Party Statement: CATHY JENKINS VS BJ'S RESTAURANTS INC

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 05/17/2019 05:10 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Lopez,Deputy Clerk




                          1 Sevan Gobel, Esq. (State Bar No. 221768)
                              sxg@manningllp.com
                          2 Kelsey Nicolaisen, Esq. (State Bar No. 276209)
                              kln@manningllp.com
                          3 Jeffrey Tsao (State Bar No. 294379)
                              jyt@manningllp.com
                          4 MANNING & KASS
                            ELLROD, RAMIREZ, TRESTER LLP
                          5 801 S. Figueroa St, 15th Floor
                            Los Angeles, California 90017-3012
                          6 Telephone: (213) 624-6900
                            Facsimile: (213) 624-6999
                          7
                            Attorneys for Defendant, BJ’S RESTAURANTS, INC.
                          8

                          9                                SUPERIOR COURT OF THE STATE OF CALIFORNIA
                        10                                   COUNTY OF LOS ANGELES, CENTRAL DISTRICT
                        11

                        12 CATHY JENKINS, an individual,                                                     Case No. BC696790
                                                                                                             [Hon. Georgina Torres Rizk, Dept. 2]
                        13                            Plaintiff,

                        14                 v.                                                                DECLARATION OF JEFFREY TSAO
                        15 BJ’S RESTAURANTS, INC., a corporation;
                           and DOES 1 through 50, Inclusive,
                        16                                                                                   Action Filed: 3/06/2018
                                        Defendants.                                                          Trial: 9/6/19
                        17

                        18                 I, Jeffrey Tsao, declare as follows:
                        19                 1.         I am an attorney duly admitted to practice before this Court. I am an attorney with
                        20 Manning & Kass, Ellrod, Ramirez, Trester LLP, attorneys of record for Defendant, BJ’S

                        21 RESTAURANTS, INC. (“BJ’s”). I have personal knowledge of the facts set forth herein, except

                        22 as to those stated on information and belief and, as to those, I am informed and believe them to be

                        23 true. If called as a witness, I could and would competently testify to the matters stated herein.

                        24                 2.         I make this declaration in support of BJ’s Motion For Summary Judgment.
                        25                 3.         Plaintiff Cathy Jenkins (“Plaintiff”) filed suit against BJ’s on March 6, 2018
                        26 alleging cause of action for premises liability and negligence. Attached as Exhibit 1 to BJ’s

                        27 Compendium of Exhibits in Support of the Motion for Summary Judgment (“Compendium”) is a

                        28 true and correct copy of Plaintiff’s Complaint.


                                                                              MOTION FOR SUMMARY JUDGMENT