On November 03, 2021 a
Motion-Secondary
was filed
involving a dispute between
Doe, John Vnr,
and
Brown, Eric Lynn,
Does 1-100,
Victor Valley Union High School District,
for Other PI/PD/WD Unlimited
in the District Court of San Bernardino County.
Preview
\a
Ra mond F. Dolen SBN 130534 F I LE
SUPERIOR COURT 0F CALIFORNIA
D
D LEN TUCKER TIERNEY & ABRAHAM COUNTY 0F SAN BERNARDINO
1710 Plum Lane, Suite A SAN BERNARDINO DISTRICT
Redlands, CA 92374
Ph: 951-683-6014 APR 06 2022
Fax: 951-683-03 14
rdolen@redlands-law.com
Our File No: 12-303b
Bv/L/zifi
\ooouoxmpmm.‘
Attorne s for Defendant,
W5 “\QL (11m DEPUTY
VICTO VALLEY UNION HIGH SCHOOL DISTRICT
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
JOHN VBK DOE, an individual; CASE NO: CIVSB 2200478
Assigned Judge : Wilfred J. Schneider
Plaintiff, Department : S-32
Complaint Filed : January 7, 2022
vs.
[Fee Exempt per Gov. Code §6103]
VICTOR VALLEY UNION HIGH
SCHOOL DISTRICT, a business entity of DECLARATION OF RAYMOND F.
form unknown; ERIC LYNN BROWN, an DOLEN IN SUPPORT OF
individual, and DOES through 100, 1 DEFENDANT’S DEMURRER
Defendants. Concurrently with Defendant’s Demurrer to
[Filed
Complaint of Plaintiff and Request for Judicial
Notice]
NNNNNNNNNv—dp—np—I—‘v—ar—IHHHH
OOQOUIAUJNt—‘OKDOOQONUI-PWNF-‘O
Date: May 24, 2022
Time: 9:00 a.m.
Department: S-32
I, Raymond F. Dolen, declare as follows:
I am an attorney duly licensed to practice before all of the courts in the State of
California and am a principal in the law firm of Dolen, Tucker, Tierney & Abraham,
attorneys of record for defendant Victor Valley Union High School District.
This declaration is submitted in support of the demurrer which I prepared t0 the
plaintiff s complaint.
Pursuant t0 Code ofCivz'l Procedure §430.41(a) and pursuant to Code osz'vz'l
Procedure §435.5, I met and conferred with attorney Cristina J. Nolan of Manly, Stewart
- 1 -
DECLARATION OF RAYMOND F. DOLEN IN SUPPORT OF DEFENDANT’S DEMURRER
V V
& Finaldi t0 discuss the contents of my demurrer and potential motion to strike. We
spoke on April 4, 2022 and e-mailed each other several times prior re: the demurrer and
motion to strike. Ms. Nolan and I were able to reach an agreement on a very significant
issue, that involving treble damages, which rendered a potential motion to strike moot.
However, we were unable to reach an agreement resolving the issues set forth in the
\OOONONKIIAUJNH
demurrer.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
Executed this 5th day of April, 2022 at Redlands, California.
DOLEN TUCKER TIERNEY & ABRAHAM
Attorne s for Defendant,
VICTO VALLEY UNION HIGH SCHOOL
DISTRICT
NNNNNNNNNr—ip—Ir—tt—Ir—AHHHn—th—I
MQONUI#UJNHO\OOONO\UIAUJNHO
. 2 -
DECLARATION OF RAYMOND F. DOLEN IN SUPPORT OF DEFENDANT’S DEMURRER
Document Filed Date
April 06, 2022
Case Filing Date
November 03, 2021
Category
Other PI/PD/WD Unlimited
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Preview
\a Ra mond F. Dolen SBN 130534 F I LE SUPERIOR COURT 0F CALIFORNIA D D LEN TUCKER TIERNEY & ABRAHAM COUNTY 0F SAN BERNARDINO 1710 Plum Lane, Suite A SAN BERNARDINO DISTRICT Redlands, CA 92374 Ph: 951-683-6014 APR 06 2022 Fax: 951-683-03 14 rdolen@redlands-law.com Our File No: 12-303b Bv/L/zifi \ooouoxmpmm.‘ Attorne s for Defendant, W5 “\QL (11m DEPUTY VICTO VALLEY UNION HIGH SCHOOL DISTRICT SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO JOHN VBK DOE, an individual; CASE NO: CIVSB 2200478 Assigned Judge : Wilfred J. Schneider Plaintiff, Department : S-32 Complaint Filed : January 7, 2022 vs. [Fee Exempt per Gov. Code §6103] VICTOR VALLEY UNION HIGH SCHOOL DISTRICT, a business entity of DECLARATION OF RAYMOND F. form unknown; ERIC LYNN BROWN, an DOLEN IN SUPPORT OF individual, and DOES through 100, 1 DEFENDANT’S DEMURRER Defendants. Concurrently with Defendant’s Demurrer to [Filed Complaint of Plaintiff and Request for Judicial Notice] NNNNNNNNNv—dp—np—I—‘v—ar—IHHHH OOQOUIAUJNt—‘OKDOOQONUI-PWNF-‘O Date: May 24, 2022 Time: 9:00 a.m. Department: S-32 I, Raymond F. Dolen, declare as follows: I am an attorney duly licensed to practice before all of the courts in the State of California and am a principal in the law firm of Dolen, Tucker, Tierney & Abraham, attorneys of record for defendant Victor Valley Union High School District. This declaration is submitted in support of the demurrer which I prepared t0 the plaintiff s complaint. Pursuant t0 Code ofCivz'l Procedure §430.41(a) and pursuant to Code osz'vz'l Procedure §435.5, I met and conferred with attorney Cristina J. Nolan of Manly, Stewart - 1 - DECLARATION OF RAYMOND F. DOLEN IN SUPPORT OF DEFENDANT’S DEMURRER V V & Finaldi t0 discuss the contents of my demurrer and potential motion to strike. We spoke on April 4, 2022 and e-mailed each other several times prior re: the demurrer and motion to strike. Ms. Nolan and I were able to reach an agreement on a very significant issue, that involving treble damages, which rendered a potential motion to strike moot. However, we were unable to reach an agreement resolving the issues set forth in the \OOONONKIIAUJNH demurrer. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed this 5th day of April, 2022 at Redlands, California. DOLEN TUCKER TIERNEY & ABRAHAM Attorne s for Defendant, VICTO VALLEY UNION HIGH SCHOOL DISTRICT NNNNNNNNNr—ip—Ir—tt—Ir—AHHHn—th—I MQONUI#UJNHO\OOONO\UIAUJNHO . 2 - DECLARATION OF RAYMOND F. DOLEN IN SUPPORT OF DEFENDANT’S DEMURRER