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OFFICES OF‘
LAw
WALKUP, MELODIA, KELLY £1 SCHOENBERGER
A PROFESSIONAL CORPORATION
F I L E
AT’En (SnUNw
D
SAN AA \
650 CALIFORNIA STREET, 26‘“
FLOOR
gmN
SAN FRANCISCO, CALIFORNIA 94108-2615 ‘ DEC 3 l 2019
981-721 0
T: (41 5) -
391 —6965
F: (41 5)
MATTHEW D. DAVIS (State Bar #141986)
mdavis@walkuplawoffice.com _ _fi
SPENCER J. PAHLKE (State Bar #250914) agiE‘illV-mm
s ahlke walku 1awoffice.com - -
‘°mm”
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\yALERCfia N. R15SE (State Bar #272566) $2333“
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ATTORNEYS FOR PLAINTIFFS
BRICEIDA LOPEZ AND JOSE SOLIS l llllilllHlllllIIININNHN
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 COUNTY OF SAN MATEO
11
12 BRICEIDA LOPEZ, an individual, JOSE Case No. 18CIV01696
SOLIS, an individual,
13 PLAINTIFFS’ OBJECTIONS TO
Plaintiffs, EVIDENCE SUBMITTED BY THE
14 AMERIGAS DEFENDANTS IN SUPPORT
v. OF THEIR MOTION FOR SUMMARY
15 JUDGEMENT 0R, IN THE
PAUL BONIFACIO, an individual, ALTERNATIVE, SUMMARY
16 MARGARET HYUN, an individual, ADJUDICATION
AMERIGAS PROPANE, L.P., a business
17 entity, AMERIGAS PROPANE, INC, a Date: 01/14/2020
corporation, AMERIGAS, INC., a corporation, Time: 9:00 a.m.
18 and DOES ONE through ONE-HUNDRED, Dept: Law and Motion
inclusive,
19 Action Filed: April 6, 2018
Defendants. Trial Date: February 18, 2020
20
21
22 Plaintiffs BRICEIDA LOPEZ and JOSE SOLIS respectfully submit the following
23 objections to evidence cited by Defendants AMERIGAS PROPANE, L.P., AMERIGAS
A8
24 PROPANE, INC., and AMERIGAS, INC. (collectively, the “AmeriGas Defendants” or
XV:|
25 “Defendants”), filed in support of Defendants’ motion for summary judgment or, alternatively,
26 summary adjudication.
27 ///
28 ///
LAW OFFICES or
WALKUP, MELonLA, KELLY
& SCHOENBERGER
A PROFESSIONAL CORPORATION
550 CALIFORNIA STREET 1
25m FLOOR
SAN FRANCISCO. CA 941 os
981-7210
(415)
PLAINTIFFS’ OBJECTIONS TO AMERIGAS DEFENDANTS’ EVIDENCE - CASE NO. 18CIV01696
OBJECTION No. 1
Material Objected To: Declaration of Christopher Wagner in Support of AmeriGas
DJ Defendants’ Motion for Surrimary Judgment or, in the Alternative, Summary Adjudication
(“Wagner Decl.”) at 1:12 (1}3): “AmeriGas, Inc. is the parent company of AmeriGas Propane,
Inc.”
Grognds for Objectiog N0. 1: Lack ofpersonal knowledge (Evid. Code, § 702, subd.
(a)); failure to set forth admissible evidence in a supporting declaration (Code Civ. Proc., § 437e,
\OOONQ
subd. (d)).
Explanation: Although the witness claims that the facts set forth in his declaration—
10 including those facts relating to the corporate structure and relationships between the AmeriGas
11 Defendants—are based on his “own personal knowledge,” his deposition testimony on August 6,
12 2019, just two and a half months before his declaration was executed, makes clear that he actually
13 has no idea how the various AmeriGas entities are related to one another.
