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1 Paul E. Gaspari, State Bar No. 76496
weintraub tobin chediak coleman grodin
2 LAW CORPORATION
475 Sansome Street, Suite 510
3
San Francisco, California 94111
4 Telephone: 415.433.1400
Facsimile: 415.433.3883
5 Email: pgaspari@weintraub.com
6 Ryan E. Abernethy, State Bar No. 267538
7 weintraub tobin chediak coleman grodin
LAW CORPORATION
8 400 Capitol Mall, 11th Floor
Sacramento, California 95814
9 Telephone: 916.558.6000
Facsimile: 916.446.1611
10 Email: rabernethy@weintraub.com
11
weintraub tobin chediak coleman grodin
Attorneys for Defendant,
12 SONOMA ACADEMY
13
14 SUPERIOR COURT OF THE STATE OF CALIFORNIA
15 IN AND FOR THE COUNTY OF SONOMA
16 DAVID SUCHARD, JODY SUCHARD, and Case No.: SCV-270984
law corporation
JANE DOE, individually, and on behalf of all
17 others similarly situated; DECLARATION OF RYAN ABERNETHY
IN SUPPORT OF SONOMA ACADEMY’S
18
Plaintiffs, MOTION FOR PROTECTIVE ORDER
19
vs. Date: July 5, 2023
20 Time: 3:00 p.m.
SONOMA ACADEMY, a California non- Dept: 19
21 profit; and DOES 1 through 500, Judge: Honorable Oscar A. Pardo
22
Defendants. Complaint Filed: June 10, 2022
23 FAC Filed: March 3, 2023
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{3926363.DOCX:}
DEC OF RYAN ABERNETHY IN SUPPORT OF MOTION FOR PROTECTIVE ORDER
1 I, Ryan E. Abernethy, declare as follows:
2 1. I am licensed to practice before all courts of the state of California and am an attorney
3 with Weintraub Tobin Chediak Coleman Grodin Law Corporation, attorneys for Defendant Sonoma
4 Academy (“Defendant” or “Sonoma Academy”).
5 2. I have personal knowledge of the facts set forth in this declaration, except as to the
6 matters stated upon information, and I could and would competently so testify under oath.
7 3. I make this declaration in support of Defendant’s motion for protective order (the
8 “Motion”).
9 4. On June 27, 2023, I met and conferred telephonically with Plaintiffs’ Counsel, Natasha
10 Serino of Schack Law Group, regarding the issues raised in this Motion.
11 5. The Parties were unable to agree on a resolution of the underlying issues raised in the
weintraub tobin chediak coleman grodin
12 Motion.
13 I declare under penalty of perjury under the laws of the State of California that the foregoing
14 is true and correct. Executed on this 28th day of June, 2023 at Sacramento, California
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law corporation
Ryan E. Abernethy
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DEC OF RYAN ABERNETHY IN SUPPORT OF MOTION FOR PROTECTIVE ORDER
1 Re: David Suchard, et al v. Sonoma Academy
Sonoma County Superior Court Case No. SCV-270984
2
PROOF OF SERVICE
3
I, the undersigned, declare:
4
I am a citizen of the United States, employed in the City and County of Sacramento,
5 California. My business address is 400 Capitol Mall, 11th Floor, Sacramento, California 95814 and
my email address is sheller@weintraub.com. I am over the age of 18 years and not a party to the
6 within action.
7 On June 28, 2023 I caused to be served the attached, and all exhibits thereto:
8 DECLARATION OF RYAN ABERNETHY IN SUPPORT OF SONOMA ACADEMY’S
MOTION FOR PROTECTIVE ORDER
9
10 [ ] (BY U.S. MAIL [CCP § 1013]) I placed such sealed envelope, addressed as follows, in the
designated area for outgoing mail in accordance with this office’s practice, whereby the mail
11 is collected, sealed, postage thereon fully prepaid for first-class mail and deposited in a United
weintraub tobin chediak coleman grodin
States mailbox that same day.
