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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 LISA KEITH IN
13 SUPPORT OF PLAINTIFF’S (1) EX
v. PARTE MOTION TO CONTINUE
14 HEARING ON DEFENDANTS’
CELESTE WHITE, an individual, ROBERT MOTION FOR SUMMARY
15 WHITE, an individual, the VALLEY ROCK JUDGMENT/ ADJUDICATION
FOUNDATION, aka THE BAR 49
16 FOUNDATION, a charitable organization, and
17 DOES 1-50, INCLUSIVE,
18 Defendants. Date: February 6, 2024
Time: 11:30 a.m.
19 Judge: Hon. Scott R.L. Young
Dept.: B
20 Complaint Filed: October 25, 2022
21 FAC Filed: March 8, 2023
Trial Date: April 2, 2024
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23 I, Lisa Keith, declare and state as follows:
24 1. I am the Plaintiff in the above-referenced matter and have personal knowledge of the facts
25 contained in this declaration, and if called as a witness would competently testify thereto.
26 2. My attorneys have been attempting to serve subpoenas for production of records on
27 Singer Associates, Inc. since September 13, 2023.
28 3. To my knowledge, the Defendants hired Singer Associates Inc. to issue press releases in
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DECLARATION OF LISA KEITH IN SUPPORT OF OPPOSITION TO DEFENDANTS MOTION TO EXTEND DEADLINE
1 violation of the non-disparagement clause in our Settlement Agreement from a previous trust action.
2 4. On January 29, 2024, I was informed by my counsel that Singer Associates, Inc. had
3 failed to produce the records that I have requested in my subpoena.
4 5. Without the document production from Singer Associates, Inc., I am unable to determine
5 the facts as it relates to the Defendants’ hiring of Singer Associates, Inc. and their involvement in issuing
6 the press releases that is the subject of this litigation. I believe the subpoena production is crucial to my
7 opposition and without this I do not have a fair opportunity to oppose the Defendants’ motion for
8 summary judgment.
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10 I declare under penalty of perjury under the laws of the state of California that the foregoing is
11 true and correct.
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15 Dated: February 1, 2024
Plaintiff, Lisa Keith
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DECLARATION OF LISA KEITH IN SUPPORT OF OPPOSITION TO DEFENDANTS MOTION TO EXTEND DEADLINE
1 PROOF OF SERVICE
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STATE OF CALIFORNIA, CITY AND COUNTY OF SAN FRANCISCO
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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.
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On February 5, 2024, I served the foregoing document(s):
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1. DECLARATION OF LISA KEITH IN SUPPORT OF PLAINTIFF'S EX PARTE
8 TO CONTINUE HEARING ON DEFENDANTS' MOTION FOR SUMARY
JUDGMENT/ADJUDICATION
9 I served the documents on the person or persons listed below as follows:
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11 Jeffrey E. Tsai
Kathleen S. Kizer
12 DLA PIPER LLP (US)
555 Mission Street, Suite 2400
13 San Francisco, CA 94105
Jeff.tsai@us.dlapiper.com
14 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
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
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transmission was unsuccessful.
18 I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct.
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Executed on February 5, 2024, at San Francisco, California.
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21 Carolina Ramos
4865-9241-5394, v. 3
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DECLARATION OF LISA KEITH IN SUPPORT OF OPPOSITION TO DEFENDANTS MOTION TO EXTEND DEADLINE
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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 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 LISA KEITH IN 13 SUPPORT OF PLAINTIFF’S (1) EX v. PARTE MOTION TO CONTINUE 14 HEARING ON DEFENDANTS’ CELESTE WHITE, an individual, ROBERT MOTION FOR SUMMARY 15 WHITE, an individual, the VALLEY ROCK JUDGMENT/ ADJUDICATION FOUNDATION, aka THE BAR 49 16 FOUNDATION, a charitable organization, and 17 DOES 1-50, INCLUSIVE, 18 Defendants. Date: February 6, 2024 Time: 11:30 a.m. 19 Judge: Hon. Scott R.L. Young Dept.: B 20 Complaint Filed: October 25, 2022 21 FAC Filed: March 8, 2023 Trial Date: April 2, 2024 22 23 I, Lisa Keith, declare and state as follows: 24 1. I am the Plaintiff in the above-referenced matter and have personal knowledge of the facts 25 contained in this declaration, and if called as a witness would competently testify thereto. 26 2. My attorneys have been attempting to serve subpoenas for production of records on 27 Singer Associates, Inc. since September 13, 2023. 28 3. To my knowledge, the Defendants hired Singer Associates Inc. to issue press releases in 1 DECLARATION OF LISA KEITH IN SUPPORT OF OPPOSITION TO DEFENDANTS MOTION TO EXTEND DEADLINE 1 violation of the non-disparagement clause in our Settlement Agreement from a previous trust action. 2 4. On January 29, 2024, I was informed by my counsel that Singer Associates, Inc. had 3 failed to produce the records that I have requested in my subpoena. 4 5. Without the document production from Singer Associates, Inc., I am unable to determine 5 the facts as it relates to the Defendants’ hiring of Singer Associates, Inc. and their involvement in issuing 6 the press releases that is the subject of this litigation. I believe the subpoena production is crucial to my 7 opposition and without this I do not have a fair opportunity to oppose the Defendants’ motion for 8 summary judgment. 9 10 I declare under penalty of perjury under the laws of the state of California that the foregoing is 11 true and correct. 12 13 14 15 Dated: February 1, 2024 Plaintiff, Lisa Keith 16 17 18 19 20 21 22 23 24 25 26 27 28 2 DECLARATION OF LISA KEITH IN SUPPORT OF OPPOSITION TO DEFENDANTS MOTION TO EXTEND DEADLINE 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 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 February 5, 2024, I served the foregoing document(s): 7 1. DECLARATION OF LISA KEITH IN SUPPORT OF PLAINTIFF'S EX PARTE 8 TO CONTINUE HEARING ON DEFENDANTS' MOTION FOR SUMARY JUDGMENT/ADJUDICATION 9 I served the documents on the person or persons listed below as follows: 10 11 Jeffrey E. Tsai Kathleen S. Kizer 12 DLA PIPER LLP (US) 555 Mission Street, Suite 2400 13 San Francisco, CA 94105 Jeff.tsai@us.dlapiper.com 14 Katy.kizer@us.dlapiper.com Attorneys for Defendants 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 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 19 Executed on February 5, 2024, at San Francisco, California. 20 21 Carolina Ramos 4865-9241-5394, v. 3 22 23 24 25 26 27 28 3 DECLARATION OF LISA KEITH IN SUPPORT OF OPPOSITION TO DEFENDANTS MOTION TO EXTEND DEADLINE