On July 21, 2022 a
Motion-Secondary
was filed
involving a dispute between
Ventura, Mario,
and
Does 1-10,
General Motors, Llc,
for Breach of Contract/Warranty Unlimited
in the District Court of San Bernardino County.
Preview
g .
omINAL
Mary Arens McBride, Esq. (SBN: 282459)
Stacey S. Davis, Esq. (SBN: 1641 16)
ERSKINE LAW GROUP, APC
1576 N. Batavia Street, Suite A
Orange, California 92867
Phone: (949) 777-6032
Fax: (714) 844-9035
Email: marensmcbride@erskinelaw.com
Email: sdavis@erskinelaw.com
\OOO\]O\Ul-b
Attorneys for Defendant,
GENERAL MOTORS LLC
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10
COUNTY OF SAN BERNARDINO
11
12 MARIO VENTURA, an individual, Case No.: CIV SB 2215820
13
Plaintiff, DECLARATION 0F STACEY DAVIS 1N w
14 SUPPORT OF GENERAL MOTORS -<
V~
LLC’S DEMURRER AND MOTION TO Tl
15 STRIKE PUNITIVE DAMAGES AS TO
PLAINTIFF S FIRST AMENDED
h
16 GENERAL MOTORS LLC, a Delaware ><
Limited Liability Company, and DOES 1
COMPLAINT
17 through 10, inclusive,
_ I
[Flled concurrently w1th Demurrer, Motion
18 t0 Strike Punitive Damages, and [Proposed]
Defendants. Orders]
19
DATE: April 12, 2023
20
TIME: 8:30 am.
21
DEPT: Sl4
22
23 DECLARATION OF STACEY DAVIS
24 I, Stacey Davis, declare as follows:
25 1. I am an attorney at law licensed to practice before all courts of the State of
26 California, and an attorney with the law firm of Erskine Law Group, APC, counsel of record for
27 General Motors LLC (“GM”), defendant in this litigation. This declaration is submitted in support
28 of GM’s Demurrer and Motion to Strike relating to Plaintiff’s First Amended Complaint (“FAC”).
PAGE 1 0F 3
DECLARATION OF STACEY DAVIS IN SUPPORT OF GENERAL MOTORS LLC’S DEMURRER AND
MOTION TO STRIKE AS TO PLAINTIFF’S FIRST AMENDED COMPLAINT
' p
I am familiar with the records and pleadings 0n file in this action and if called as a witness, I could
and would competently testify to the matters set forth below. Matters outside of my personal
knowledge are based upon information and belief.
QONUI¥UJN
2. Prior t0 filing GM’s Demurrer and Motion to Strike, this office attempted to meet
and confer telephonically with Plaintiff’ s counsel t0 discuss the issues we had with Plaintiff s FAC,
but unfortunately, were unsuccessful in our attempts.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
Executed 0n February 10, 2023, in Orange, California.
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13 Stacey Davis, Esq.
Counsel for General Motors LLC
14
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PAGE 2 0F 3
DECLARATION OF STACEY DAVIS IN SUPPORT OF GENERAL MOTORS LLC’S DEMURRER AND
MOTION TO STRIKE AS TO PLAINTIFF’S FIRST AMENDED COMPLAINT
Document Filed Date
February 14, 2023
Case Filing Date
July 21, 2022
Category
Breach of Contract/Warranty Unlimited
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g . omINAL Mary Arens McBride, Esq. (SBN: 282459) Stacey S. Davis, Esq. (SBN: 1641 16) ERSKINE LAW GROUP, APC 1576 N. Batavia Street, Suite A Orange, California 92867 Phone: (949) 777-6032 Fax: (714) 844-9035 Email: marensmcbride@erskinelaw.com Email: sdavis@erskinelaw.com \OOO\]O\Ul-b Attorneys for Defendant, GENERAL MOTORS LLC SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF SAN BERNARDINO 11 12 MARIO VENTURA, an individual, Case No.: CIV SB 2215820 13 Plaintiff, DECLARATION 0F STACEY DAVIS 1N w 14 SUPPORT OF GENERAL MOTORS -< V~ LLC’S DEMURRER AND MOTION TO Tl 15 STRIKE PUNITIVE DAMAGES AS TO PLAINTIFF S FIRST AMENDED h 16 GENERAL MOTORS LLC, a Delaware >< Limited Liability Company, and DOES 1 COMPLAINT 17 through 10, inclusive, _ I [Flled concurrently w1th Demurrer, Motion 18 t0 Strike Punitive Damages, and [Proposed] Defendants. Orders] 19 DATE: April 12, 2023 20 TIME: 8:30 am. 21 DEPT: Sl4 22 23 DECLARATION OF STACEY DAVIS 24 I, Stacey Davis, declare as follows: 25 1. I am an attorney at law licensed to practice before all courts of the State of 26 California, and an attorney with the law firm of Erskine Law Group, APC, counsel of record for 27 General Motors LLC (“GM”), defendant in this litigation. This declaration is submitted in support 28 of GM’s Demurrer and Motion to Strike relating to Plaintiff’s First Amended Complaint (“FAC”). PAGE 1 0F 3 DECLARATION OF STACEY DAVIS IN SUPPORT OF GENERAL MOTORS LLC’S DEMURRER AND MOTION TO STRIKE AS TO PLAINTIFF’S FIRST AMENDED COMPLAINT ' p I am familiar with the records and pleadings 0n file in this action and if called as a witness, I could and would competently testify to the matters set forth below. Matters outside of my personal knowledge are based upon information and belief. QONUI¥UJN 2. Prior t0 filing GM’s Demurrer and Motion to Strike, this office attempted to meet and confer telephonically with Plaintiff’ s counsel t0 discuss the issues we had with Plaintiff s FAC, but unfortunately, were unsuccessful in our attempts. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed 0n February 10, 2023, in Orange, California. 10 11 12 13 Stacey Davis, Esq. Counsel for General Motors LLC 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PAGE 2 0F 3 DECLARATION OF STACEY DAVIS IN SUPPORT OF GENERAL MOTORS LLC’S DEMURRER AND MOTION TO STRIKE AS TO PLAINTIFF’S FIRST AMENDED COMPLAINT