Motion-Secondary: BELLA ROSSAL BY AND THROUGH HER GUARDIAN AD LITEM JACQUELINE GARCIA VS CITY OF BURBANK, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 07/14/2020 06:25 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Lopez,Deputy Clerk




                  Lane Quigley, (SBN 62449)                                                                                                (SPACE BELOW FOR FILING STAMP ONLY)
                  LIEBMAN, QUIGLEY & SHEPPARD                                                                         [Exempt from filing fee under Government Code Section 6103]
                  A PROFESSIONAL LAW CORPORATION
                    3255 WILSHIRE BOULEVARD
                          SUITE 1200
                  LOS ANGELES, CALIFORNIA 90010-1404
                             (213) 387-0777
                  Facsimile: (213) 383-6754
                  Attorneys for Defendant
                  BURBANK UNIFIED SCHOOL DISTRICT (A Public Entity)


                                                       SUPERIOR COURT OF THE STATE OF CALIFORNIA
                                                                  FOR THE COUNTY OF LOS ANGELES

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           ll      BELLA ROSSAL, by and through her                                                CASE NO.               20STCV12022
                   guardian ad litem JACQUELIN GARCIA, )
           12                                                                                      [Assigned           for    All     Purposes           to the        Honorable
                                              Plaintiff,                                    )      Thomas D. Long; Dept. “31"]
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                   Vv                                                                       )      DECLARATION OF JOHN W. EVANS UNDER
           14                                                                                      CODE OF CIVILPROCEDURE SECTIONS 430.41
                   CITY OF BURBANK; BURBANK UNIFIED )                                              AND 435.5 IN SUPPORT OF DEMURRER    TO
           is      SCHOOL DISTRICT; and DOES 1 to 100, )                                           PLAINTIFF'S               COMPLAINT                 AND       MOTION           TO
                   Inclusive,                                                                      STRIKE PORTIONS OF PLAINTIFF'S COMPLAINT
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                                                                                                   DATE:                              December 8, 2020
           17                             Defendants.                                              TIME:                              3:30 p.m.
                                                                                                                                      "34"
                                                                                                   DEPT.:
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                                                                                                   ID RESERVATION: 081833620454
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                               |, John W. Evans, declare:
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                                              | am an attorney at law duly licensed to practice law in all the courts of the State of
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                   California and a shareholder in the law firm of Liebman, Quigley & Sheppard, A Professional Law
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                   Corporation, attorneys for defendant BURBANK UNIFIED SCHOOL                                                           DISTRICT (A Public Entity)
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                   (‘BUSD”). This Declaration in made pursuant to Code of Civil Procedure sections 430.41 and 435.5
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                   with respect to the good faith meet and confer efforts made prior to the filing of Defendant BUSD’s
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                   Demurrer and Motion to Strike with respect to the Complaint of Plaintiff BELLA ROSSAL, by and
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                   through her guardian ad litem JACQUELINE GARCIA (‘Plaintiff’).
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                               2          On July 8, 2020, | sent Plaintiffs counsel a meet and confer letter regarding the issues
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                        DECLARATION OF JOHN W. EVANS UNDER CODE OF CIVIL PROCEDURE SECTIONS 430.41 AND 435.5
                                           IN SUPPORT OF DEMURRER AND MOTION TO STRIKE