On April 19, 2019 a
Motion-Secondary
was filed
involving a dispute between
Randolph, Teresa,
and
Daley, Cynthia,
Larson, Debra,
State Of California,
Trustees Of The California State University,
for (36) Unlimited Wrongful Termination
in the District Court of Butte County.
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1 Thomas Dimitre SBN 276924
Thomas Dimitre Attorney at Law LLC
2 PO Box 801 11/6/2019
Ashland, OR 97520
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Tel: 541 890 5022
4 Fax: 541 488 4601
Email: dimitre@mind.net
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IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
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FOR THE COUNTY OF BUTTE
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TERESA RANDOLPH, Case No. 19CV01226
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13 Plaintiff
SWORN DECLARATION OF THOMAS
14 v. DIMITRE IN SUPPORT OF MOTION TO
15 COMPEL AND MOTION FOR
ATTORNEY’S FEES.
16 TRUSTEES OF THE CALIFORNIA
STATE UNIVERSITY, STATE OF
17 CALIFORNIA, CYNTHIA DALEY, AND
DEBRA LARSON
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19 Defendants
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I, Thomas Dimitre, resident and am employed in Oregon, declare and state as follows:
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1. I am the Plaintiff’s attorney in this case.
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4 2. I am personally aware of all of the facts, and am competent to testify about each fact as
5 set forth in this declaration. All of my statements are based on my personal knowledge.
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I am competent to testify to these facts.
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3. I have spent 23 hours of time responding to Defendant’s lack of response to Plaintiff’s
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First Request for Production of Documents. I charge $300 per hour.
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10 4. I spent at least three hours on the phone with Defendants’ counsel on meet and confer
11 regarding the motion to compel, and at least 20 additional hours responding to
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Defendants’ lack of response and production of documents in this case.
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5. I swear, under the penalty of perjury, under the laws of the State of California, that
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the foregoing is true and correct.
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16 s/s Thomas Dimitre
____________________ Date: November 5, 2019
17 Thomas Dimitre
Attorney for Plaintiff
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Teresa Randolph
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Document Filed Date
November 06, 2019
Case Filing Date
April 19, 2019
Category
(36) Unlimited Wrongful Termination
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1 Thomas Dimitre SBN 276924 Thomas Dimitre Attorney at Law LLC 2 PO Box 801 11/6/2019 Ashland, OR 97520 3 Tel: 541 890 5022 4 Fax: 541 488 4601 Email: dimitre@mind.net 5 6 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 7 FOR THE COUNTY OF BUTTE 8 9 10 11 TERESA RANDOLPH, Case No. 19CV01226 12 13 Plaintiff SWORN DECLARATION OF THOMAS 14 v. DIMITRE IN SUPPORT OF MOTION TO 15 COMPEL AND MOTION FOR ATTORNEY’S FEES. 16 TRUSTEES OF THE CALIFORNIA STATE UNIVERSITY, STATE OF 17 CALIFORNIA, CYNTHIA DALEY, AND DEBRA LARSON 18 19 Defendants 20 21 22 23 24 25 26 27 28 1 1 I, Thomas Dimitre, resident and am employed in Oregon, declare and state as follows: 2 1. I am the Plaintiff’s attorney in this case. 3 4 2. I am personally aware of all of the facts, and am competent to testify about each fact as 5 set forth in this declaration. All of my statements are based on my personal knowledge. 6 I am competent to testify to these facts. 7 3. I have spent 23 hours of time responding to Defendant’s lack of response to Plaintiff’s 8 First Request for Production of Documents. I charge $300 per hour. 9 10 4. I spent at least three hours on the phone with Defendants’ counsel on meet and confer 11 regarding the motion to compel, and at least 20 additional hours responding to 12 Defendants’ lack of response and production of documents in this case. 13 5. I swear, under the penalty of perjury, under the laws of the State of California, that 14 the foregoing is true and correct. 15 16 s/s Thomas Dimitre ____________________ Date: November 5, 2019 17 Thomas Dimitre Attorney for Plaintiff 18 Teresa Randolph 19 20 21 22 23 24 25 26 27 28 2