On May 31, 2019 a
Objection Filed - TO EVIDENCE OFFERED BY PRISCILLA HUNT AND BESSEMER TRUST COMPANY AS CO TRUSTEES OF THE DONALD G HUNT LIVING TRUST AND HUNT ENTERPRISES INC IN SUPPT OF THEIR RESPECTIVE MSJ
was filed
involving a dispute between
Juarez Alvarez, Yolanda,
and
Bessemer Trust Company, N.A.,
City Of Fontana,
Does 1 Through 100,
Does 5 Through 100, Inclusive,
Hunt Enterprises, Inc.,
Hunt, Priscilla,
Hunt Priscilla Living Trust,
for Complaint for Damages Unlimited
in the District Court of San Bernardino County.
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Lawrence Levy,Esq. suz-“r-wrrw ,
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THE LAWYERS GROUP, INC. C;
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505 SuiteE
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Attorneys for Plaintiff,
Yolanda Juarez Alvarez
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO
YOLANDA JUAREZ ALVAREZ, an Case No. CIVDSI916334
individual,
Assigned for all purposes to:
Plaintiff, Hon. Thomas S. Garza
_
Dept. S-27
V.
OBJECTIONS TO EVIDENCE OFFERED
HUNT PRISCILLA LIVING TRUST; BY PRISCILLA HUNT AND BESSEMER
CITY OF FONTANA, and DOES 1 TRUST COMPANY AS CO-TRUSTEES OF
1 00, inclusive, pvvvvvvvvvvvvvvvvvvv
THE DONALD G. HUNT LIVING TRUST
AND HUNT ENTERPRISES, INC. IN
Defendants, SUPPORT OF THEIR RESPECTIVE
MOTIONS FOR SUMMARY JUDGMENT
-and-
JUAN HERNANDEZ, an individual, Date: May 17, 2023
Time: 8:30 am.
Dept: S-27
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Nominal Defendant
Action Filed: May 3 1 2019
,
Trial Date: June 13, 2022
OOQONUI-PUJNV-‘OKOOOQQUIAWNHO
Plaintiff, Yolanda Juarez Alvarez, hereby submits her “Obj ections to ‘Evidence’” offered
by Defendants, Priscilla Hunt and Bessemer Trust Company, N.A. as co-Trustees of the Donald
G. Hunt Living Trust and Hunt Enterprises, Inc.:
1
Objections to Evidence Offered by A11 Moving Parties in Support of Their MSJs
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OBJECTIONS TO DECLARATION 0F SUSAN WILLIAMS
OBJECTION NO. 1
Material Objected to: Par. 8, to wit:
“Prior to and at the time of the Subj ect Accident, Hunt Enterprises did not own, possess,
control, manage or maintain the areas to the lefi and right sides of the entrance to the
KOOOQONUI-PUJNH
in fiont of the
Oakcrest Apartments on Cherry Avenue in Fontana which are located
the curb of
block wall on both sides of said entrance or in the public parkway between
exhibits A-B
Cherry Avenue and the edge of the public sidewalk (as depicted in the
Google Maps photographs). This includes but is not limited to that Hunt Enterprises did
not own, possess, control, manage or maintain the various trees and other
vegetation
H
sides of said
y—A
depicted in said photographs located in front of the block wall on both
entrance or in the publiZ: parkway betWeen the curb and Cherry Avenue
u—t
and edge of the
r—I
public sidewalk.”
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>— Grounds for Objection:
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Lack of Personal Knowledge: Evidence Code sec. 702
Inadmissible as a conclusion of law, lacking in evidentiary facts
H'r—s
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Authorities and Argument:
OOQONUI-hUJNfi-‘OKOOONQUIAUJNfiO
Ms. Williams, in her Declaration, stated that “Prior to and at the time of the Subj ect
N
N Accident, DGHLT and Hunt Enterprises did not own, possess, control, manage or maintain...”
N the subj ect property. This statement, however, is nothing more than conclusions offered by Ms.
[\J
Williams, totally lacking in evidentiary facts, and incapable of
supporting a motion for summary
I
N judgment.
