Document for Jane Doe vs Mission Rowing et al

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                                1    Michael J. Deniro (State Bar No. 249782)
     PO Box 3602
2    Santa Barbara, CA 93130
     Telephone: (805) 845-8223
3    Email: mjdeniro@cox.net
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5    Lawyer for Defendant Carol Nagy
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             SUPERIOR COURT FOR THE COUNTY OF SANTA BARBARA
8                            COOK DIVISION
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11    Jane Doe,                                           )   CASE NO. 23CV01793
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12                     Plaintiff,                         )   Declaration of Michael J. DeNiro re
                                                          )   Motion to Strike References to “Jane
13                v.                                      )   Doe” in the Complaint
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14    Mission Rowing, Conal Groom,                        )   Judge: Timothy J. Staffel
      Carol Nagy and Does 1-50,                           )   Dept.: SM-3
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                       Defendant.                         )   Action Filed: April 25, 2023
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                                                          )   Hearing: June 28, 2023 0830 PT
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21   I, Michael J. DeNiro, declare:
22      1. I am the lawyer for Defendant Carol Nagy in the above-captioned action.
23      2. I have personal knowledge of the facts stated herein and if called as a witness
24         would so testify.
25      3. Plaintiff’s Attorney of Record, Janean Acevedo Daniels, called me on June
26         13, 2023 to ask for an extension until June 16, 2023 to file an Opposition to
27         my client Defendant Carol Nagy’s Motion to Strike References to “Jane
28         Doe” in the Complaint on behalf of her client Plaintiff Jane Doe.

         Declaration of Michael J. DeNiro re Motion to Strike References to “Jane Doe” in the Complaint

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2       4. I said no problem, then asked if we needed to file a stipulation with the Court
3           because the Opposition was due June 14, 2023.
4       5. Ms. Daniels said she didn’t know, but that she would check with the clerk
5           of the Court to find out.
6       6. I did not hear back from Ms. Daniels.
7       7. Ms. Daniels did not file an Opposition to my client Defendant Carol Nagy’s
8           Motion to Strike References to “Jane Doe” in the Complaint on behalf of
9           her client Plaintiff Jane Doe on June 16, 2023, or at any time.
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11   I declare under penalty of perjury that the foregoing is true and correct.
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13   Dated: June 23, 2023                            ___________________________
14                                                              Michael J. DeNiro
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          Declaration of Michael J. DeNiro re Motion to Strike References to “Jane Doe” in the Complaint

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