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1 John S. Rueppel (SBN: 267467)
Angie Lam (SBN: 244719)
2 JOHNSTON, KINNEY & ZULAICA LLP
101 Montgomery Street, Suite 1600
3 San Francisco, California 94104
4 Telephone: (415) 693-0550
Facsimile: (415) 693-0500
5 Email: john@jkzllp.com
angie.lam@jkzllp.com
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Attorneys for Plaintiff,
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Lisa Keith
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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IN THE COUNTY OF NAPA
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11 LISA KEITH, CASE NO: 22CV001269
12 Plaintiff, DECLARATION OF CAROLINA RAMOS
13 IN SUPPORT OF PLAINTIFF LISA
v. KEITH’S SUR-REPLY TO OPPOSITION
14 TO DEFENDANTS VALLEY ROCK
CELESTE WHITE, an individual, ROBERT FOUNDATION’S AND DR. ROBERT
15 WHITE, an individual, the VALLEY ROCK WHITE’S NOTICE OF MOTION AND
FOUNDATION, aka THE BAR 49 MOTION FOR ISSUE, EVIDENCE,
16 FOUNDATION, a charitable organization, and AND/OR TERMINATING SANCTIONS
17 DOES 1-50, INCLUSIVE, AGAINST PLAINTIFF LISA KEITH FOR
VIOLATING COURT ORDER
18 Defendants. COMPELLING RESPONSES TO
DISCOVERY; AND REQUEST FOR
19 SANCTIONS PURSUANT TO CCP §
2023.030
20
21
Date: November 7, 2023
22 Time: 8:30 a.m.
Judge: Hon. Scott R.L. Young
23 Dept.: B
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Complaint Filed: October 25, 2022
25 FAC Filed: March 8, 2023
Trial Date: April 2, 2024
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DECLARATION OF CAROLINA RAMOS IN SUPPORT OF PLAINTIFF’S SUR-REPLY TO OPPOSITION
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1 I, Carolina Ramos, declare as follows:
2 1. I am a paralegal with the firm Johnston, Kinney & Zulaica LLP. I have personal
3 knowledge of the following and if called upon could and would testify competently thereto.
4 2. On October 14, 2023, I attempted to access a document production link for the above
5 referenced matter that Mr. Benjamin Rose (“Mr. Rose”) of Carden Rose, Inc. had provided the day
6 before.
7 3. Since Mr. Rose uploaded the document production into a Sharefile drive in which I did
8 not have access to, I emailed Mr. Rose and requested a OneDrive link instead.
9 4. On October 15, 2023, I received a OneDrive link from Mr. Rose and was then able to
10 access the production. I then downloaded the production so that the process of reviewing the documents
11 for relevancy can start.
12 5. On October 19, 2023, I received instruction from Ms. Angie Lam, an associate attorney
13 at my firm, to prepare documents for service to Defendants’ counsel.
14 6. As part of my responsibilities, which is also the normal course of business at the firm, I
15 bate stamped each of the 151 documents identified to be produced as part of Ms. Lisa Keith’s
16 supplemental production.
17 7. Other than bate stamping the 151 documents that will be produced, I did not alter, modify,
18 or change any of the documents in Ms. Lisa Keith’s supplemental production.
19 8. On October 23, 2023, I served via electronic service, to the Defendants’ counsel, Mr.
20 Jeffrey Tsai and Ms. Kathleen Kizer, Ms. Lisa Keith’s supplemental production. A true and correct copy
21 of the October 23, 2023 proof of service is attached hereto as Exhibit A.
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DECLARATION OF CAROLINA RAMOS IN SUPPORT OF PLAINTIFF’S SUR-REPLY TO OPPOSITION
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1 I declare under penalty of perjury under the laws of the State of California that the foregoing is
2 true and correct.
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Executed on November 2, 2023 at Antioch, California.
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5 JOHNSTON, KINNEY & ZULAICA LLP
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7 Dated: November 2, 2023 By:
8 Carolina Ramos, Declarant
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DECLARATION OF CAROLINA RAMOS IN SUPPORT OF PLAINTIFF’S SUR-REPLY TO OPPOSITION
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Exhibit A
Lisa Keith v. Celeste White, et al.
