On January 25, 2019 a
Motion-Secondary
was filed
involving a dispute between
California Fire Protection Coalition,
Del Toro Trejo, Juan Carlos,
Filed By: Fire Guard Corporation,
Fire Guard Corporation,
Shahangian, Bahman Brian,
and
California Department Of Forestry And Fire Protection,
California Office Of The State Fire Marshal,
Dennis Mathisen In His Official Capacity As State Fire Marshal,
Does 1-10,
Jeffery Schwartz In His Official Capacity As Deputy State Fire Marshall,
Mike Richwine In His Official Capacity As State Fire Marshal,
for (Civil Rights/Discrimination)
in the District Court of Sacramento County.
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1 TIMOTHY V. KASSOUNL SBN 142907
KASSOUNI LAW FlLED/EMI ED
2 455 Capitol Mall, Suite 604
Sacramento, CA 95814
3
Telephone: (916)930-0030
. SEP .2-7 2022
4 Facsimile: (916)930-0033 By:. E. Macdonald
E-Mail: Timothy@Kassounilaw.com Deputy Clerk
5
6 Attorneys for Plaintiffs
FIRE GUARD CORPORATION, BAHMAN BRIAN
7 SHAHANGIAN. and JUAN CARLOS DEL TORO TREJO
8
SUPERIOR COURT OF THE STATE OF CALIFORNIA
9
CITY AND COUNTY OF SACRAMENTO
10
m
O FIRE GUARD CORPORATION; Case No: 34-2019-00249221-CU-CR-GDS
O
O
11 BAHMAN BRIAN SHAHANGIAN, an
m
O-, individual; and CALIFORND\ FIRE
12 PROTECTION COALITION, a Califomia
«-i Ov DECLARATION OF TIMOTHY V.
< 1/3
a, •—' 13 Corporafion; and JUAN CARLOS DEL
KASSOUNI SUPPORT OF
C9 TORO TREJO, an mdividual,
^ 2_ OPPOSITION TO DEFENDANTS'
o 14
O o MOTION FOR SUMMARY
Plaintiffs, ADJUDICATION
< o o 15
CO
in OS.
16 V.
Co
OS
Date: October 11,2022
lU
17 CALIFORNIA DEPARTMENT OF Time: 1:30 p.m.
FORESTRY AND FIRE PROTECTION; Dept.: 53
18 CALIFORNIA OFFICE OF THE STATE Trial Date: December 5, 2022
FIRE MARSHAL; DENNIS MATfflSEN, in
19
his official capacity as State Fire Marshal;
20 JEFFERY SCHWARTZ, in his official
caipacity as Deputy State Fire Marshall; and
21 and DOES 1 -10, inclusive.
22 Defendants.
23
24
25
26
27
28
DECLARATION OF TIMOTHY V. KASSOUNI SUPPORT OF OPPOSITION
TO DEFENDANTS' MOTION FOR SUMMARY ADJUDICATION
FILED BY FAX
1 1. I am over 18 years old and competent to testif>' as to the facts set forth in this
2. declaration. I am coimsel for Plainfiffs Fire Guard Corp., Bahman Brian Shahangian, and Juan
3
Carlos Del Toro Trejo. 1 have personal knowledge of the facts stated herein and i f called and
4
swom, I could and woiild testify' to the following facts of my own personal knowledge.
5
2. Attached to Plaintiffs' Exhibits at Exhibit 1 is a true and correct copy of portions
6
7 of die National Fire Protection study entitled "U.S. Experience With Sprinklers;" This document
8 was provided to me by Defendants as part of the initial mle making file.
9 3. Attached to Plaintiffs' Exhibits at Exhibit 2 is a true and correct copy of the first
ro
O 10
O
I
page of "Update of Initial Statement of Reasons" prepared by Defendant Office of the State Fue
o
ro
Ov
.-^
n
— VO Marshal . This document was provided to me by Defendants as part of the rule making file.
CO —
^ *^ I/O ov
Ov
12
< 00
< 'i 13 I declare under penalty of perjur>' under the laws of the State of Califomia that the
:3 o- •
o o
00 .ti
14 foregoing:is true and correct. . ,
c/^
^— a
a. fc o
Document Filed Date
September 27, 2022
Case Filing Date
January 25, 2019
Category
(Civil Rights/Discrimination)
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1 TIMOTHY V. KASSOUNL SBN 142907 KASSOUNI LAW FlLED/EMI ED 2 455 Capitol Mall, Suite 604 Sacramento, CA 95814 3 Telephone: (916)930-0030 . SEP .2-7 2022 4 Facsimile: (916)930-0033 By:. E. Macdonald E-Mail: Timothy@Kassounilaw.com Deputy Clerk 5 6 Attorneys for Plaintiffs FIRE GUARD CORPORATION, BAHMAN BRIAN 7 SHAHANGIAN. and JUAN CARLOS DEL TORO TREJO 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 CITY AND COUNTY OF SACRAMENTO 10 m O FIRE GUARD CORPORATION; Case No: 34-2019-00249221-CU-CR-GDS O O 11 BAHMAN BRIAN SHAHANGIAN, an m O-, individual; and CALIFORND\ FIRE 12 PROTECTION COALITION, a Califomia «-i Ov DECLARATION OF TIMOTHY V. < 1/3 a, •—' 13 Corporafion; and JUAN CARLOS DEL KASSOUNI SUPPORT OF C9 TORO TREJO, an mdividual, ^ 2_ OPPOSITION TO DEFENDANTS' o 14 O o MOTION FOR SUMMARY Plaintiffs, ADJUDICATION < o o 15 CO in OS. 16 V. Co OS Date: October 11,2022 lU 17 CALIFORNIA DEPARTMENT OF Time: 1:30 p.m. FORESTRY AND FIRE PROTECTION; Dept.: 53 18 CALIFORNIA OFFICE OF THE STATE Trial Date: December 5, 2022 FIRE MARSHAL; DENNIS MATfflSEN, in 19 his official capacity as State Fire Marshal; 20 JEFFERY SCHWARTZ, in his official caipacity as Deputy State Fire Marshall; and 21 and DOES 1 -10, inclusive. 22 Defendants. 23 24 25 26 27 28 DECLARATION OF TIMOTHY V. KASSOUNI SUPPORT OF OPPOSITION TO DEFENDANTS' MOTION FOR SUMMARY ADJUDICATION FILED BY FAX 1 1. I am over 18 years old and competent to testif>' as to the facts set forth in this 2. declaration. I am coimsel for Plainfiffs Fire Guard Corp., Bahman Brian Shahangian, and Juan 3 Carlos Del Toro Trejo. 1 have personal knowledge of the facts stated herein and i f called and 4 swom, I could and woiild testify' to the following facts of my own personal knowledge. 5 2. Attached to Plaintiffs' Exhibits at Exhibit 1 is a true and correct copy of portions 6 7 of die National Fire Protection study entitled "U.S. Experience With Sprinklers;" This document 8 was provided to me by Defendants as part of the initial mle making file. 9 3. Attached to Plaintiffs' Exhibits at Exhibit 2 is a true and correct copy of the first ro O 10 O I page of "Update of Initial Statement of Reasons" prepared by Defendant Office of the State Fue o ro Ov .-^ n — VO Marshal . This document was provided to me by Defendants as part of the rule making file. CO — ^ *^ I/O ov Ov 12 < 00 < 'i 13 I declare under penalty of perjur>' under the laws of the State of Califomia that the :3 o- • o o 00 .ti 14 foregoing:is true and correct. . , c/^ ^— a a. fc o