14 Specifically, the witness testified that he works for AmeriGas Propane, L.P., and that at the
15 time of his deposition, he was the “Director of Compliance and Regulatory Affairs,” a titlehe has
16 held since July 1,2019. (08/06/19 Deposition of Christopher Wagner (“Wagner Depo.”) at 12:12—
17 22, attached as Exh. C to Plaintiffs’ Index of Evidence and Evidence in Opposition to the
18 AmeriGas Defendants’ Motion for Summary Judgment or, in the Alternative, Summary
19 Adjudication.) When asked whether he holds any job titles or positions with AmeriGas, Inc. (a
20 different AmeriGas entity), the witness replied:
21 There are multiple affiliations through the AmeriGas trade name, and I’d have to
have legal counsel specifically identify those different interactions and how those
22 names relate to one another. But I believe that all of the AmeriGas companies,
there is a portion of the company that’s affiliated with personnel, and then there are
23 others that are cross—affiliated through business—type relationships and legal
standards. But I’m not directly familiar with what all of those are.
24
2’5 (Id. at 15:10—22; see also id. at 16:13—17:4 [witness again explaining that “there are numerous
26 different affiliations of the AmeriGas name” and that he is “not directly familiar with their
27 association with the organization’fl.)
28 ///
LAW OFFICES OF
WALKUP, h(ELODIA, KELLY
SLSCHOENBERGER
ApnorzssmNAL CORPORATION
650 CALIFORNIA STREET 2
26TH FLOOR
SAN FRANCISCO. CA 94108
981 ~721 0
(41 5)
PLAINTIFFS’ OBJECTIONS TO ANIERIGAS DEFENDANTS’ EVIDENCE - CASE NO. 18CIV01696
Additionally, when the witness was asked to describe both his current and prior job duties
at AmeriGas Propane, L.P., his responses revealed that he is not currently doing nor has he ever
done any work that would expose him :[ofirst—hand knowledge of the corporate structure and
relationships between the various AmeriGas entities. (See Wagner Depo. at 14:13—15:9
[explaining that in his current position, he deals primarily with federal, state, and local codes and
standards, offering interpretations thereof and interacting with regulatory agencies to ensure
compliance therewith]; see also id.at 32:16—35:8 and Exhibit 98 thereto [explaining that
\OOOQON
previously, his role was to ensure that AmeriGas Propane, L.P., has an “effective safety training
program[]” so itsemployees can “understand and avoid the risks associated with theirjobs”].)
10 Against this backdrop, it isquite plain that the matter stated in paragraph 3 of the witness’s
11 declaration is not based on his personal knowledge. The statement is,therefore, inadmissible.
12 OBJECTION NO. 2
13 Material Obiected T0: Wagner Decl. at 1:13—15 (1f4): “AmeriGas Propane, Inc. is the
14 former general partner of AmeriGas Propane, L.P. As the result of a recent transaction unrelated
15 t0 this lawsuit, the current general partner of AmeriGas Propane, L.P. isnow non—party, AmeriGas
16 Propane GP, LLC, also a separate entity.”
17 Grounds for Obiection No. 2_: Lack 0f personal knowledge (Evid. Code, § 702, subd.
18 (a)); failure to set forth admissible evidence in a supporting declaration (Code Civ. Proc., § 437C,
19 subd. (d)).
20 Exglanation: As explained above (see Obj ection No. 1), although the witness claims that
21 the facts set forth in his declaration are based on his “own personal knowledge,” his deposition
22 testimony on August 6, 2019, makes clear that he actually has no idea how the various AmeriGas
23 entities are related to one another. (See Wagner Depo. at 12:12—22, 14:13—15:22, 16:13—17:4,
24 32: 1 6—35z8; see also Exhibit 98.) Thus, the statement in paragraph 4 of the witness’s declaration
25 is not based on his personal knowledge and consequently, it isinadmissible.
26 ///
27 ///
28 ///
LAW OFFICES OF
WALKUP, MELODIA, KELLY
SLSCHOENBERGER
A PROFISSIONAL CORPORATION
650 CALIFORNIA STREET 3
F00R
SAN FRANCISCO, CA 941 08
981-7210
(415)
PLAINTIFFS’ OBJECTIONS TO AMERIGAS DEFENDANTS’ EVIDENCE - CASE NO. 18CIV01696
OBJECTION N0. 3
Material Obiected To: Wagner Decl. at 1:18—19 (third sentence of 11 5): “It [referring to
#WN AmeriGas Propane, L.P.] isalso a subsidiary of AmeriGas Propane, Inc.”
Grognds for Obiection N0. 3: Lack of personal knowledge (Evid. Code, § 702, subd.
(a)); failure to set forth admissible evidence in a supporting declaration (Code Civ. Proc., § 437e,
subd. (d)).
