Document for Louis Montano, Jr., et al. vs Ngochao Nguyen, et al.

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                                1 CHRISTOPHER A. CALLIHAN (SBN 203010)
   CITY ATTORNEY
 2
   CITY OF SALINAS
 3 OFFICE OF THE CITY ATTORNEY
   200 Lincoln Avenue
 4 Salinas, CA 93901
   Telephone: (831) 758-7256
 5 Facsimile: (831) 758-7257

 6 William R. Price (SBN 171531)
   D. Scott Dodd (SBN 170500)
 7 LAW OFFICES OF WILLIAM R. PRICE
   12636 High Bluff Dr., Suite 400
 8 San Diego, CA 92130
   Telephone: (858) 888-0588
 9 Emails: wprice@williamrprice.com, sdodd@williamrprice.com

10 Attorneys for Defendant and Cross-Complainant
   CITY OF SALINAS
11
                     SUPERIOR COURT OF THE STATE OF CALIFORNIA
12
                                    COUNTY OF MONTEREY
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14
   LOUIS MONTANO, JR.; LOUIE MONTANO Case No. 21CV003635
15 III; and MICHAEL MONTANO,
                                            (Consolidated with Case Nos. 22CV002531;
16               Plaintiffs,                22CV003206; 22CV003261; 22CF003443 and
                                            22CV003598)
17         vs.
                                            (*Exempt from filing fees pursuant to Gov. Code
18 CITY   OF  SALINAS,   GINO’S RESTAURANT, section 6103)
   INC.; GINO’S FINE ITALIAN FOOD, INC.;
19 BLFA PROPERTIES LLC; NTN                 DECLARATION OF D. SCOTT DODD IN
   PROPERTIES LLC; NGOCHAO THI              SUPPORT OF CITY OF SALINAS’
20 NGUYEN;     RALPH   BOZZO;  ROSAURA      MOTION FOR SUMMARY JUDGMENT
   ARCOS PANIAGUA; AUSTIN ALARCON;
21 and DOES 1-35,

22               Defendants.                   Date: August 4, 2023
                                               Time: 8:30 a.m.
23                                             Dept: 14

24 AND RELATED CROSS-ACTIONS.                  Complaint Filed: November 16, 2021

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      DECLARATION OF D. SCOTT DODD IN SUPPORT OF CITY OF SALINAS’ MOTION FOR SUMMARY
                                         JUDGMENT
 1         I, D. Scott Dodd, declare as follows:

 2         1.      I am an attorney at law duly licensed to practice before all of the courts in the State

 3 of California. I am an attorney of record for Defendant City of Salinas in this action. I have

 4 personal knowledge of the facts set forth in this Declaration and, if called as a witness, could and

 5 would testify competently to such facts under oath.

 6         2.      Submitted herewith as Exhibit 36 are true and accurate copies of referenced

 7 excerpts of the Deposition of Austin Alarcon, taken on March 10, 2023.

 8         3.      Submitted herewith as Exhibit 37 are true and accurate copies of referenced

 9 excerpts of the Deposition of Sergeant James Godwin, taken on July 13, 2023.

10         4.      Submitted herewith as Exhibit 38 are true and accurate copies of referenced excerpts

11 of the Deposition of Officer Ryan Keating, taken on July 14, 2023.

12         5.      Submitted herewith as Exhibit 39 are true and accurate copies of referenced

13 excerpts of the Deposition of Officer Seth Morten, taken on June 29, 2023.

14         I declare under penalty of perjury under the laws of the State of California that the

15 foregoing is true and correct.

16         Executed on this 28th day of July, 2023, at San Diego, California.

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                                                                           D. Scott Dodd
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       DECLARATION OF D. SCOTT DODD IN SUPPORT OF CITY OF SALINAS’ MOTION FOR SUMMARY
                                          JUDGMENT