker, Executive Officer Pedro “Peter” de la Cerda (SBN 249085) 12/22/2022 11:57 AM EDWARDS& DE LA CERDA, PLLC By: Narzralli Baksh , Deputy 3500 Maple Ave., Ste 1100 Dallas, TX 75219 P: 214.550.5239 F; 214.722.2101 peter@ edwardsdelacerda.com ATTORNEY FOR PLAINTIFF SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ALAMEDA. JOHN DOE CLG03277 22CV05053 Case No. Plaintiff, 10 PLAINTIFF’S NOTICE OF FILING vs. REDACTED CERTIFICATES OF MERIT 1 PURSUANT TO SECTION 340.1 OF THE DOE SCHOOL DISTRICT, a business entity } CODE OF CIVIL PROCEDURE 12 of form unknown; and DOES 1- 500, 13 [Filed concurrently with Plaintiff's Complaint] Defendants 14 15 aaa 16 The following redacted Certificates of Merit are hereby filed pursuant to Section 340.1 of the 17 Code of Civil Procedure. The Certificates are being filed in redacted state to protect the privacy of the 18 parties to this litigation. Upon an order of this Court, the unredacted Certificates will be lodged under 19 seal with the Clerk of Courts and/or filed or lodged in any manner that this Court sees fit. The 20 Certificates are as follows 21 1 Mental Health Care Provider’s Certificate of Merit, enclosed herewith as Exhibit A 22 2 Declaration of Pedro “Peter” de la Cerda Filed as a Certificate of Merit against Doe 23 School District by an Attorney for the Plaintiff Pursuant to Section 340.1 of the Code of Civil 24 Procedure, enclosed herewith as Exhibit B 25 26 27 28 1 PLAINTIFF’S NOTICE OF FILING REDACTED CERTIFICATES OF MERIT PURSUANT TO SECTION 340.1 OF THE CODE OF CIVIL PROCEDURE 1 Dated: December 16, 2022 Respectfully submitted, 2 EDWARDS& DE LA CERDA, PLLC 3 By: Ee Pedro “Peter” de la Cerda (SBN 249085) 4 Edwards & de la Cerda, PLLC 3500 Maple Ave., Ste 1100 Dallas, T 75219 P: 214.550.5239 F: 214.722.2101 peter@ edwardsdelacerda.com ATTORNEY FOR PLAINTIFF 10 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 PLAINTIFF’S NOTICE OF FILING REDACTED CERTIFICATES OF MERIT PURSUANT TO SECTION 340.1 OF THE CODE OF CIVIL PROCEDURE Exhibit A Pedro “Peter” de la Cerda (SBN 249085) EDWARDS & DE LA CERDA, PLLC 3500 Maple Ave., Ste 1100 Dallas, TX 75219 P: 214.550.5239 F: 214.722.2101 3 peter@edwardsdelacerda.com ATTORNEY FOR PLAINTIFF SUPERIOR COURT OF THE STATE OF CALIFORNIA 6 IN AND FOR THE COUNTY OF SANTA BARBARA JOHN DOE CLG03277, Case No.: Plaintiff, MENTAL HEALTH CARE PROVIDER’S vs. CERTIFICATE OF MERIT [C.C.P. 340.1] DOE SCHOOL DISTRICT, a business entity 10 of form unknown; and DOES 1-500, 11 Defendants. 12 13 14 CONDITIONALLY SUBMITTED UNDER SEAL PURSUANT TO CALIFORNIA 15 RULES OF COURT RULE 2.551 AND CODE OF CIVIL PROCEDURE SECTION 340.1 2 16 This Certificate of Merit and Declaration in Support thereof is submitted by the undersigned 17 pursuant to California Code of Civil Procedure section 340.1(g)(2). 18 ee: 19 ee 20 ee a 21 a 1 CERTIFICATE OF MERIT (MENTAL HEALTH PRACTITIONER) ee ee ee < 6 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. As to the foregoing statements made by me upon information and belief, I believe them to be true. Executed this 8th day of December, 2022, at Los Angeles, California. 10 11 CKD 12 Corrina Levine, M.A., LMFT, CA #130706 14 15 16 17 18 19 20 21 2 CERTIFICATE OF MERIT (MENTAL HEALTH PRACTITIONER) Exhibit B Pedro “Peter” de la Cerda (SBN 249085) EDWARDS & DE LA CERDA, PLLC 3500 Maple Ave., Ste 1100 Dallas, T 75219 P: 214.550.5239 F: 214.722.2101 peter@ edwardsdelacerda.com ATTORNEY FOR PLAINTIFF SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SANTA BARBARA JOHN DOE CLG03277, Case No. 10 Plaintiff, 1 vs. CERTIFICATE OF MERIT FOR PLAINTIFF JOHN DOE CLG03277 VERSUS DEFENDANT 12 DOE SCHOOL DISTRICT, a business entity of form unknown; and DOES 1-500, DOE SCHOOL DISTRICT, et al., PURSUANT 13 TO CODE OF CIVIL PROCEDURE SECTION Defendants. 340.1(g)(1) 14 Filed Pursuant to C ode of Civil Procedure 15 Section 340.1, as amended by Assembly Bill 16 218 17 --- a LODGED CONFIDENTIALLY FOR INCAMERA REVIEW ONLY 18 PURSUANT TO CALIFORNIA RULES OF COURT 2.551 AND 2.585, AND CODE OF CIVIL PROCEDURE SECTION 340.1(q)(1) AND 340.1(p) 20 This Certificate of Merit and Declaration in Support thereof is submitted by the undersigned 21 confidentially for in camera review only, pursuant to California Code of Civil Procedure section 340.1(g)(1). CERTIFICATE OF MERIT AND DECLARATION OF PEDRO “PETER” DE LA CERDA 25 ee 26 i ee 27 i ee 28 1 CERTIFICATE OF MERIT (ATTORNEY) I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 10 Executed this 16 day of December, 2022, at Dallas, Texas. 1 Ly 12 Pedro “Peter” (le la Cerda 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 CERTIFICATE OF MERIT (ATTORNEY)