\DWVQUI
Explanation: As explained above (see Objection No. 1), although the witness claims that
the facts set forth in his declaration are based on his “own personal knowledge,” his deposition
testimony on August 6, 2019, makes clear that he actually has no idea how the various AmeriGas
10 entities are related t0 one another. (See Wagner Depo. at 12:12—22, 14:13—15:22, 16:13—17z4,
11 32:16—35:8; see aIso Exhibit 98.) Thus, the statement in the third sentence ofparagraph 5 of the
12 witness’s declaration isnot based on his personal knowledge and consequently, it isinadmissible.
13 OBJECTION NO. 4
14 Material Obiected To: Wagner Decl. at 1:20—21 (fl 6): “Each of the aforementioned
15 AmeriGas Defendants is a separate corporate entity from one another, maintains their own
16 corporate records, finances, and separate assets and liabilities.”
17 Grounds for Obiection No. 4: Lack of personal knowledge (Evid. Code, § 702, subd.
18 (a)); secondary evidence rule (Evid. Code, § 1523); failure to set forth admissible evidence in a
19 supporting declaration (Code Civ. Proc., § 437C, subd. (d)).
20 Exglanation: As explained above (see Obj ection No. 1), although the witness claims that
21 the facts set forth in his declaration are based on his “own personal knowledge,” his deposition
22 testimony on August 6, 2019, makes clear that he actually has no idea how the various AmeriGas
23 entities are related to one another. (See Wagner Depo. at 12:12—22, 14:13—15:22, 16:13—1724,
24 32:16—35z8; see also Exhibit 98.) Thus, the statement in paragraph 6 of the witness’s declaration
25 is not based on his personal knowledge and consequently, it isinadmissible.
26 Moreover, oral testimony is inadmissible to prove the content of a writing unless the
27 proponent can show that one of the exceptions set forth in subdivisions (b), (c), or (d) of Evidence
28 Code section 1523 (hereafter, “section 1523”) applies. (Evid. Code, § 1523, subd. (a).) Thus, the
LAW OFFICLS 0r
WALKUP, Minoma, KELLY
SCHOB‘IBERGER
6L
A PROFESSIONAL CORPORATION
650 CALIFORNIA STREET 4
26TH FLOOR
SAN FRANCISCO, CA 94105
931-7210
(415)
PLAINTIFFS’ OBJECTIONS TO AMERIGAS DEFENDANTS’ EVIDENCE - CASE NO. 18CIV01696
witness’s statements regarding-the existence and contents ofthegAmeriGas entities’ corporate and
financial records are inadmissible urfleSS'Defendants. can show that, an exception applies.
Under subdivisions (b) and (c) of section 1523, oral testimony'is admissible if'the
proponent does not have possession or control offhe original or a copy of thewriting and one of
\ODOflQUI-PUJNy—t
several other conditions exists. Subdivision (d) of section 152.3 fec‘og‘nizes’ an exception ‘for
voluminous writings. Here,.Defendantisfhave. made no attempt t0 show that they d0 not possess or
control a copy (or the original) of their own corporateand financial records. Nor have Defendants
made any effort to showthat they cannot produce a copy of those records due 'to their size.