12
[ ] (BY PERSONAL SERVICE) I caused each such envelope to be delivered by hand to the
13 addressees at the addresses listed below.
14 [ ] (VIA FACSIMILE) I caused each such document to be sent by facsimile machine number
(916) 446-2640 to the following persons or their representative at the addresses and the
15 facsimile numbers listed below.
16 [X] (VIA EMAIL [CRC § 2.251/CCP § 1010.6]) I caused each such document to be sent by
law corporation
electronic mail to the addressees at the email addresses listed below.
17
[ ] (VIA FEDERAL EXPRESS) I caused each such envelope to be delivered via Federal Express
18 overnight service to the addressees at the addresses listed below.
19 Attorneys for Plaintiffs Attorneys for Plaintiffs
Jack W. Weaver Alexander M. Schack
20 Rachael M. Mache Natasha N. Serino
WELTY, WEAVER & CURRIE Shannon F. Nocon
21 3554 Round Barn Blvd., Suite 300 SCHACK LAW GROUP
Santa Rosa, Ca 95403 16870 West Bernardo Drive, Suite 400
22 Telephone: (707) 433-4842 San Diego, CA 92127
Facsimile: (707) 473-9778 Telephone: (858) 485-6535
23 Email: jack@weltyweaver.com Facsimile: (858) 485-0608
rachael@weltyweaver.com Email: alexschack@schacklawgroup.com
24 Paralegal - Shannon Monaco natashascrino@schacklawgroup.com
shannon@weltyweaver.com shannonnocon@schacklawgroup.com
25
26 I declare under the penalty of perjury under the laws of the state of California that the
foregoing is true and correct. Executed at Sacramento, California, on June 28 2023.
27
__________________________________________
28 Serena Heller
{3926363.DOCX:} -3-
DEC OF RYAN ABERNETHY IN SUPPORT OF MOTION FOR PROTECTIVE ORDER
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1 Paul E. Gaspari, State Bar No. 76496 weintraub tobin chediak coleman grodin 2 LAW CORPORATION 475 Sansome Street, Suite 510 3 San Francisco, California 94111 4 Telephone: 415.433.1400 Facsimile: 415.433.3883 5 Email: pgaspari@weintraub.com 6 Ryan E. Abernethy, State Bar No. 267538 7 weintraub tobin chediak coleman grodin LAW CORPORATION 8 400 Capitol Mall, 11th Floor Sacramento, California 95814 9 Telephone: 916.558.6000 Facsimile: 916.446.1611 10 Email: rabernethy@weintraub.com 11 weintraub tobin chediak coleman grodin Attorneys for Defendant, 12 SONOMA ACADEMY 13 14 SUPERIOR COURT OF THE STATE OF CALIFORNIA 15 IN AND FOR THE COUNTY OF SONOMA 16 DAVID SUCHARD, JODY SUCHARD, and Case No.: SCV-270984 law corporation JANE DOE, individually, and on behalf of all 17 others similarly situated; DECLARATION OF RYAN ABERNETHY IN SUPPORT OF SONOMA ACADEMY’S 18 Plaintiffs, MOTION FOR PROTECTIVE ORDER 19 vs. Date: July 5, 2023 20 Time: 3:00 p.m. SONOMA ACADEMY, a California non- Dept: 19 21 profit; and DOES 1 through 500, Judge: Honorable Oscar A. Pardo 22 Defendants. Complaint Filed: June 10, 2022 23 FAC Filed: March 3, 2023 24 25 26 27 28 {3926363.DOCX:} DEC OF RYAN ABERNETHY IN SUPPORT OF MOTION FOR PROTECTIVE ORDER 1 I, Ryan E. Abernethy, declare as follows: 2 1. I am licensed to practice before all courts of the state of California and am an attorney 3 with Weintraub Tobin Chediak Coleman Grodin Law Corporation, attorneys for Defendant Sonoma 4 Academy (“Defendant” or “Sonoma Academy”). 5 2. I have personal knowledge of the facts set forth in this declaration, except as to the 6 matters stated upon information, and I could and would competently so testify under oath. 7 3. I make this declaration in support of Defendant’s motion for protective order (the 8 “Motion”). 