Napa County Superior Court
Case No. 22CV001269
DECLARATION OF CAROLINA RAMOS IN SUPPORT
OF PLAINTIFF LISA KEITH’S SUR-REPLY TO
OPPOSITION TO DEFENDANTS VALLEY ROCK
FOUNDATION’S AND DR. ROBERT WHITE’S NOTICE
OF MOTION AND MOTION FOR ISSUE, EVIDENCE,
AND/OR TERMINATING SANCTIONS AGAINST
PLAINTIFF LISA KEITH FOR VIOLATING COURT
ORDER COMPELLING RESPONSES TO DISCOVERY;
AND REQUEST FOR SANCTIONS PURSUANT TO CCP
§2023.030
1 PROOF OF SERVICE
2
STATE OF CALIFORNIA, CITY AND COUNTY OF SAN FRANCISCO
3
I am employed in the City and County of San Francisco, State of California. I am over the age
4 of 18 years and not a party to the within action; my business address is Johnston Kinney & Zulaica LLP,
101 Montgomery Street, Suite 1600, San Francisco, California 94104. My business email address is
5 carolina@jkzllp.com.
6
On October 23, 2023, I served the foregoing document described as:
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SUPPLEMENTAL DOCUMENT PRODUCTION IN RESPONSE TO DEFENDANT,
8 VALLEY ROCK FOUNDATION’S REQUEST FOR PRODUCTION OF DOCUMENTS
TO PLAINTIFF LISA KEITH, SET ONE
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10 on all interested parties in this action addressed as follows:
11 Jeffrey E. Tsai, Esq.
Kathleen S. Kizer, Esq.
12 DLA PIPER LLP (US)
555 Mission Street, Suite 2400
13 San Francisco, CA 94105
14 Jeff.tsai@us.dlapiper.com
Kathy.kizer@us.dlapiper.com
15
[X] (BY EMAIL) Pursuant to Code of Civil Procedure section 1010.6, I caused the document(s) to
16 be electronically transmitted by me to the persons listed in the above email address(es). I did not receive
within a reasonable time after the transmission, any electronic message or other indication that the
17 transmission was unsuccessful.
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[X] (STATE) I declare under penalty of perjury under the laws of the State of California that the
19 foregoing is true and correct.
20 Executed on October 23, 2023, at San Francisco, California.
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Carolina Ramos
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25 4864-4694-0813, v. 1
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PROOF OF SERVICE
PROOF OF SERVICE
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2 STATE OF CALIFORNIA, CITY OF ANTIOCH AND COUNTY OF CONTRA COSTA
3
I am employed in the City and County of San Francisco, State of California. I am over the age of
4 18 years and not a party to the within action; my business address is Johnston Kinney & Zulaica LLP,
101 Montgomery Street, Suite 1600, San Francisco, California 94104. My electronic business address is
5 carolina@jkzllp.com.
6 On November 2, 2023, I served the foregoing document(s):
7
1. DECLARATION OF CAROLINA RAMOS IN SUPPORT OF PLAINTIFF LISA KEITH’S
8 SUR-REPLY TO OPPOSITION TO DEFENDANTS VALLEY ROCK FOUNDATION’S
AND DR. ROBERT WHITE’S NOTICE OF MOTION AND MOTION FOR ISSUE,
9 EVIDENCE, AND/OR TERMINATING SANCTIONS AGAINST PLAINTIFF LISA KEITH
FOR VIOLATING COURT ORDER COMPELLING RESPONSES TO DISCOVERY
10
11 I served the documents on the person or persons listed below as follows:
12 Jeffrey E. Tsai
Kathleen S. Kizer
13 DLA PIPER LLP (US)
555 Mission Street, Suite 2400
14 San Francisco, CA 94105
Jeff.tsai@us.dlapiper.com
15 Katy.kizer@us.dlapiper.com
Attorneys for Defendants
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[X] (BY EMAIL) Pursuant to Code of Civil Procedure section 1010.6, I caused the document(s) to
17 be electronically transmitted by me to the persons listed in the above email address(es). I did not receive
18 within a reasonable time after the transmission, any electronic message or other indication that the
transmission was unsuccessful.
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I declare under penalty of perjury under the laws of the State of California that the foregoing is
20 true and correct.
