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1 XAVIER BECERRA
Attorney General of California
2 PETER D. HALLORAN
8/30/2019
Supervising Deputy Attorney General
3 JERRY J. DESCHLER
Deputy Attorney General
4 State Bar No. 215691
1300 I Street, Suite 125
5 P.O. Box 944255
Sacramento, CA 94244-2550
6 Telephone: (916) 210-7871
Fax: (916) 324-5567
7 E-mail: Jerry.Deschler@doj.ca.gov
Attorneys for Defendants
8 Board of Trustees of the California State University,
which is the State of California acting in its higher
9 education capacity (erroneously sued as "Trustees
of the California State University, State of
10 Cal/fornia"), Cynthia Daley, and Debra Larson
11 SUPERIOR COURT OF THE STATE OF CALIFORNIA
12 COUNTY OF BUTTE
13 CIVIL DIVISION
14
15
TERESA RANDOLPH, Case No. 19CV01226
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Plaintiff, SUPPLEMENTAL DECLARATION OF
17 JERRY J. DESCHLER IN SUPPORT OF
v. DEFENDANTS' DEMURRER TO FIRST
18 AMENDED COMPLAINT
19 TRUSTEES OF THE CALIFORNIA Date: S,eptember 11, 2019
STATE UNIVERSITY, STATE OF Time: 9:00 a.m.
20 CALIFORNIA, AND CYNTHIA DALEY, Dept: 10
AN INDIVIDUAL, AND DEBRA LARSON, Judge: Robert A. Glusman
21 AN INDIVIDUAL, Trial Date: none
Action Filed: April 24, 2019
22 Defendants.
23
24 I, Jerry Deschler, declare:
25 1. I am an attorney licensed to practice in all of the courts of the State of California, and
26 am a Deputy Attorney General with the California Department of Justice, Office of the Attorney
27 General, attorneys for Defendants Board of Trustees of the California State University, which is
28 the State of California acting in its higher education capacity (erroneously sued as "Trustees of
1
Supplemental Declaration Of Jerry J. Deschler In Support Of Defendants' Demurrer to First Amended Complaint
(19CV01226)
1 the California State University, State of California"), Cynthia Daley, and Debra Larson
2 ( collectively " Defendants"). The following statements are based upon my personal knowledge,
3 and if called upon to testify thereto, I could and would competently do so.
4 2. Plaintiff Teresa Randolph' s ("Randolph") opposition to Defendants' demurrer was
5 due August 28, 2019. On August 29, 2019, I obtained a copy of Randolph's opposition from the
6 Court's website. In a previous telephone conversation with Randolph's counsel, Thomas Dimitre,
7 I informed Mr. Dimitre that my clients preferred to stipulate to electronic service, and I asked him
8 wither he would stipulate to electronic service in this case. He agreed. Again, however, Mr.
9 Dimitre did not serve a copy of Randolph' s opposition by electronic means. Instead, according to
10 the Certificate of Service attached to the copy from the Court' s website, he allegedly served the
11 opposition via U.S. mail. As of August 30, 2019, I still had not received a copy.
12 Executed this 30th day of August, 2019, in Sacramento, California.
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SA2019102196
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Supplemental Declaratio n Of Jerry J. Deschler In Support Of Defendants' Demurrer to First Amended Complaint
(19CV01226)
DECLARATION OF SERVICE BY E-MAIL and OVERNIGHT COURIER
Case Name: Teresa Randolph v. Trustees of the California State University, et al.
Case No .: 19CV01226
I declare:
I am employed in the Office of the Attorney General, which is the office of a member of the
California State Bar, at which member's direction this service is made. I am 18 years of age or
older and not a party to this matter; my business address is: 1300 I Street, Suite 125, P.O. Box
944255, Sacramento, CA 94244-2550. I am familiar with the business practice at the Office of
the Attorney General for collection and processing of correspondence for overnight mail with the
FEDERAL EXPRESS. In accordance with that practice, correspondence placed in the internal
mail collection system at the Office of the Attorney General is deposited with the overnight
courier that same day in the ordinary course of business.
On August 30, 2019, I served the attached SUPPLEMENTAL DECLARATION OF JERRY
J. DESCHLER IN SUPPORT OF DEFENDANTS' DEMURRER TO FIRST AMENDED
COMPLAINT by transmitting a true copy via electronic mail. In addition, I placed a true copy
thereof enclosed in a sealed envelope, in the internal mail system of the Office of the Attorney
General, for overnight delivery, addressed as follows:
Thomas Dimitre
PO Box 801
Ashland, OR 97520
E-mail Address: dimitre@mind.net
I declare under penalty of perjury under the laws of the State of California the foregoing is true
and correct and that this declaration was executed on August 3 2019, at Sacramento,
California.
