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1 Christopher J. Fry, Esq. (SBN: 298874)
Email: cfry@frylawcorp.com
2 Kristine Du, Esq. (SBN: 338095)
Email: kdu@frylawcorp.com
3 FRY LAW CORPORATION
980 9th Street, 16th Floor
4 Sacramento, California 95814
Telephone: (916) 291-0700
5 Facsimile: (916) 848-0256
6 Attorneys for Plaintiff,
SHERRY LARSEN and dba CALIFORNIA STATE ENTERPRISES
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8 SUPERIOR COURT FOR THE STATE OF CALIFORNIA
9 IN AND FOR THE COUNTY OF PLACER
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12 SHERRY LARSEN, individually and dba CASE NO.: S-CV-0045659
CALIFORNIA STATE ENTERPRISES,
13 DECLARATION OF CHRISTOPHER J.
Plaintiff, FRY IN SUPPORT OF MOTION TO
14 CONTINUE TRIAL AND RELATED
vs. DATES
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PLACER VALLEY SPORTS COMPLEX, Date: January 3, 2023
16 INC. dba @the Grounds, a California
Corporation; and DOES 1-10, inclusive, Time: 8:30 a.m.
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Defendants. Dept.: 31
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Trial: November 14, 2022
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Action Filed: October 2, 2020
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DECLARATION OF CHRISTOPHER J. FRY
1 I, Christopher J. Fry, hereby declare and state as follows:
2 I am counsel of record for the Plaintiff herein. I am duly licensed to practice before
3 the Courts of the State of California, including this Honorable Court. If called to do so, I
4 could, and would, testify to the matters contained herein of my own personal knowledge,
5 except as to those matters which are stated upon information and belief, and as to those
6 matters, I believe them to be true.
7 This is a complicated contract case. It has not been pending long. The first
8 deposition in the case was taken only recently. Defendant just recently fully responded to
9 discovery and that discovery is deficient. Plaintiff was in pro per for a lengthy amount of
10 time. Plaintiff only recently retained my office.
11 The case was filed approximately two (2) years ago. Plaintiff alleges Defendant
12 cancelled the Facility License Agreement and Plaintiff’s rights to hold events at the Placer
13 County Fairgrounds between 2020 and 2025 in breach of the agreement. Plaintiff seeks
14 damages of over $250,000.00, interest, and attorney fees, trial should not be rushed.
15 No parties will suffer prejudice as Plaintiff no longer able to hold events at the
16 Fairgrounds, and time will only serve to clarify the claims and potentially prompt
17 settlement discussions.
18 Plaintiff retained our office in November of 2022. At that point, trial was set for
19 November 14, 2022, just a few days later. It is currently trailing waiting for a courtroom
20 Plaintiff’s counsels need time to review Plaintiff’s file and be up to date with the facts of
21 the case, it was apparent the case had work that needed to be done. I proposed
22 continuing the trial as various deadlines may have come and gone. Defendant has had
23 notice of Plaintiff’s intent to push trial out for at least a few weeks.
24 I attempted to meet and confer to obtain a stipulation to continue trial but said
25 attempts have been steadfastly rejected by Defendant. Plaintiff is bringing this motion to
26 continue the trial, the settlement conference and any related dates at least six (6) months.
27 I Declare under penalty of perjury and under the laws of the State of California that
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DECLARATION OF CHRISTOPHER J. FRY
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1 the foregoing is true and correct to the best of my personal knowledge.
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3 DATED: November 15, 2022 Respectfully submitted,
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FRY LAW CORPORATION
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7 By:_________________________________
Christopher J. Fry, Esq.
8 Attorneys for Plaintiff
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DECLARATION OF CHRISTOPHER J. FRY
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PROOF OF SERVICE
2 CALIFORNIA SUPERIOR COURT
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I am employed in the County of Sacramento, State of California. I am over the age
4 of 18 and not a party to the within action; my business address is: 980 9th Street, 16th
Floor, Sacramento, California 95814. On November 15, 2022, I served the foregoing
5 document(s) described as:
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DECLARATION OF CHRISTOPHER J. FRY IN SUPPORT OF MOTION TO
7 CONTINUE TRIAL AND RELATED DATES
8 On all interested parties in this action addressed as follows:
9 Defendant Placer Valley Sports Complex, Inc.:
10 Sinclair Wilson, et al.
Robert F. Sinclair, Esq.
11 2390 Professional Drive
Roseville, CA 95661
12 Email: rsinclair@swbclaw.com
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[X] BY MAIL AND ELECTRONIC TRANSMISSION: I caused such documents to
14 be mailed and emailed to the email address above. I did not receive, within a reasonable
time after the transmission, any electronic message or other indication that the
15 transmission was unsuccessful.
