On September 05, 2017 a
Party Statement
was filed
involving a dispute between
M., N.,
and
Butte County Office Of Education,
California Teaching Fellows Foundation,
Fresno Unified School District,
Perez-Esteban, Andres,
The California State University,
for civil
in the District Court of Fresno County.
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E-FILED
1 CYNTHIA G. LAWRENCE (SBN 148927) 6/20/2019 2:37 PM
TAHMINA YASSINE (SBN 285542)
ANN MARZ (SBN 221313) Superior Court of California
2
SIMS, LAWRENCE & ARRUTI County of Fresno
3 2261 Lava Ridge Court By: L Peterson, Deputy
Roseville, CA 95661
4 Telephone: (916) 797-8881
Facsimile: (916) 253-1544
5
Attorneys for Defendant/Cross-Complainant
6 CALIFORNIA TEACHING FELLOWS FOUNDATION
7
SUPERIOR COURT OF THE STATE OF CALIFORNIA
8
COUNTY OF FRESNO
9
10 N.M., a minor, by and through her Guardian ad Case No. 17CECG03023
Litem, D.M.,
11 SUPPLEMENTAL DECLARATION OF
Plaintiff, CYNTHIA G. LAWRENCE IN SUPPORT
12 OF CALIFORNIA TEACHING FELLOWS
vs.
FOUNDATION’S MOTION FOR
13
FRESNO UNIFIED SCHOOL DISTRICT; SUMMARY JUDGMENT AS TO
14 ANDRES PEREZ-ESTEBAN; BUTTE PLAINTIFF’S COMPLAINT
COUNTY OFFICE OF EDUCATION;
15 CALIFORNIA TEACHING FELLOWS
FOUNDATION; THE CALIFORNIA STATE Date: June 26, 2019
16 UNIVERSITY; and DOES 1 to 25, inclusive, Time: 3:30 p.m.
Dept.: 403
17 Defendants.
18
AND RELATED CROSS-ACTIONS Complaint Filed: September 5, 2017
19 Trial Date: November 4, 2019
20 I, CYNTHIA LAWRENCE, declare as follows:
21 1. I am an attorney duly licensed to practice law in the State of California and am a
22 partner in the law firm Sims, Lawrence & Arruti attorneys of record for Defendant/Cross-
23 Complainant CALIFORNIA TEACHING FELLOWS FOUNDATION (hereinafter “CTFF”). This
24 Declaration is made in support of Defendant CTFF’s Motion for Summary Judgment as to Plaintiff’s
25 Complaint. I have personal knowledge of the matters set forth herein, and if called upon as a witness
26 could competently testify thereto.
27 2. Attached to the Supplemental Index of Evidence as Exhibit Q is a true and correct
28 copy of excerpts of the Deposition of Mike Snell, Person Most Knowledgeable for Defendant CTFF,
-1-
SUPPLEMENTAL DECLARATION OF CYNTHIA G. LAWRENCE IN SUPPORT OF MOTION FOR
SUMMARY JUDGMENT AS TO PLAINTIFF’S COMPLAINT
1 taken on May 2, 2019, including the cover page and the court reporter’s certification.
2 3. Attached to the Supplemental Index of Evidence as Exhibit R is a true and correct
3 copy of excerpts of the Deposition of Plaintiff N.M. taken on April 18, 2019, including the cover
4 page and the court reporter’s certification.
5 I declare under penalty of perjury under the laws of the State of California that the
6 foregoing is true and correct.
7 Executed this 20th day of June 2019, at Roseville, California.
8
9 By
10 CYNTHIA G. LAWRENCE
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SUPPLEMENTAL DECLARATION OF CYNTHIA G. LAWRENCE IN SUPPORT OF MOTION FOR
SUMMARY JUDGMENT AS TO PLAINTIFF’S COMPLAINT
Document Filed Date
June 20, 2019
Case Filing Date
September 05, 2017
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E-FILED 1 CYNTHIA G. LAWRENCE (SBN 148927) 6/20/2019 2:37 PM TAHMINA YASSINE (SBN 285542) ANN MARZ (SBN 221313) Superior Court of California 2 SIMS, LAWRENCE & ARRUTI County of Fresno 3 2261 Lava Ridge Court By: L Peterson, Deputy Roseville, CA 95661 4 Telephone: (916) 797-8881 Facsimile: (916) 253-1544 5 Attorneys for Defendant/Cross-Complainant 6 CALIFORNIA TEACHING FELLOWS FOUNDATION 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 COUNTY OF FRESNO 9 10 N.M., a minor, by and through her Guardian ad Case No. 17CECG03023 Litem, D.M., 11 SUPPLEMENTAL DECLARATION OF Plaintiff, CYNTHIA G. LAWRENCE IN SUPPORT 12 OF CALIFORNIA TEACHING FELLOWS vs. FOUNDATION’S MOTION FOR 13 FRESNO UNIFIED SCHOOL DISTRICT; SUMMARY JUDGMENT AS TO 14 ANDRES PEREZ-ESTEBAN; BUTTE PLAINTIFF’S COMPLAINT COUNTY OFFICE OF EDUCATION; 15 CALIFORNIA TEACHING FELLOWS FOUNDATION; THE CALIFORNIA STATE Date: June 26, 2019 16 UNIVERSITY; and DOES 1 to 25, inclusive, Time: 3:30 p.m. Dept.: 403 17 Defendants. 18 AND RELATED CROSS-ACTIONS Complaint Filed: September 5, 2017 19 Trial Date: November 4, 2019 20 I, CYNTHIA LAWRENCE, declare as follows: 21 1. I am an attorney duly licensed to practice law in the State of California and am a 22 partner in the law firm Sims, Lawrence & Arruti attorneys of record for Defendant/Cross- 23 Complainant CALIFORNIA TEACHING FELLOWS FOUNDATION (hereinafter “CTFF”). This 24 Declaration is made in support of Defendant CTFF’s Motion for Summary Judgment as to Plaintiff’s 25 Complaint. I have personal knowledge of the matters set forth herein, and if called upon as a witness 26 could competently testify thereto. 27 2. Attached to the Supplemental Index of Evidence as Exhibit Q is a true and correct 28 copy of excerpts of the Deposition of Mike Snell, Person Most Knowledgeable for Defendant CTFF, -1- SUPPLEMENTAL DECLARATION OF CYNTHIA G. LAWRENCE IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT AS TO PLAINTIFF’S COMPLAINT 1 taken on May 2, 2019, including the cover page and the court reporter’s certification. 2 3. Attached to the Supplemental Index of Evidence as Exhibit R is a true and correct 3 copy of excerpts of the Deposition of Plaintiff N.M. taken on April 18, 2019, including the cover 4 page and the court reporter’s certification. 5 I declare under penalty of perjury under the laws of the State of California that the 6 foregoing is true and correct. 7 Executed this 20th day of June 2019, at Roseville, California. 8 9 By 10 CYNTHIA G. LAWRENCE 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -2- SUPPLEMENTAL DECLARATION OF CYNTHIA G. LAWRENCE IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT AS TO PLAINTIFF’S COMPLAINT