21 Executed on November 2, 2023, at Antioch, California.
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Carolina Ramos
24 4893-4976-0652, v. 3
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DECLARATION OF CAROLINA RAMOS IN SUPPORT OF PLAINTIFF’S SUR-REPLY TO OPPOSITION
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Preview
1 John S. Rueppel (SBN: 267467) Angie Lam (SBN: 244719) 2 JOHNSTON, KINNEY & ZULAICA LLP 101 Montgomery Street, Suite 1600 3 San Francisco, California 94104 4 Telephone: (415) 693-0550 Facsimile: (415) 693-0500 5 Email: john@jkzllp.com angie.lam@jkzllp.com 6 Attorneys for Plaintiff, 7 Lisa Keith 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN THE COUNTY OF NAPA 10 11 LISA KEITH, CASE NO: 22CV001269 12 Plaintiff, DECLARATION OF CAROLINA RAMOS 13 IN SUPPORT OF PLAINTIFF LISA v. KEITH’S SUR-REPLY TO OPPOSITION 14 TO DEFENDANTS VALLEY ROCK CELESTE WHITE, an individual, ROBERT FOUNDATION’S AND DR. ROBERT 15 WHITE, an individual, the VALLEY ROCK WHITE’S NOTICE OF MOTION AND FOUNDATION, aka THE BAR 49 MOTION FOR ISSUE, EVIDENCE, 16 FOUNDATION, a charitable organization, and AND/OR TERMINATING SANCTIONS 17 DOES 1-50, INCLUSIVE, AGAINST PLAINTIFF LISA KEITH FOR VIOLATING COURT ORDER 18 Defendants. COMPELLING RESPONSES TO DISCOVERY; AND REQUEST FOR 19 SANCTIONS PURSUANT TO CCP § 2023.030 20 21 Date: November 7, 2023 22 Time: 8:30 a.m. Judge: Hon. Scott R.L. Young 23 Dept.: B 24 Complaint Filed: October 25, 2022 25 FAC Filed: March 8, 2023 Trial Date: April 2, 2024 26 27 28 1 DECLARATION OF CAROLINA RAMOS IN SUPPORT OF PLAINTIFF’S SUR-REPLY TO OPPOSITION f 1 I, Carolina Ramos, declare as follows: 2 1. I am a paralegal with the firm Johnston, Kinney & Zulaica LLP. I have personal 3 knowledge of the following and if called upon could and would testify competently thereto. 4 2. On October 14, 2023, I attempted to access a document production link for the above 5 referenced matter that Mr. Benjamin Rose (“Mr. Rose”) of Carden Rose, Inc. had provided the day 6 before. 7 3. Since Mr. Rose uploaded the document production into a Sharefile drive in which I did 8 not have access to, I emailed Mr. Rose and requested a OneDrive link instead. 9 4. On October 15, 2023, I received a OneDrive link from Mr. Rose and was then able to 10 access the production. I then downloaded the production so that the process of reviewing the documents 11 for relevancy can start. 12 5. On October 19, 2023, I received instruction from Ms. Angie Lam, an associate attorney 13 at my firm, to prepare documents for service to Defendants’ counsel. 14 6. As part of my responsibilities, which is also the normal course of business at the firm, I 15 bate stamped each of the 151 documents identified to be produced as part of Ms. Lisa Keith’s 16 supplemental production. 17 7. Other than bate stamping the 151 documents that will be produced, I did not alter, modify, 18 or change any of the documents in Ms. Lisa Keith’s supplemental production. 19 8. On October 23, 2023, I served via electronic service, to the Defendants’ counsel, Mr. 20 Jeffrey Tsai and Ms. Kathleen Kizer, Ms. Lisa Keith’s supplemental production. A true and correct copy 21 of the October 23, 2023 proof of service is attached hereto as Exhibit A. 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 /// 2 DECLARATION OF CAROLINA RAMOS IN SUPPORT OF PLAINTIFF’S SUR-REPLY TO OPPOSITION f 1 I declare under penalty of perjury under the laws of the State of California that the foregoing is 2 true and correct. 3 Executed on November 2, 2023 at Antioch, California. 