16 I declare that I am employed in the office of a member of the bar of this court at
17 whose direction the service was made. I declare under penalty of perjury under the laws
of California that the above is true and correct. Executed on November 15, 2022, at
18 Sacramento, California.
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21 Christopher J. Fry
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DECLARATION OF CHRISTOPHER J. FRY
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1 Christopher J. Fry, Esq. (SBN: 298874) Email: cfry@frylawcorp.com 2 Kristine Du, Esq. (SBN: 338095) Email: kdu@frylawcorp.com 3 FRY LAW CORPORATION 980 9th Street, 16th Floor 4 Sacramento, California 95814 Telephone: (916) 291-0700 5 Facsimile: (916) 848-0256 6 Attorneys for Plaintiff, SHERRY LARSEN and dba CALIFORNIA STATE ENTERPRISES 7 8 SUPERIOR COURT FOR THE STATE OF CALIFORNIA 9 IN AND FOR THE COUNTY OF PLACER 10 11 12 SHERRY LARSEN, individually and dba CASE NO.: S-CV-0045659 CALIFORNIA STATE ENTERPRISES, 13 DECLARATION OF CHRISTOPHER J. Plaintiff, FRY IN SUPPORT OF MOTION TO 14 CONTINUE TRIAL AND RELATED vs. DATES 15 PLACER VALLEY SPORTS COMPLEX, Date: January 3, 2023 16 INC. dba @the Grounds, a California Corporation; and DOES 1-10, inclusive, Time: 8:30 a.m. 17 Defendants. Dept.: 31 18 Trial: November 14, 2022 19 Action Filed: October 2, 2020 20 21 22 23 24 25 26 27 28 DECLARATION OF CHRISTOPHER J. FRY 1 I, Christopher J. Fry, hereby declare and state as follows: 2 I am counsel of record for the Plaintiff herein. I am duly licensed to practice before 3 the Courts of the State of California, including this Honorable Court. If called to do so, I 4 could, and would, testify to the matters contained herein of my own personal knowledge, 5 except as to those matters which are stated upon information and belief, and as to those 6 matters, I believe them to be true. 7 This is a complicated contract case. It has not been pending long. The first 8 deposition in the case was taken only recently. Defendant just recently fully responded to 9 discovery and that discovery is deficient. Plaintiff was in pro per for a lengthy amount of 10 time. Plaintiff only recently retained my office. 11 The case was filed approximately two (2) years ago. Plaintiff alleges Defendant 12 cancelled the Facility License Agreement and Plaintiff’s rights to hold events at the Placer 13 County Fairgrounds between 2020 and 2025 in breach of the agreement. Plaintiff seeks 14 damages of over $250,000.00, interest, and attorney fees, trial should not be rushed. 15 No parties will suffer prejudice as Plaintiff no longer able to hold events at the 16 Fairgrounds, and time will only serve to clarify the claims and potentially prompt 17 settlement discussions. 18 Plaintiff retained our office in November of 2022. At that point, trial was set for 19 November 14, 2022, just a few days later. It is currently trailing waiting for a courtroom 20 Plaintiff’s counsels need time to review Plaintiff’s file and be up to date with the facts of 21 the case, it was apparent the case had work that needed to be done. I proposed 22 continuing the trial as various deadlines may have come and gone. Defendant has had 23 notice of Plaintiff’s intent to push trial out for at least a few weeks. 24 I attempted to meet and confer to obtain a stipulation to continue trial but said 25 attempts have been steadfastly rejected by Defendant. Plaintiff is bringing this motion to 26 continue the trial, the settlement conference and any related dates at least six (6) months. 27 I Declare under penalty of perjury and under the laws of the State of California that 28 DECLARATION OF CHRISTOPHER J. FRY 1 1 the foregoing is true and correct to the best of my personal knowledge. 2 3 DATED: November 15, 2022 Respectfully submitted, 4 FRY LAW CORPORATION 5 6 7 By:_________________________________ Christopher J. Fry, Esq. 8 Attorneys for Plaintiff 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DECLARATION OF CHRISTOPHER J. FRY 2 1 PROOF OF SERVICE 2 CALIFORNIA SUPERIOR COURT 3 I am employed in the County of Sacramento, State of California. I am over the age 4 of 18 and not a party to the within action; my business address is: 980 9th Street, 16th Floor, Sacramento, California 95814. On November 15, 2022, I served the foregoing 5 document(s) described as: 6 DECLARATION OF CHRISTOPHER J. FRY IN SUPPORT OF MOTION TO 7 CONTINUE TRIAL AND RELATED DATES 8 On all interested parties in this action addressed as follows: 9 Defendant Placer Valley Sports Complex, Inc.: 10 Sinclair Wilson, et al. Robert F. Sinclair, Esq. 11 2390 Professional Drive Roseville, CA 95661 12 Email: rsinclair@swbclaw.com 13 [X] BY MAIL AND ELECTRONIC TRANSMISSION: I caused such documents to 14 be mailed and emailed to the email address above. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the 15 transmission was unsuccessful. 16 I declare that I am employed in the office of a member of the bar of this court at 17 whose direction the service was made. I declare under penalty of perjury under the laws of California that the above is true and correct. Executed on November 15, 2022, at 18 Sacramento, California. 19 20 ____________________ 21 Christopher J. Fry 22 23 24 25 26 27 28 DECLARATION OF CHRISTOPHER J. FRY 3