N The same rules of evidence applicable to oral testimony at tn'al apply to a declaration .
N
N 2
N Objections to Evidence Oflered by A11 Moving Parties in Support of Their MSJs
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" E ' V SBN 55845 'r Lawrence Levy,Esq. suz-“r-wrrw , = » " THE LAWYERS GROUP, INC. C; ” ‘ " ‘ I " ' > ‘ I , " x; 505 SuiteE East First Street, Tustin, California 92780 . a U. a “”3 37m; {,5 ~32- 2w“) Tel: 714,672.0899 F ' 714,672.0677 : fig \OOOQQUIAUJNv—I Attorneys for Plaintiff, Yolanda Juarez Alvarez §?waW“' fl’ ,_ LW’” ‘J ‘Ipuiy SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO YOLANDA JUAREZ ALVAREZ, an Case No. CIVDSI916334 individual, Assigned for all purposes to: Plaintiff, Hon. Thomas S. Garza _ Dept. S-27 V. OBJECTIONS TO EVIDENCE OFFERED HUNT PRISCILLA LIVING TRUST; BY PRISCILLA HUNT AND BESSEMER CITY OF FONTANA, and DOES 1 TRUST COMPANY AS CO-TRUSTEES OF 1 00, inclusive, pvvvvvvvvvvvvvvvvvvv THE DONALD G. HUNT LIVING TRUST AND HUNT ENTERPRISES, INC. IN Defendants, SUPPORT OF THEIR RESPECTIVE MOTIONS FOR SUMMARY JUDGMENT -and- JUAN HERNANDEZ, an individual, Date: May 17, 2023 Time: 8:30 am. Dept: S-27 NNNNNNNNNHHHHHHj—ty—IHp—t Nominal Defendant Action Filed: May 3 1 2019 , Trial Date: June 13, 2022 OOQONUI-PUJNV-‘OKOOOQQUIAWNHO Plaintiff, Yolanda Juarez Alvarez, hereby submits her “Obj ections to ‘Evidence’” offered by Defendants, Priscilla Hunt and Bessemer Trust Company, N.A. as co-Trustees of the Donald G. Hunt Living Trust and Hunt Enterprises, Inc.: 1 Objections to Evidence Offered by A11 Moving Parties in Support of Their MSJs \r V OBJECTIONS TO DECLARATION 0F SUSAN WILLIAMS OBJECTION NO. 1 Material Objected to: Par. 8, to wit: “Prior to and at the time of the Subj ect Accident, Hunt Enterprises did not own, possess, control, manage or maintain the areas to the lefi and right sides of the entrance to the KOOOQONUI-PUJNH in fiont of the Oakcrest Apartments on Cherry Avenue in Fontana which are located the curb of block wall on both sides of said entrance or in the public parkway between exhibits A-B Cherry Avenue and the edge of the public sidewalk (as depicted in the Google Maps photographs). This includes but is not limited to that Hunt Enterprises did not own, possess, control, manage or maintain the various trees and other vegetation H sides of said y—A depicted in said photographs located in front of the block wall on both entrance or in the publiZ: parkway betWeen the curb and Cherry Avenue u—t and edge of the r—I public sidewalk.” p—t >— Grounds for Objection: r—I Lack of Personal Knowledge: Evidence Code sec. 702 Inadmissible as a conclusion of law, lacking in evidentiary facts H'r—s u—t Authorities and Argument: OOQONUI-hUJNfi-‘OKOOONQUIAUJNfiO Ms. Williams, in her Declaration, stated that “Prior to and at the time of the Subj ect N N Accident, DGHLT and Hunt Enterprises did not own, possess, control, manage or maintain...” N the subj ect property. This statement, however, is nothing more than conclusions offered by Ms. [\J Williams, totally lacking in evidentiary facts, and incapable of supporting a motion for summary I N judgment. N The same rules of evidence applicable to oral testimony at tn'al apply to a declaration . N N 2 N Objections to Evidence Oflered by A11 Moving Parties in Support of Their MSJs