DECLARATION OF ERIN M KELLY IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES GENERAL AND REQUEST FOR 3750 IN MONETARY SANCTIONS AGAINST BLUE NOTE THERAPEUTICS AND ITS COUNSEL GORDON REES SCULLY MANSUKHANI (TRANSACTION ID # 100217383) FILED BY PLAINTIFF CHAVAREE, LAURA

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On April 25, 2023 a wrongful discharge case was filed by Chavaree, Laura, represented by Abrams, Courtney, and Friedman, Andrew H., against Blue Note Telehealth, Inc., A Corporation, Blue Note Therapeutics, Inc., A Corporation, Does 1 Through 50, Inclusive et al. represented by Dulloo, Waseem H., and Fairbrother, Melissa M, in the jurisdiction of San Francisco County. Judge RICHARD B. ULMER presiding.

                        
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                           1   Helmer • Friedman, LLP                                            DISCOVERY
     Andrew H. Friedman (SBN 153166)
 2   afriedman@helmerfriedman.com
                                                                                 ELECTRONICALLY
     Erin M. Kelly, Esq. (SBN 308309)
 3   ekelly@helmerfriedman.com                                                       FILED
     9301 Wilshire Blvd., Suite 609                                              Superior Court of California,
                                                                                  County of San Francisco
 4   Beverly Hills, California 90210
     Tel: (310) 396-7714                                                             10/26/2023
 5   Fax: (310) 396-9215                                                         Clerk of the Court
                                                                                    BY: SANDRA SCHIRO
                                                                      …