4 5 JOHNSTON, KINNEY & ZULAICA LLP 6 7 Dated: November 2, 2023 By: 8 Carolina Ramos, Declarant 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 DECLARATION OF CAROLINA RAMOS IN SUPPORT OF PLAINTIFF’S SUR-REPLY TO OPPOSITION f Exhibit A Lisa Keith v. Celeste White, et al. Napa County Superior Court Case No. 22CV001269 DECLARATION OF CAROLINA RAMOS IN SUPPORT OF PLAINTIFF LISA KEITH’S SUR-REPLY TO OPPOSITION TO DEFENDANTS VALLEY ROCK FOUNDATION’S AND DR. ROBERT WHITE’S NOTICE OF MOTION AND MOTION FOR ISSUE, EVIDENCE, AND/OR TERMINATING SANCTIONS AGAINST PLAINTIFF LISA KEITH FOR VIOLATING COURT ORDER COMPELLING RESPONSES TO DISCOVERY; AND REQUEST FOR SANCTIONS PURSUANT TO CCP §2023.030 1 PROOF OF SERVICE 2 STATE OF CALIFORNIA, CITY AND COUNTY OF SAN FRANCISCO 3 I am employed in the City and County of San Francisco, State of California. I am over the age 4 of 18 years and not a party to the within action; my business address is Johnston Kinney & Zulaica LLP, 101 Montgomery Street, Suite 1600, San Francisco, California 94104. My business email address is 5 carolina@jkzllp.com. 6 On October 23, 2023, I served the foregoing document described as: 7 SUPPLEMENTAL DOCUMENT PRODUCTION IN RESPONSE TO DEFENDANT, 8 VALLEY ROCK FOUNDATION’S REQUEST FOR PRODUCTION OF DOCUMENTS TO PLAINTIFF LISA KEITH, SET ONE 9 10 on all interested parties in this action addressed as follows: 11 Jeffrey E. Tsai, Esq. Kathleen S. Kizer, Esq. 12 DLA PIPER LLP (US) 555 Mission Street, Suite 2400 13 San Francisco, CA 94105 14 Jeff.tsai@us.dlapiper.com Kathy.kizer@us.dlapiper.com 15 [X] (BY EMAIL) Pursuant to Code of Civil Procedure section 1010.6, I caused the document(s) to 16 be electronically transmitted by me to the persons listed in the above email address(es). I did not receive within a reasonable time after the transmission, any electronic message or other indication that the 17 transmission was unsuccessful. 18 [X] (STATE) I declare under penalty of perjury under the laws of the State of California that the 19 foregoing is true and correct. 20 Executed on October 23, 2023, at San Francisco, California. 21 22 Carolina Ramos 23 24 25 4864-4694-0813, v. 1 26 27 28 1 PROOF OF SERVICE PROOF OF SERVICE 1 2 STATE OF CALIFORNIA, CITY OF ANTIOCH AND COUNTY OF CONTRA COSTA 3 I am employed in the City and County of San Francisco, State of California. I am over the age of 4 18 years and not a party to the within action; my business address is Johnston Kinney & Zulaica LLP, 101 Montgomery Street, Suite 1600, San Francisco, California 94104. My electronic business address is 5 carolina@jkzllp.com. 6 On November 2, 2023, I served the foregoing document(s): 7 1. DECLARATION OF CAROLINA RAMOS IN SUPPORT OF PLAINTIFF LISA KEITH’S 8 SUR-REPLY TO OPPOSITION TO DEFENDANTS VALLEY ROCK FOUNDATION’S AND DR. ROBERT WHITE’S NOTICE OF MOTION AND MOTION FOR ISSUE, 9 EVIDENCE, AND/OR TERMINATING SANCTIONS AGAINST PLAINTIFF LISA KEITH FOR VIOLATING COURT ORDER COMPELLING RESPONSES TO DISCOVERY 10 11 I served the documents on the person or persons listed below as follows: 12 Jeffrey E. Tsai Kathleen S. Kizer 13 DLA PIPER LLP (US) 555 Mission Street, Suite 2400 14 San Francisco, CA 94105 Jeff.tsai@us.dlapiper.com 15 Katy.kizer@us.dlapiper.com Attorneys for Defendants 16 [X] (BY EMAIL) Pursuant to Code of Civil Procedure section 1010.6, I caused the document(s) to 17 be electronically transmitted by me to the persons listed in the above email address(es). I did not receive 18 within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. 19 I declare under penalty of perjury under the laws of the State of California that the foregoing is 20 true and correct. 21 Executed on November 2, 2023, at Antioch, California. 22 23 Carolina Ramos 24 4893-4976-0652, v. 3 25 26 27 28 4 DECLARATION OF CAROLINA RAMOS IN SUPPORT OF PLAINTIFF’S SUR-REPLY TO OPPOSITION f