Motion-Secondary: *MF* Frias -v- Himnel USA Incorporated et al Print

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                                Elyza   P. Heraldez, Esq. (State   Bar N0. 293395)
     HERALDEZ LAW PC                                                                 ELECTRONICALLY FILED (Auto
                                                                                                              )

     8280 Aspen Street, Suite 120                                                    SUPERIOR COURT OF CALIFO RNIA
     Rancho Cucamonga, CA 91730                                                      COUNTY OF SAN BERNARDINC
     Office: (909) 942—9992                                                           3/1 5/2024 4:41 PM
     Email: Elyza.Heraldez@Heraldezlaw.com

     Attorneys for   Plaintiff,
     NORMA FRIAS



                                  SUPERIOR COURT OF THE STATE OF CALIFORNIA

                                     FOR THE COUNTY OF SAN BERNARDINO
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11   NORMA FRIAS,                                         CASE NO.: CIVSB2314042
12                    Plaintiff,                          Assigned t0 Hon. Michael A. Sachs, Dept. $28

13            VS.                                         SUPPLEMENTAL DECLARATION OF ELYZA P.
                                                          HERALDEZ IN SUPPORT OF PLAINTIFF’S
14   HIMNEL USA INCORPORATED, a                           REPLY TO DEFENDANT HIMNEL USA
     California Corporation, HIMNEL USA                   INCORPORATED’S OPPOSITION TO
15   INCORPORATED DBA ST. MARY’S                          PLAINTIFF’S MOTION TO COMPEL FURTHER
     MONTESSORI SCHOOL, a California                      RESPONSES TO EMPLOYMENT FORM
16   Corporation, and DOES 1-20, Inclusive,               INTERROGATORIES, SET ONE AND REQUEST
                                                          FOR PRODUCTION OF DOCUMENTS, SET ONE
17                    Defendants.

18                                                        Hearing Date: March 22, 2024
                                                          Time: 8:30 am.
19                                                        Location: Department $28


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                                                          Complaint filed: June 21, 2023
21                                                        Discovery Cutoff: None Set
                                                          Trail Date:   None   Set
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       SUPPLEMENTAL DECLARATION OF ELYZA P. HERALDEZ IN SUPPORT OF PLAINTIFF’S
       REPLY TO DEFENDANT HIMNEL USA INCORPORATED’S OPPOSITION TO PLAINTIFF’S
              MOTION TO COMPEL FURTHER RESPONSES TO EMPLOYMENT FORM
       INTERROGATORIES, SET ONE AND REQUEST FOR PRODUCTION OF DOCUMENTS, SET
                                        ONE
                                           DECLARATION OF ELYZA P. HERALDEZ
               I,   Elyza Heraldez, declare as follows:

               1.        I   am attorney licensed t0 practice      law    in the state   0f California. Ihave personal knowledge

     0f the   facts set forth herein,      and   if called as a Witness, I    could and would competently testify thereto.

               2.        I   make     this declaration in support     0f     Norma   Frias’s (“Plaintiff”)          Reply (“Reply”) To

     Defendant Himnel           USA      Incorporated’s Opposition (“Opposition”)               T0    Plaintiff s   Motion T0 Compel

     Further Responses          To Employment Form            Interrogatories, Set        One And Request For Production Of

     Documents, Set One (“Motion”).

               3.        I   made    clear t0 Defendants’ counsel that Plaintiffwas not           opposed t0 a stipulated protective

10   order.   A true and correct copy ofmy e-mail t0 opposing counsel on December 29, 2023, is attached hereto
11   as Exhibit “D”.


12             4.        A true and correct copy 0f the e-mail           I   sent opposing counsel       0n March        15, 2024,    with the

13   proposed stipulated protective order and stipulation t0 take the instant Motion off calendar                               is    attached

14   hereto as Exhibit “E”.

15             5.        A true and correct copy of the proposed stipulated protective order attached to my e-mail
16   sent to opposing counsel           on March    15, 2024, is attached hereto as        Exhibit “F”.

17             6.        A true and correct copy of the proposed stipulation to take the instant Motion off calendar
18   attached to     my e—mail       sent to opposing counsel    on March 15,2024,         is   attached hereto as Exhibit “G”.

19             7.        Unfortunately, as 0f the time of filing the instant Reply,                I   have not received any response

20   t0    my e-mail   sent   0n March     15, 2024.


21             8.        A true and correct copy 0f Plaintiff’s Employment Form Interrogatoreis, Set                          1, is   attached

22   hereto as Exhibit “H”.

23             9.        A    true    and correct copy of Defendant’s response                  t0    Plaintiff’s   Employment Form

24   Interrogatoreis, Set       1, is   attached hereto as Exhibit “I”.

25             10.       A true and correct copy of Plaintiff’ s Requests for Production,                  Set   1, is   attached hereto as

26   Exhibit “J”.

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           SUPPLEMENTAL DECLARATION OF ELYZA P. HERALDEZ IN SUPPORT OF PLAINTIFF’S
           REPLY TO DEFENDANT HIMNEL USA INCORPORATED’S OPPOSITION TO PLAINTIFF’S
                  MOTION TO COMPEL FURTHER RESPONSES TO EMPLOYMENT FORM
           INTERROGATORIES, SET ONE AND REQUEST FOR PRODUCTION OF DOCUMENTS, SET
                                            ONE