Document for CAL-WEST RAIN, INC., A CALIFORNIA CORPORATION VS WESTLAND FARMS LLC, A CALIFORNIA LIMITED LIABILITY ET AL

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                                1   Peter W. Beckman
     Attorney at Law
 2   1400 Chester Ave., Suite K
     Bakersfield, CA 93301
 3   Tel: (661) 327-7261
     Email: beckmanlaw@att.net
 4   SBN 85105
 5
 6   Attorney for: Defendants WESTLAND FARMS, LLC., and SITHOL YIN
 7
 8
                SUPERIOR COURT OF CALIFORNIA, COUNTY OF KERN
 9
               METROPOLITAN DIVISION - UNLIMITED JURISDICTION
10
                                    --oOo–
11
     CAL-WEST RAIN, INC.,               )     NO. BCV-22-103054
12   a California Corporation,          )
                                        )     DECLARATION OF PETER
13                  Plaintiff,          )     W. BECKMAN
     vs.                                )
14                                      )
     WESTLAND FARMS LLC; a California   )
15   Limited Liability Company; SITHOL )
     YIN; and DOES 1 THROUGH 10,        )
16   inclusive                          )
                                        )
17                  Defendants.         )
     ___________________________________)
18        I, Peter W. Beckman, declare:
19        1. I am the attorney for defendants Westland Farms LLC and
20   Sithol Yin in this matter.
21        2. On Monday, August 7, 2023, I served on Wanger Jones Helsely
22   PC, 265 E. River Park Circle, Suite 310, Fresno, CA 93720 by
23   overnight delivery the following proposed responses to requests for
24   admissions that I believe are in substantial compliance with Section
25   2033.220 of the California Code of Civil Procedure, and which contain
26   no objections:
27        A. [PROPOSED] RESPONSE OF SITHOL YIN TO PLAINTIFF’S REQUESTS FOR
28   ADMISSIONS, SET ONE
 1        B.[PROPOSED] RESPONSE OF WESTLANDS FARMS LLC TO PLAINTIFF’S
 2   REQUEST FOR ADMISSIONS, SET ONE
 3        3. In addition, I served the following responses to Plaintiffs
 4   Form Interrogatories and Requests for Production of Documents which
 5   contain no objections:
 6        C. RESPONSE OF DEFENDANT WESTLAND FARMS LLC TO PLAINTIFF’S
 7   REQUEST FOR PRODUCTION OF DOCUMENTS
 8        D. RESPONSE OF DEFENDANT SITHOL YIN TO PLAINTIFF’S REQUEST FOR
 9   PRODUCTION OF DOCUMENTS
10        E.   RESPONSE   OF   DEFENDANT    SITHOL     YIN   TO   PLAINTIFF’S   FORM
11   INTERROGATORIES, SET ONE
12        F. RESPONSE OF DEFENDANT WESTLAND FARMS LLC TO PLAINTIFF’S FORM
13   INTERROGATORIES, SET ONE
14        4. I would request that the pending Motion to have Admissions
15   Deemed Admitted be denied in accordance with the provisions of Code
16   of Civil Procedure Section 2033.280(c).
17        5. I stand prepared to pay whatever amount of sanctions the
18   Court deems appropriate.
19        5. A copy of the Proof of Service with respect to the discovery
20   responses is attached hereto as Exhibit A.
21        I declare the foregoing to be true under penalty of perjury
22   under the laws of the State of California. Executed at Bakersfield,
23   Kern County, California, on August 7, 2023.
24
25
26                                               PETER W. BECKMAN
27
28

