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
Ra mondF. Dolen SBN 130534
D LEN TUCKER TIERNEY & ABRAHAM SUPER“)figgufisgmpomm
COUNTY 0F SAN BgnNAnmNo
17 10 Plum Lane, SUite A SAN BERNARDND DsSTR‘CT
Redlands, CA 92374
Ph: 951-683-6014 2 8 2022
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Fdaxlz 1383(103114 .
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BY
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Our File No: 12-303 KAUS .
\DOONONUI-PUJNt—i
Attorne s for Defendant,
VICTO VALLEY UNION HIGH SCHOOL DISTRICT
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
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JOHN VNR DOE, an individual; CASE NO: CIVSB 213 141 8
p—ax
é Assigned Judge: Khymberli S. Apaloo
DJ.N Plaintiff, ) Department: S-25
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Complaint Filed: November 3, 2021
VS.
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A [Fee Exempt per Gov. Code §6103]
VICTOR VALLEY UNION HIGH
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SCHOOL DISTRICT, a business entity 0f DECLARATION OF RAYMOND F.
form unknown; ERIC LYNN BROWN, an DOLEN IN SUPPORT OF
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individual, and DOES 1 through 100 DEFENDANT’S DEMURRER
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fl Defendants. ) Date: April 5, 2022
Time: 9:00 a.m.
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Department: S—25
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\O [Filed Concurrently with Defendant’s Demurrer]
NO I, Raymond F. Dolen, declare as follows:
NH I am an attorney duly licensed t0 practice before all of the courts in the State of
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California and am a principal in thelaw firm of Dolen, Tucker, Tierney & Abraham,
N U) attorneys 0f record for defendant Victor Valley Union High School District.
N$ This declaration is submitted in support 0f the demurrer which I prepared t0 the
U‘I
N plaintiff s complaint.
N O\ Pursuant to Code ofCivil Procedure §430.41(a) and pursuant to Code osz'viZ
NN Procedure §435.5, I met and conferred with attorney Cristina J. Nolan of Manly, Stewart
N 00 & Finaldi to discuss the contents of my demurrer and potential motion to strike. We
_ 1 _
DECLARATION OF RAYMOND F. DOLEN IN SUPPORT OF DEFENDANT’S DEMURRER
V V
spoke on February 18, 2022. Ms. Nolan and I were able to reach an agreement on a very
significant issue, that involving treble damages, Which rendered a potential motion t0
strike on my part moot. However, we were unable t0 reach an agreement resolving the
issues set forth in my demurrer.
I declare under penalty of perjury under the laws 0f the State 0f California that the
\OOOQQUI-PUJNH
foregoing is true and correct.
Executed this 25th day of February, 2022 at Redlands, California.
DOLEN TUCKER TIERNEY & ABRAHAM
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VICTO VALLEY UNION HIGH SCHOOL
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DECLARATION OF RAYMOND F. DOLEN IN SUPPORT OF DEFENDANT’S DEMURRER
Document Filed Date
February 28, 2022
Case Filing Date
November 03, 2021
Category
Other PI/PD/WD Unlimited
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Preview
Ra mondF. Dolen SBN 130534 D LEN TUCKER TIERNEY & ABRAHAM SUPER“)figgufisgmpomm COUNTY 0F SAN BgnNAnmNo 17 10 Plum Lane, SUite A SAN BERNARDND DsSTR‘CT Redlands, CA 92374 Ph: 951-683-6014 2 8 2022 - Fdaxlz 1383(103114 . r O en (2)5re an S- aW.C01Tl BY ”aggr- UEIDEPU-W Our File No: 12-303 KAUS . \DOONONUI-PUJNt—i Attorne s for Defendant, VICTO VALLEY UNION HIGH SCHOOL DISTRICT SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO .—; O p— >-‘ JOHN VNR DOE, an individual; CASE NO: CIVSB 213 141 8 p—ax é Assigned Judge: Khymberli S. Apaloo DJ.N Plaintiff, ) Department: S-25 g—n Complaint Filed: November 3, 2021 VS. v—n A [Fee Exempt per Gov. Code §6103] VICTOR VALLEY UNION HIGH r—t kl] SCHOOL DISTRICT, a business entity 0f DECLARATION OF RAYMOND F. form unknown; ERIC LYNN BROWN, an DOLEN IN SUPPORT OF r—t ON individual, and DOES 1 through 100 DEFENDANT’S DEMURRER v—t fl Defendants. ) Date: April 5, 2022 Time: 9:00 a.m. r—i 00 Department: S—25 i t—d \O [Filed Concurrently with Defendant’s Demurrer] NO I, Raymond F. Dolen, declare as follows: NH I am an attorney duly licensed t0 practice before all of the courts in the State of N [\J California and am a principal in thelaw firm of Dolen, Tucker, Tierney & Abraham, N U) attorneys 0f record for defendant Victor Valley Union High School District. N$ This declaration is submitted in support 0f the demurrer which I prepared t0 the U‘I N plaintiff s complaint. N O\ Pursuant to Code ofCivil Procedure §430.41(a) and pursuant to Code osz'viZ NN Procedure §435.5, I met and conferred with attorney Cristina J. Nolan of Manly, Stewart N 00 & Finaldi to discuss the contents of my demurrer and potential motion to strike. We _ 1 _ DECLARATION OF RAYMOND F. DOLEN IN SUPPORT OF DEFENDANT’S DEMURRER V V spoke on February 18, 2022. Ms. Nolan and I were able to reach an agreement on a very significant issue, that involving treble damages, Which rendered a potential motion t0 strike on my part moot. However, we were unable t0 reach an agreement resolving the issues set forth in my demurrer. I declare under penalty of perjury under the laws 0f the State 0f California that the \OOOQQUI-PUJNH foregoing is true and correct. Executed this 25th day of February, 2022 at Redlands, California. DOLEN TUCKER TIERNEY & ABRAHAM p—t o p—d r—I VICTO VALLEY UNION HIGH SCHOOL H DISTRICT m_N r—I p—n A r—A U1 p—t ON r—d fl u—A M r—I Q NO N r—I N [\J N U) Nb N LII N O\ Nfl N OO _ 2 _ DECLARATION OF RAYMOND F. DOLEN IN SUPPORT OF DEFENDANT’S DEMURRER