9 4. On June 27, 2023, I met and conferred telephonically with Plaintiffs’ Counsel, Natasha 10 Serino of Schack Law Group, regarding the issues raised in this Motion. 11 5. The Parties were unable to agree on a resolution of the underlying issues raised in the weintraub tobin chediak coleman grodin 12 Motion. 13 I declare under penalty of perjury under the laws of the State of California that the foregoing 14 is true and correct. Executed on this 28th day of June, 2023 at Sacramento, California 15 16 law corporation Ryan E. Abernethy 17 18 19 20 21 22 23 24 25 26 27 28 {3926363.DOCX:} -2- DEC OF RYAN ABERNETHY IN SUPPORT OF MOTION FOR PROTECTIVE ORDER 1 Re: David Suchard, et al v. Sonoma Academy Sonoma County Superior Court Case No. SCV-270984 2 PROOF OF SERVICE 3 I, the undersigned, declare: 4 I am a citizen of the United States, employed in the City and County of Sacramento, 5 California. My business address is 400 Capitol Mall, 11th Floor, Sacramento, California 95814 and my email address is sheller@weintraub.com. I am over the age of 18 years and not a party to the 6 within action. 7 On June 28, 2023 I caused to be served the attached, and all exhibits thereto: 8 DECLARATION OF RYAN ABERNETHY IN SUPPORT OF SONOMA ACADEMY’S MOTION FOR PROTECTIVE ORDER 9 10 [ ] (BY U.S. MAIL [CCP § 1013]) I placed such sealed envelope, addressed as follows, in the designated area for outgoing mail in accordance with this office’s practice, whereby the mail 11 is collected, sealed, postage thereon fully prepaid for first-class mail and deposited in a United weintraub tobin chediak coleman grodin States mailbox that same day. 12 [ ] (BY PERSONAL SERVICE) I caused each such envelope to be delivered by hand to the 13 addressees at the addresses listed below. 14 [ ] (VIA FACSIMILE) I caused each such document to be sent by facsimile machine number (916) 446-2640 to the following persons or their representative at the addresses and the 15 facsimile numbers listed below. 16 [X] (VIA EMAIL [CRC § 2.251/CCP § 1010.6]) I caused each such document to be sent by law corporation electronic mail to the addressees at the email addresses listed below. 17 [ ] (VIA FEDERAL EXPRESS) I caused each such envelope to be delivered via Federal Express 18 overnight service to the addressees at the addresses listed below. 19 Attorneys for Plaintiffs Attorneys for Plaintiffs Jack W. Weaver Alexander M. Schack 20 Rachael M. Mache Natasha N. Serino WELTY, WEAVER & CURRIE Shannon F. Nocon 21 3554 Round Barn Blvd., Suite 300 SCHACK LAW GROUP Santa Rosa, Ca 95403 16870 West Bernardo Drive, Suite 400 22 Telephone: (707) 433-4842 San Diego, CA 92127 Facsimile: (707) 473-9778 Telephone: (858) 485-6535 23 Email: jack@weltyweaver.com Facsimile: (858) 485-0608 rachael@weltyweaver.com Email: alexschack@schacklawgroup.com 24 Paralegal - Shannon Monaco natashascrino@schacklawgroup.com shannon@weltyweaver.com shannonnocon@schacklawgroup.com 25 26 I declare under the penalty of perjury under the laws of the state of California that the foregoing is true and correct. Executed at Sacramento, California, on June 28 2023. 27 __________________________________________ 28 Serena Heller {3926363.DOCX:} -3- DEC OF RYAN ABERNETHY IN SUPPORT OF MOTION FOR PROTECTIVE ORDER