                                           -2-
Exhibit “A”
 1   Peter W. Beckman
     Attorney at Law
 2   1400 Chester Ave., Suite K
     Bakersfield, CA 93301
 3   Tel: (661) 327-7261
     Email: beckmanlaw@att.net
 4   SBN 85105
 5
 6   Attorney for: Defendants WESTLAND FARMS, LLC., and SITHOL YIN
 7
 8
                        SUPERIOR COURT OF CALIFORNIA, COUNTY OF KERN
 9
                      METROPOLITAN DIVISION - UNLIMITED JURISDICTION
10
                                             --oOo–
11
     CAL-WEST RAIN, INC.,               )             NO. BCV-22-103054
12   a California Corporation,          )
                                        )             PROOF OF SERVICE BY
13                  Plaintiff,          )             OVERNIGHT DELIVERY
     vs.                                )
14                                      )
     WESTLAND FARMS LLC; a California   )
15   Limited Liability Company; SITHOL )
     YIN; and DOES 1 THROUGH 10,        )
16   inclusive                          )
                                        )
17                  Defendants.         )
     ___________________________________)
18
19           I, the undersigned, declare that at the time of service of
20   papers herein referred to, I was at least 18 years of age and that
21   my business address is 1400 Chester Ave., Suite K, Bakersfield, CA
22   93301. On August 7, 2023, the following documents by overnight
23   delivery:
24           1. [PROPOSED] RESPONSE OF SITHOL YIN TO PLAINTIFF’S REQUESTS FOR
25   ADMISSIONS, SET ONE
26           2.[PROPOSED] RESPONSE OF WESTLANDS FARMS LLC TO PLAINTIFF’S
27   REQUEST FOR ADMISSIONS, SET ONE
28
     Cal-Rain, Inc. v. Westland Farms, LLC
     Proof of Service
 1           3. RESPONSE OF DEFENDANT WESTLAND FARMS LLC TO PLAINTIFF’S
 2   REQUEST FOR PRODUCTION OF DOCUMENTS
 3           4. RESPONSE OF DEFENDANT SITHOL YIN TO PLAINTIFF’S REQUEST FOR
 4   PRODUCTION OF DOCUMENTS
 5           5.     RESPONSE         OF      DEFENDANT    SITHOL     YIN   TO   PLAINTIFF’S   FORM
 6   INTERROGATORIES, SET ONE
 7           6. RESPONSE OF DEFENDANT WESTLAND FARMS LLC TO PLALINTIFF’S FORM
 8   INTERROGATORIES, SET ONE
 9           I enclosed the documents in an envelope or package provided by
10   an overnight delivery carrier and addressed to the persons at the
11   addresses in item 5. I placed the envelope or package for collection
12   and overnight delivery at an office or a regularly utilized drop box
13   of the overnight delivery carrier addressed as follows:
14           Wanger Jones Helsely PC
             265 E. River Park Circle, Suite 310
15           Fresno, CA 93720
16           Attn: Amanda G. Hebesha, Esq.
17           I declare the foregoing to be true under penalty of perjury
18   under the laws of the State of California. Executed at Bakersfield,
19   Kern County, California, on August 7, 2023.
20
21
22
23                                                             PETER W. BECKMAN
24
25
26
27
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     Cal-Rain, Inc. v. Westland Farms, LLC
     Proof of Service
                                                         -2-
                  P R O O F   O F    S E R V I C E
                               BY MAIL
                         AND ELECTRONICALLY

                STATE OF CALIFORNIA, COUNTY OF KERN

     I, the undersigned, declare that at the time of service of

papers herein referred to, I was at least 18 years of age and

that my business address is 1400 Chester Ave., Suite K,

Bakersfield, CA 93301. On August 7, 2023, I served the foregoing

Declaration of Peter W. Beckman by placing a true and correct

copy thereof in a sealed envelope with sufficient postage paid

addressed as follows:

Amanda G. Hebesha, Esq.
Wanger Jones Helsley PC
265 E. River Park Circle, Suite 310
Fresno, CA 93720

     I personally deposited said envelope with the United States

Postal Service at Bakersfield, Kern County, California.   In addition,

I transmitted an electronic copy in of said pleading in pdf format

via email to Amanda G. Hebesha, Esq., e-mail address,

“ahebesha@wjhattorney.com”.

     I declare the foregoing to be true under penalty of perjury

under the laws of the State of California. Executed at

Bakersfield, Kern County, California, on August 7, 2023.




                                __________________________________

                                PETER W. BECKMAN