Party Discovery: RIGOLI -V- C.R. ENGLAND, INC., ET AL Print

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         1
                                                                                        FILED
             Jeffrey ARager Esq    SBN 185216                                 SUPERIOR COURT OF CALiFORNtA
             James Y Yoon Esq SBN 289906                                        CSAN ERARDINO D STR C
         2   THE RAGER LAW FIRM
             970 West 190 Street Suite 340                                            APR 10 2018
         3   Torrance California 90502
             Telephone 310 527 6994
         4   Facsimile 310 527 6800
                                                                                        i
                                                                                  DANIEL     IERL EtN DEPUTY
             Email jeffa ragerlawoffices com
         5          james c ragerlawoffices com

         6   Melanie Savarese Esq SBN 216950
             Savarese Law Firm
         7   37 W Sierra Madre Blvd
             Sierra Madre CA 91024
         8   Phone 626 355 3264
             Facsimile 626 355 3491
         9   Email melanie a savareselawfirm com


        10   Attorneys for Plaintiff BRIANNE RIGOLI

        11                        SUPERIOR COURT OF THE STATE OF CALIFORNIA

        12                               FOR THE COUNTY OF SAN BERNARDINO

        13


        14   BRIANNE RIGOLI                                       CASE No     CIVDS1502545

        15                                                         Assigned To    Hon      Janet M Frangie Dept
                                            Plaintiff             S29
        16
                    vs
                                                                  SUPPLEMENTAL NOTICE OF INTENT TO
        17                                                        USE VIDEOTAPED TESTIMONY OF
                                                                  CHRISTIAN THURGOOD PURSUANT TO
        18   C R ENGLAND INC         a   Corporation              CCP     2025 340 m

        19                                                        Dat     April 10 2018
                                                                  T   e   8 30
        20                                  Defendant             Dep       29

        21


        22

        23   TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD

        24
                    PLEASE TAKE NOTICE THAT Plaintiff BRIANNE RIGOLI hereby intends introduce the
        25
             following additional portions of videotaped testimony of Christian R Thurgood at trial
        26


        27

        28   58 23 59 4




             SUPPLEMENTAL NOTICE OF INTENT TO USE VIDEOTAPED TESTIMONY OF CHRISTIAN
                                    THURGOOD PURSUANT TO CCP               2025 340    m
Y




     1       60 6 21

     2       64 4 66 11

     3
             The specific testimony is as follows
     4


     5       58 23 59 4


     6       MS   SAVARESE             Okay    Let   s   go ahead and         we   ll   mark   as   Exhibit 1       it s been Bates stamped

     7       CRE123483 and 84 We ll mark that as 1

     8       Exhibit 1 was marked for identification

     9       Q Take a minute to review those two pages and let me know when you re done 11 25 57

    10       A Okay I m done
    11


    12       60 6 21

    13
         Q Okay And was the last time that you had been to Colton in 2014 was it in July
    14       A I don t remember But I know that that was the only time that I talked with Ms Rigoli
    15       Q Do you know how many times you went to Colton in 2014
    16   A I don t


    17   Q How do you know that it was in July of 2014 that you spoke with Ms Rigoli
    18
         A I know for a couple of reasons The main reason is I sent an e mail to Jesse Hayes the attorney for
    19
         C R England at the time He had just requested documentation about my visit with Ms Rigoli and all
    20   I      I just
                          I forwarded that over and said These are the notes that I took when I met with her in July
    21   Paraphrasing
    22

    23
         64 4 66 11
    24

    25
         Q Okay How is it that you know when you called to follow up with Ms Rigoli
         A Because this         was
                                       basically         either   it   was
                                                                             we were going to keep the investigation on these notes
    26

         open or we were going to close out the case ifthere were no further issues And so at that time is when
    27
         I   would     have            her   and

    28
                              called
                                                     called her talked to her found out that everything was okay and so



         SUPPLEMENTAL NOTICE OF INTENT TO USE VIDEOTAPED TESTIMONY OF CHRISTIAN
                        THURGOOD                                  PURSUANT TO CCP                   2025 340    m