On October 08, 2021 a
Motion-Secondary
was filed
involving a dispute between
Baker, Lucy,
Roe, John,
Roe, Jane,
and
Chaffey Joint Union High School District,
Does 1-50, Inclusive,
Riden, David Arthur,
for Complex Civil Unlimited
in the District Court of San Bernardino County.
Preview
AEGIS LAW FIRM, PC
KASHIF HAQUE, State Bar No. 218672
SAMUEL A. WONG,
FAWN F. BEKAM,
State Bar No. 217104
State Bar No. 3073 12
9811 Irvine Center Drive, Suite 100
MN Wm
CPUNTY 0F SAN Be 0m"
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92618
Irvine, California
4EC07mn
Telephone: (949) 379-6250
Facsimile: (949) 379-6251 BY
ANTHONY f§flTWfiL
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\OOONQUI-h
Attorneys for Plaintiff G.S.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
m
n G.S., individually and 0n behalf 0f all others CASE NO.: CIVD82134233
similarly situated,
n Assignedfor all purposes t0:
Plaintiff,
B Hon. Joseph T. Ortiz, Dept. SI 7
vs.
M DECLARATION OF FAWN F. BEKAM IN
CHAFFEY JOINT UNION HIGH SCHOOL SUPPORT OF MOTION FOR LEAVE TO
w AMEND TO SUBSTITUTE CLASS
DISTRICT;DAVID A. RIDEN, an individual;
REPRESENTATIVE
m and DOES through 100.
1
n
Date: January 31, 2023
Defendants.
m Time: 1:30 p.m.
Dept: S17
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DECLARATION OF FAWN F. BEKAM IN SUPPORT OF MOTION FOR LEAVE TO AMEND
I, Fawn F. Bekam, hereby declare as follows:
1. I am an attorney at law licensed t0 practice before all of the courts of the State 0f
California. I am a senior associate at Aegis Law Firm, PC (“Aegis”), counsel for Plaintiff G.S.
(“Plaintiff’ or “G.S.”) in this matter. I am thoroughly familiar with and have personal knowledge of all
of the facts set forth herein.
2. I submit this declaration in support of Plaintiff’ s Motion for Leave t0 Amend to Substitute
Class Representative. If called as a witness, I could and would competently testify thereto.
\OOONON
3. On October 8, 2021, Plaintiff submitted a tort claim to Defendant Chaffey Joint Union
High School District (“the District”). A true and correct copy of the form and attached correspondence
10 submitted to the District on October 2021 attached hereto as Exhibit A.
8, is The copy attached hereto
11 does not include the attomey’s signature, as that was placed on the form and correspondence prior
t0
12 mailing. However, the substance of the form and attached correspondence is identical to that which was
13 mailed t0 the District.
14 4. Following the initial status conference in this matter, the District and G.S. both
15 propounded formal discovery.
16 5. Following receipt of the discovery requests from the District t0 G.S., I made several
17 attempts to gain G.S.’s cooperation in drafting substantive responses. However, without revealing
18 attomey—client privileged communications, G.S. was unable to carry her duties as a named plaintiff. As
19 a young woman unfamiliar with litigation and already emotionally distraught due to the allegations of
20 sexual misconduct alleged in this lawsuit, G.S. informed me that she n0 longer wished to continue as a
21 class representative. Since then, G.S. has stopped responding to
my efforts to contact her.
22 6. My office has been retained by M.L., and M.L. has agreed to substitute as class
23 representative in G.S.’s place. M.L. attended Los Osos High School from 2015 to 2019, and regularly
24 used the restroom and locker room where Defendant David Riden allegedly placed the hidden camera.
25 Based on these facts, M.L. fits the definition of a putative class member as alleged in the operative
26 Complaint.
27 7. A true and correct copy 0f Plaintiff’s proposed First Amended Complaint with changes
28 in redline is attached hereto as Exhibit B.
