Party Statement: EASON -v- BLM VICTORVILLE et al Print

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        THOMPSON                                  COLEGATE LLP
        3610 Fourteenth Street
        P O Box 1299
        Riverside California 92502
        Tel         951 682 5550
        Fax         951 781 4012


        GARY T MONTGOMERY SBN 166817
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                                                                                                       COUNII aF SAN BER IARO
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        L SLIL E MU1                                 17 II SBN 097221
        lmurad ci tci ru nct                                                                                 APR 2 4 2019
        DANIEL C FAUSTINO SBN 207553
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                                                                                                             CE AR R LEi E
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                                                                                   I                 BLM    VICTORVILLE           a
        Aiio ncys for Defer c anis SPICE DELJG I7
                                                                                             and

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           lifaa t a Limited Partne slaip sued and vc cl


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                                                          SUPERIOR COURT OF THE STATE OF CALIFORNIA

                                                             FOR THE COUNTY OF SAN BERNARDINO                                               t




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        DEBORAH ANTIONETTE EASON                                                        CASE NO CIVDS 1621424

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                                                Plaintiff                               JUDGE Hon Thomas Garza Dept S27

                                                                                        DECLARATION OF LESLIE E MURAD
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                                                                                        II IN SUPPORT OF DEFENDANT S
        DOLLAR TREE STORES INC    SPICE                                                 OPPOSITION TO PLAINTIFF S MOTION
        DELIGHT INC and DOES 1 TO 100 Inclusive                                         TO QUASH
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 q                                              Defendants                               FILED C 3l CURRENTLY W1TIT
                                                                                        DEFENI ANT S OPPO               I7 IOl        AND

                                                                                        DECLARATION OF GARY T
                                                                                        MONTGOMERY IN SUPPORT

    a
                                                                                        DATE May 6 2019
                                                                                        TIME 8 30 a m
                                                                                        DEPT S27

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                                                                                        TRIAL DATE                   03 02 2020
                                                                                        ACTION FILED                 12 08 2016
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                                                                 DECLARATION OF LESLIE E MURAD II
    1                                    DECLARATION OF LESLIE E MURAD II ESQ

2                I LESLIE E MURAD II declare as follows

    3            1         I    am an associate        with   the   law firm   of   Thompson        Colegate LLP    attorneys of


    4   record   herein for Defendants SPICE DELIGHT                          1NC   and BLM VICTORVILLE a California

    5   Limited      Partnership    sued and served as          DOE 1     hereinafter   Defendants        opposing defendants to

        the Motion to Quash filed by the Plaintiff I have been duly admitted to practice law in the State of
    7   California I make this declaration in support of Defendants Opposition to the Plaintiff s Motion to

        Quash the subpoenas seeking medical records for the Plaintiff from Dr Joseph Ho and Victor Valley
    9   Community Hospital based on my own personal knowledge and a review of the file of this matter
    a   maintained in our offices If called upon to testify I could and would competently testify thereto

t i              2         Attached hereto        as   Exhibit      A    and incorporated herein by reference is a true and

a2      correct copy of pages from the Transdev Services Inc employment file for the plaintiff dealing with
    3   her medical treatment at or by the offices of Dr Joseph Ho and Victor Valley Community Hospital
1                 3        On or about March 7 2019 I received a telephone call from Anna Mkhitarian

l5      paralegal to Araksya Boyadzhyan Esq counsel for the plaintiff Ms Mkhitarian wanted to know
1 G     about our subpoenas and why we were seeking these records since their office was not aware of
        whom these medical providers were I explained that both Dr Ho and Victor Valley Community

                                                                                        file     from   Transdev   Services   Inc
18      Hospital       were     identified   in   the    plaintif    s   employment




19        Transdev         Contrary to what the plaintif s counsel understood Ms Eason did in fact make a
2o      Workers Compensation Claim stemming from                           a   December     11   2014 fall with her employer

2t      Transdev Dr Ho was her treating Workers Compensation doctor The Workers Compensation
    2   Claim was later denied by Ms Eason s employer

    3             4        I also told Ms Mkhitarian that we most likely would not obtain any records from Dr
2       Ho   since our    copy     service   Bosco Legal Services Inc               Bosco      had found that Dr Ho had left the

2s      State and was most likely now in Alabama

2t                5            I also told Ms Mkhitarian that the employment file disclosed Ms Eason had suffered

27      an illness injury in June of 2014 at the same Dollar Tree shopping center and was treated at Victor
28      Valley Community Hospital for her injuries We wanted to find out what was the prior injury illness
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                                                  DECLARATION OF LESLIE E MURAD II