Michele Warburton
Declarant Signature
SA2019102196
14063057 .docx
Preview
1 XAVIER BECERRA Attorney General of California 2 PETER D. HALLORAN 8/30/2019 Supervising Deputy Attorney General 3 JERRY J. DESCHLER Deputy Attorney General 4 State Bar No. 215691 1300 I Street, Suite 125 5 P.O. Box 944255 Sacramento, CA 94244-2550 6 Telephone: (916) 210-7871 Fax: (916) 324-5567 7 E-mail: Jerry.Deschler@doj.ca.gov Attorneys for Defendants 8 Board of Trustees of the California State University, which is the State of California acting in its higher 9 education capacity (erroneously sued as "Trustees of the California State University, State of 10 Cal/fornia"), Cynthia Daley, and Debra Larson 11 SUPERIOR COURT OF THE STATE OF CALIFORNIA 12 COUNTY OF BUTTE 13 CIVIL DIVISION 14 15 TERESA RANDOLPH, Case No. 19CV01226 16 Plaintiff, SUPPLEMENTAL DECLARATION OF 17 JERRY J. DESCHLER IN SUPPORT OF v. DEFENDANTS' DEMURRER TO FIRST 18 AMENDED COMPLAINT 19 TRUSTEES OF THE CALIFORNIA Date: S,eptember 11, 2019 STATE UNIVERSITY, STATE OF Time: 9:00 a.m. 20 CALIFORNIA, AND CYNTHIA DALEY, Dept: 10 AN INDIVIDUAL, AND DEBRA LARSON, Judge: Robert A. Glusman 21 AN INDIVIDUAL, Trial Date: none Action Filed: April 24, 2019 22 Defendants. 23 24 I, Jerry Deschler, declare: 25 1. I am an attorney licensed to practice in all of the courts of the State of California, and 26 am a Deputy Attorney General with the California Department of Justice, Office of the Attorney 27 General, attorneys for Defendants Board of Trustees of the California State University, which is 28 the State of California acting in its higher education capacity (erroneously sued as "Trustees of 1 Supplemental Declaration Of Jerry J. Deschler In Support Of Defendants' Demurrer to First Amended Complaint (19CV01226) 1 the California State University, State of California"), Cynthia Daley, and Debra Larson 2 ( collectively " Defendants"). The following statements are based upon my personal knowledge, 3 and if called upon to testify thereto, I could and would competently do so. 4 2. Plaintiff Teresa Randolph' s ("Randolph") opposition to Defendants' demurrer was 5 due August 28, 2019. On August 29, 2019, I obtained a copy of Randolph's opposition from the 6 Court's website. In a previous telephone conversation with Randolph's counsel, Thomas Dimitre, 7 I informed Mr. Dimitre that my clients preferred to stipulate to electronic service, and I asked him 8 wither he would stipulate to electronic service in this case. He agreed. Again, however, Mr. 9 Dimitre did not serve a copy of Randolph' s opposition by electronic means. Instead, according to 10 the Certificate of Service attached to the copy from the Court' s website, he allegedly served the 11 opposition via U.S. mail. As of August 30, 2019, I still had not received a copy. 12 Executed this 30th day of August, 2019, in Sacramento, California. 13 14 15 16 SA2019102196 17 14061060.docx 18 19 20 21 22 23 24 25 26 27 28 2 Supplemental Declaratio n Of Jerry J. Deschler In Support Of Defendants' Demurrer to First Amended Complaint (19CV01226) DECLARATION OF SERVICE BY E-MAIL and OVERNIGHT COURIER Case Name: Teresa Randolph v. Trustees of the California State University, et al. Case No .: 19CV01226 I declare: I am employed in the Office of the Attorney General, which is the office of a member of the California State Bar, at which member's direction this service is made. I am 18 years of age or older and not a party to this matter; my business address is: 1300 I Street, Suite 125, P.O. Box 944255, Sacramento, CA 94244-2550. I am familiar with the business practice at the Office of the Attorney General for collection and processing of correspondence for overnight mail with the FEDERAL EXPRESS. In accordance with that practice, correspondence placed in the internal mail collection system at the Office of the Attorney General is deposited with the overnight courier that same day in the ordinary course of business. On August 30, 2019, I served the attached SUPPLEMENTAL DECLARATION OF JERRY J. DESCHLER IN SUPPORT OF DEFENDANTS' DEMURRER TO FIRST AMENDED COMPLAINT by transmitting a true copy via electronic mail. In addition, I placed a true copy thereof enclosed in a sealed envelope, in the internal mail system of the Office of the Attorney General, for overnight delivery, addressed as follows: Thomas Dimitre PO Box 801 Ashland, OR 97520 E-mail Address: dimitre@mind.net I declare under penalty of perjury under the laws of the State of California the foregoing is true and correct and that this declaration was executed on August 3 2019, at Sacramento, California. Michele Warburton Declarant Signature SA2019102196 14063057 .docx