On January 04, 2022 a
Party Statement
was filed
involving a dispute between
Richard Bozner, Candyce E. Bozner As Trustees Of The Bozner Family Trust Dated December 16, 1991,
and
Does 1 Through 100,
Lilia Navarro, As Trustee Of The Navarro Trust Dated May 1, 2007,
Luis Navarro, As Trustee Of The Navarro Trust Dated May 1, 2007,
for Other Real Property Unlimited
in the District Court of San Bernardino County.
Preview
ELECTRONICALLY FILED
SUPERIOR COURT OF CALIFORNIA
Thomas N. Jacobson, State Bar N5127 COUNTY OF SAN BERNARDINO
I LAW OFFICES OF THOMAS N. JACOBSON SAN BERNARDINO DISTRICT
1650 Iowa Ave., Suite 190
Riverside, CA 92507 1/2/2024 3:47 PM
T: (9511 682-7882
F: (951) 682-7884 By: Abrianna Rodriguez, DEPUTY
tom@tomjacobsonlaw.corn
4
Attorneys For Defendants, Richard
And Candyce Bozner
SUPERIOR COURT OP CALIPORNIA
7 COUNTY OP SAN BERNARDINO — SAN BERNAR9INO DISTRICT
9 RICElARD BOZNER, CANDYCE E. ) CASE NO. CIVSB 2200084
BOZNER as TRIJSTEES OF THE BQZNER )
FAMILY TRYUST DATED DECEMBER 16 9ECLARATION OP JIMMY 9
1991, WILLIAMS
11
Plaintii'fs,
12
vs,
13
LUIS NAVARRO, LILIA NAVARRO AS
14 TRUSTEES OF THE NAVARRO TRUST
DATED MAY 1, 2007, and DOES 1-100,
inclusive
16 Defendants.
18 I, Jimmy D. Williams, declare as follows:
19 1. I afn a surveyor licensed by the State of California. If called upon to testify I would
20 testify as set forth herein. All of the matters set forth herein are within my personal lotowledge
21 and experience.
22 2. I prepared the elevation survey attached as Exhibit "A". This was prepared in response to
23 a request from the Bozners that I establish the elevations of various portions of their property
24 with regard to the adjacent property I have learned is owned by Mr. and Mrs. Navarro.
25 3. I have considerable experience with regard to the issue between the Bozner property and
26 the Navarro property. I have performed a survey of the boundary line between the properties and
27 marked the property for the fence that has been installed by Mr. Navarro. Throughout my work
7, ON 0750 N
f05070
faaal aa
aA,SNtalaa
Raa«s, CA07507
- I-
DECLARATION OF JIMMY D. WILLIAMS
1 with the patties I have endeavored to perform my work with objectivity and not to favor a party
2 with any of the work I have performed.
4. The attached document (Exhibit "A") establishes the low point of the fence line between
4 the Navarro property and the Bozner property. The low point of the boundary between the two
5 properties is approximately half way along the property line.
5. I have observed the low point is an area wherein water from the Navarro property appears
7 to enter the Bozner property from two sources: (1) a swale on a concrete slap that directs the
8 water from the Navarro property to the Bozner property, and (2) a French Drain and drainage
9 pipe that has its low point at the site the low point between the two properties.
10 6. It is quite evident from anyone standing near the propetty line and observing the low
11 point where the swale and drains are located that water exits the Navarro property and flows onto
12 the Bozner property because of the way the swale was constructed and because the drain from
13 other sources reaches a low point at the point where both the drain and swale have deposited
14 water onto the Bozner property.
I declare under penalty of perjury under the laws of the State of California the foregoing
16
is tfue and correct.
Executed this ado day of December 2023 at Grand Terrace, California.
19 Jimmy D. Wthams~
20
21
22
23
24
26
1 1110 *fflaassN
10 ofoa0,0odof00
0 as do,f001107
-2-
DECI ARATION OP JIMMY B. WII I IAMS
Document Filed Date
January 02, 2024
Case Filing Date
January 04, 2022
Category
Other Real Property Unlimited
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Preview
ELECTRONICALLY FILED SUPERIOR COURT OF CALIFORNIA Thomas N. Jacobson, State Bar N5127 COUNTY OF SAN BERNARDINO I LAW OFFICES OF THOMAS N. JACOBSON SAN BERNARDINO DISTRICT 1650 Iowa Ave., Suite 190 Riverside, CA 92507 1/2/2024 3:47 PM T: (9511 682-7882 F: (951) 682-7884 By: Abrianna Rodriguez, DEPUTY tom@tomjacobsonlaw.corn 4 Attorneys For Defendants, Richard And Candyce Bozner SUPERIOR COURT OP CALIPORNIA 7 COUNTY OP SAN BERNARDINO — SAN BERNAR9INO DISTRICT 9 RICElARD BOZNER, CANDYCE E. ) CASE NO. CIVSB 2200084 BOZNER as TRIJSTEES OF THE BQZNER ) FAMILY TRYUST DATED DECEMBER 16 9ECLARATION OP JIMMY 9 1991, WILLIAMS 11 Plaintii'fs, 12 vs, 13 LUIS NAVARRO, LILIA NAVARRO AS 14 TRUSTEES OF THE NAVARRO TRUST DATED MAY 1, 2007, and DOES 1-100, inclusive 16 Defendants. 18 I, Jimmy D. Williams, declare as follows: 19 1. I afn a surveyor licensed by the State of California. If called upon to testify I would 20 testify as set forth herein. All of the matters set forth herein are within my personal lotowledge 21 and experience. 22 2. I prepared the elevation survey attached as Exhibit "A". This was prepared in response to 23 a request from the Bozners that I establish the elevations of various portions of their property 24 with regard to the adjacent property I have learned is owned by Mr. and Mrs. Navarro. 25 3. I have considerable experience with regard to the issue between the Bozner property and 26 the Navarro property. I have performed a survey of the boundary line between the properties and 27 marked the property for the fence that has been installed by Mr. Navarro. Throughout my work 7, ON 0750 N f05070 faaal aa aA,SNtalaa Raa«s, CA07507 - I- DECLARATION OF JIMMY D. WILLIAMS 1 with the patties I have endeavored to perform my work with objectivity and not to favor a party 2 with any of the work I have performed. 4. The attached document (Exhibit "A") establishes the low point of the fence line between 4 the Navarro property and the Bozner property. The low point of the boundary between the two 5 properties is approximately half way along the property line. 5. I have observed the low point is an area wherein water from the Navarro property appears 7 to enter the Bozner property from two sources: (1) a swale on a concrete slap that directs the 8 water from the Navarro property to the Bozner property, and (2) a French Drain and drainage 9 pipe that has its low point at the site the low point between the two properties. 10 6. It is quite evident from anyone standing near the propetty line and observing the low 11 point where the swale and drains are located that water exits the Navarro property and flows onto 12 the Bozner property because of the way the swale was constructed and because the drain from 13 other sources reaches a low point at the point where both the drain and swale have deposited 14 water onto the Bozner property. I declare under penalty of perjury under the laws of the State of California the foregoing 16 is tfue and correct. Executed this ado day of December 2023 at Grand Terrace, California. 19 Jimmy D. Wthams~ 20 21 22 23 24 26 1 1110 *fflaassN 10 ofoa0,0odof00 0 as do,f001107 -2- DECI ARATION OP JIMMY B. WII I IAMS