1
DECLARATION OF FAWN F. BEKAM IN SUPPORT OF MOTION FOR LEAVE TO AMEND
Document Filed Date
December 07, 2022
Case Filing Date
October 08, 2021
Category
Complex Civil Unlimited
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AEGIS LAW FIRM, PC KASHIF HAQUE, State Bar No. 218672 SAMUEL A. WONG, FAWN F. BEKAM, State Bar No. 217104 State Bar No. 3073 12 9811 Irvine Center Drive, Suite 100 MN Wm CPUNTY 0F SAN Be 0m" gzmzwo 92618 Irvine, California 4EC07mn Telephone: (949) 379-6250 Facsimile: (949) 379-6251 BY ANTHONY f§flTWfiL ggptm“ \OOONQUI-h Attorneys for Plaintiff G.S. SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO m n G.S., individually and 0n behalf 0f all others CASE NO.: CIVD82134233 similarly situated, n Assignedfor all purposes t0: Plaintiff, B Hon. Joseph T. Ortiz, Dept. SI 7 vs. M DECLARATION OF FAWN F. BEKAM IN CHAFFEY JOINT UNION HIGH SCHOOL SUPPORT OF MOTION FOR LEAVE TO w AMEND TO SUBSTITUTE CLASS DISTRICT;DAVID A. RIDEN, an individual; REPRESENTATIVE m and DOES through 100. 1 n Date: January 31, 2023 Defendants. m Time: 1:30 p.m. Dept: S17 w m m n n m fi % m x DECLARATION OF FAWN F. BEKAM IN SUPPORT OF MOTION FOR LEAVE TO AMEND I, Fawn F. Bekam, hereby declare as follows: 1. I am an attorney at law licensed t0 practice before all of the courts of the State 0f California. I am a senior associate at Aegis Law Firm, PC (“Aegis”), counsel for Plaintiff G.S. (“Plaintiff’ or “G.S.”) in this matter. I am thoroughly familiar with and have personal knowledge of all of the facts set forth herein. 2. I submit this declaration in support of Plaintiff’ s Motion for Leave t0 Amend to Substitute Class Representative. If called as a witness, I could and would competently testify thereto. \OOONON 3. On October 8, 2021, Plaintiff submitted a tort claim to Defendant Chaffey Joint Union High School District (“the District”). A true and correct copy of the form and attached correspondence 10 submitted to the District on October 2021 attached hereto as Exhibit A. 8, is The copy attached hereto 11 does not include the attomey’s signature, as that was placed on the form and correspondence prior t0 12 mailing. However, the substance of the form and attached correspondence is identical to that which was 13 mailed t0 the District. 14 4. Following the initial status conference in this matter, the District and G.S. both 15 propounded formal discovery. 16 5. Following receipt of the discovery requests from the District t0 G.S., I made several 17 attempts to gain G.S.’s cooperation in drafting substantive responses. However, without revealing 18 attomey—client privileged communications, G.S. was unable to carry her duties as a named plaintiff. As 19 a young woman unfamiliar with litigation and already emotionally distraught due to the allegations of 20 sexual misconduct alleged in this lawsuit, G.S. informed me that she n0 longer wished to continue as a 21 class representative. Since then, G.S. has stopped responding to my efforts to contact her. 22 6. My office has been retained by M.L., and M.L. has agreed to substitute as class 23 representative in G.S.’s place. M.L. attended Los Osos High School from 2015 to 2019, and regularly 24 used the restroom and locker room where Defendant David Riden allegedly placed the hidden camera. 25 Based on these facts, M.L. fits the definition of a putative class member as alleged in the operative 26 Complaint. 27 7. A true and correct copy 0f Plaintiff’s proposed First Amended Complaint with changes 28 in redline is attached hereto as Exhibit B. 1 DECLARATION OF FAWN F. BEKAM IN SUPPORT OF MOTION FOR LEAVE TO AMEND