Party Discovery: *MF* Frias -v- Himnel USA Incorporated et al Print

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                                Elyza P. Heraldez, Esq. (State Bar No. 293395)
     HERALDEZ LAW PC
     7349 Milliken Avenue, Ste. 1404
     Rancho Cucamonga, CA 91730                                 ELECTRONICALLY FILED
     Office: (909) 942-9992                                      SUPERIOR COURT OF CALIFORNIA
     Email: Elyza.Heraldez@Heraldezlaw.com
                                                                COUNTY OF SAN BERNARDINO
                                                                SAN BERNARDINO DISTRICT
     Attorneys for   Plaintiff,                                 12/4/2023 4:07     PM
     YESENIA ROBLES
                                                                By:   Jasmine Bolanos,   DEPUTY




                                  SUPERIOR COURT OF THE STATE OF CALIFORNIA

                                     FOR THE COUNTY OF SAN BERNARDINO
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11   YESENIA ROBLES,                                  CASE NO.: CIVSB2314929
12                    Plaintiff,                      [Assigned for   all   purposes t0 the Hon. Michael A.
                                                      Sachs, Dpt. $28]
13          vs.
                                                      DECLARATION OF ELYZA P. HERALDEZ IN
14   HIMNEL USA INCORPORATED, a                       SUPPORT OF PLAINTIFF’S COMPEL
     California Corporation, HIMNEL USA               FURTHER RESPONSES TO EMPLOYMENT
15   INCORPORATED DBA ST. MARY’S                      FORM INTERROGATORIES, SET ONE AND
     MONTESSORI SCHOOL, a California                  REQUEST FOR PRODUCTION OF
16   Corporation, and DOES 1-20, Inclusive,           DOCUMENTS, SET ONE
17                    Defendants.                     [Filed concurrently With Plaintiff s Notice of Motion
                                                      And Motion to Compel Further Responses         t0
18                                                    Employment Form                     One And
                                                                              Interrogatories, Set
                                                      Request For Production Of Documents, Set One
19                                                    Separate Statement; and [proposed] Order on Motion to
                                                      Compel Further Discovery Responses; and Separate
20                                                    Statement]


21                                                    Hearing Date: February 14, 2024
                                                      Time: 8:30 am.
22                                                    Location: Department $28


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                                                      Complaint filed: July 5, 2023
24                                                    Discovery Cutoff: None Set
                                                      Trail Date:   None    Set
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        DECLARATION OF ELYZA P. HERALDEZ IN SUPPORT OF 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 to 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         of Yesenia Robles’s (“Plaintiff”) Motion t0 Compel

     Further Responses to                 Employment Form           Interrogatories,          Set        One and Request For Production 0f

     Documents, Set One (“Motion”), brought against Himnel                                 USA          Incorporated dba   St.   Mary’s Montessori

     School’s (“Defendant”).

                  3.        A true       and correct copy 0f the relevant portion 0f Defendant’s Surveillance Camera and

10   Audio Recording produced                 in response to a request for personnel records is attached hereto as                         Exhibit

11   “A.”

12                4.        A true and correct copy 0f the relevant portion of Defendant’s Use 0f Company Property
13   Policy produced in response to a request for personnel records                             is      attached hereto as Exhibit “B.”

14                5.        On     or about September 21, 2023,         I   sent counsel for Defendant,              Dusty Knapp and       J.   Jason

15   Hill a detailed correspondence addressing the deficiencies in Defendant’s responses to Plaintiff‘s


16   Employment Form Interrogatories,                  Set   One and Plaintiff” s Request for Production of Documents,                    Set One.

17   A true and correct copy of the meet and confer correspondence                                  I   sent to Defendant’s counsel    0n 0r about

18   September 21, 2023             is   attached hereto as Exhibit “C.”

19                Ihereby declare under penalty ofperjury under the laws 0fthe State 0f California that the foregoing

20   is   true   and    correct.


21                Executed      this 14th   day 0f November 2023            at   Rancho Cucamonga,              California.


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                                                                      _féjl%     Elyza P. Heraldez

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        DECLARATION OF ELYZA P. HERALDEZ IN SUPPORT OF PLAINTIFF’S MOTION TO
      COMPEL FURTHER RESPONSES TO EMPLOYMENT FORM INTERROGATORIES, SET ONE;
                AND REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE