Motion,Ex Parte: Rodriguez et al -v - General Motors, LLC et al Print

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                                                           ORIGTNAL                             x.



                  Mary Arcns McBride,        Esq.   (SBN 282459)
                  Alexandria O. Pappas. Esq.        (SBN 326149)
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                  ERSKINE      LAW GROUP, APC                                                                                 3\
                  1592 N. Batavia    St..   Suite   1A
                  Orange,    CA  92867
AX                Tel: (949)   777-6032
                  Fax: (714) 844-9035
BYF               marensmcbride@erskinelaw.com
                  apappas@crskinclaw.c0m
       \Omflamhw
                  Attorneys for Defendant,
                  GENERAL MOTORS LLC


                                      SUPERIOR COURT OF THE STATE OF CALIFORNIA

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                                              FOR THE COUNTY OF SAN BERNARDINO

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      12          MANUEL RODRIGUEZ                  and   LUCIA DE LA Case               No.:   CIV832228894
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                  ROSA DAVILA,
                                                                          DECLARATION OF ALEXANDRIA O.
      l4                               Plaintiffs,                        PAPPAS IN SUPPORT OF GENERAL
                                                                          MOTORS LLC’S DEMURRER AND
      15                                                                  MOTION TO STRIKE PUNITIVE
                                                                          DAMAGES AS TO PLAINTIFFS’ FIRST
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                                                                          AMENDED COMPLAINT
                  GENERAL MOTORS              LLC,; and     DOES   l

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                  through 10, inclusive,
                                                                          Filed concurrently with       Demurrer, Motion to
      18                                                                  Strike           Punitive Damages, and Proposed

                                       Defendants.
                                                                          Order
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                                                                          Case       Initiated:       December   30,   2022
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      21                                                                  Assigned          to the   Honorable Winston Keh
                                                                          Department S-33
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                                                                          Date: October              4,   2023
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                                                                          Time: 8:30 AM.
      24                                                                  Department: S33

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      27                                     DECLARATION OF ALEXANDRIA O. PAPPAS
      28          I,   Alexandria O. Pappas, declare as follows:
                                                                       PAGE   l   0F 4
                       DECLARATION OF ALEXANDRIA O PAPPAS IN SUPPORT OF GENERAL MOTORS LLC’S DEMURRER
                               AND MOTION TO STRIKE AS TO PLAINTIFFS‘ FIRST AMENDED COMPLAINT
              l.          I    am   an attorney    at   law licensed      to practice before all courts           0f the State of

     California, and an attorney with thc law                 firm of Erskine Law Group, APC,                 counsel of record for

     General Motors           LLC (“GM").       defendant in this      litigation.   This declaration   is   submitted    in   suppon

     0f   GM‘s Dcmurrcr and Motion               to Strike relating to Plaintiffs‘ First         Amended Complaint.              I   am

     familiar with the records         and pleadings on file        in this action      and ifcalled as a witness,     I   could and

     would competently              testify to the matters       set    forth below.      Matters outside of         my    personal

     knowledge arc based upon information and                   belief.


             2.           Prior to filing      GM‘s Demurrer and Motion               to Strike. this   office attempted to meet

     and confer tclcphonically with             Plaintiffs’   counsel     in   an attempt to discuss the issues      we had      with

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     Plaintiffs’ First        Amended Complaint,        but unfortunately, were unsuccessful in our attempts.

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             I     declare under penalty of perjury under the laws of the State of Califomia that the

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     foregoing     is   true   and correct.

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             Executed on August            7,   2023, in Orange, California.

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                                                                                   Alexandria O. Pappas. Esq.
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                                                                                   Counsel for General Motors         LLC
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                                                                PAGE    2 0F 4
      DECLARATION OE ALEXANDRIA O PAPPAS 1N SUPPORT OF GENERAL MOTORS LLC‘S DEMURRER
               AND MOTION TO STRIKE AS TO PLAINTIFFS’ FIRST AMENDED COMPLAINT