Instead, Defendants have simply failed t0 produce the documents they now wish to rely upon,
H o despite the presmnptive ease With which :such documents could have been produced. Thus, the
p—I
F" exceptions set fofih in subdivisions (b), (c), and (d) of Section 1523 do not apply, and any
N
1—-
testimony regarding the-existen'ce and terms of the purported comorate and financial records ofthe
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various AmeriGas entities is inadmissible;
p—-
-# Dated: December 31, 2019 ‘WALKUP, MELo 1A J SCHOENBERGER
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PLATNTIFFS’ OBJECTIONS TO‘ AMBRIGAS DEFENDANTS’ EVIDENCE- CASE ,NO. IBCIVO 1696
Preview
¥\J OFFICES OF‘ LAw WALKUP, MELODIA, KELLY £1 SCHOENBERGER A PROFESSIONAL CORPORATION F I L E AT’En (SnUNw D SAN AA \ 650 CALIFORNIA STREET, 26‘“ FLOOR gmN SAN FRANCISCO, CALIFORNIA 94108-2615 ‘ DEC 3 l 2019 981-721 0 T: (41 5) - 391 —6965 F: (41 5) MATTHEW D. DAVIS (State Bar #141986) mdavis@walkuplawoffice.com _ _fi SPENCER J. PAHLKE (State Bar #250914) agiE‘illV-mm s ahlke walku 1awoffice.com - - ‘°mm” . \yALERCfia N. R15SE (State Bar #272566) $2333“ \OOONONUI @ ATTORNEYS FOR PLAINTIFFS BRICEIDA LOPEZ AND JOSE SOLIS l llllilllHlllllIIININNHN SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF SAN MATEO 11 12 BRICEIDA LOPEZ, an individual, JOSE Case No. 18CIV01696 SOLIS, an individual, 13 PLAINTIFFS’ OBJECTIONS TO Plaintiffs, EVIDENCE SUBMITTED BY THE 14 AMERIGAS DEFENDANTS IN SUPPORT v. OF THEIR MOTION FOR SUMMARY 15 JUDGEMENT 0R, IN THE PAUL BONIFACIO, an individual, ALTERNATIVE, SUMMARY 16 MARGARET HYUN, an individual, ADJUDICATION AMERIGAS PROPANE, L.P., a business 17 entity, AMERIGAS PROPANE, INC, a Date: 01/14/2020 corporation, AMERIGAS, INC., a corporation, Time: 9:00 a.m. 18 and DOES ONE through ONE-HUNDRED, Dept: Law and Motion inclusive, 19 Action Filed: April 6, 2018 Defendants. Trial Date: February 18, 2020 20 21 22 Plaintiffs BRICEIDA LOPEZ and JOSE SOLIS respectfully submit the following 23 objections to evidence cited by Defendants AMERIGAS PROPANE, L.P., AMERIGAS A8 24 PROPANE, INC., and AMERIGAS, INC. (collectively, the “AmeriGas Defendants” or XV:| 25 “Defendants”), filed in support of Defendants’ motion for summary judgment or, alternatively, 26 summary adjudication. 27 /// 28 /// LAW OFFICES or WALKUP, MELonLA, KELLY & SCHOENBERGER A PROFESSIONAL CORPORATION 550 CALIFORNIA STREET 1 25m FLOOR SAN FRANCISCO. CA 941 os 981-7210 (415) PLAINTIFFS’ OBJECTIONS TO AMERIGAS DEFENDANTS’ EVIDENCE - CASE NO. 18CIV01696 OBJECTION No. 1 Material Objected To: Declaration of Christopher Wagner in Support of AmeriGas DJ Defendants’ Motion for Surrimary Judgment or, in the Alternative, Summary Adjudication (“Wagner Decl.”) at 1:12 (1}3): “AmeriGas, Inc. is the parent company of AmeriGas Propane, Inc.” Grognds for Objectiog N0. 1: Lack ofpersonal knowledge (Evid. Code, § 702, subd. (a)); failure to set forth admissible evidence in a supporting declaration (Code Civ. Proc., § 437e, \OOONQ subd. (d)). Explanation: Although the witness claims that the facts set forth in his declaration— 10 including those facts relating to the corporate structure and relationships between the AmeriGas 11 Defendants—are based on his “own personal knowledge,” his deposition testimony on August 6, 12 2019, just two and a half months before his declaration was executed, makes clear that he actually 13 has no idea how the various AmeriGas entities are related to one another. 14 Specifically, the witness testified that he works for AmeriGas Propane, L.P., and that at the 15 time of his deposition, he was the “Director of Compliance and Regulatory Affairs,” a titlehe has 16 held since July 1,2019. (08/06/19 Deposition of Christopher Wagner (“Wagner Depo.”) at 12:12— 17 22, attached as Exh. C to Plaintiffs’ Index of Evidence and Evidence in Opposition to the 18 AmeriGas Defendants’ Motion for Summary Judgment or, in the Alternative, Summary 19 Adjudication.) When asked whether he holds any job titles or positions with AmeriGas, Inc. (a 20 different AmeriGas entity), the witness replied: 21 There are multiple affiliations through the AmeriGas trade name, and I’d have to have legal counsel specifically identify those different interactions and how those 22 names relate to one another. But I believe that all of the AmeriGas companies, there is a portion of the company that’s affiliated with personnel, and then there are 23 others that are cross—affiliated through business—type relationships and legal standards. But I’m not directly familiar with what all of those are. 24 2’5 (Id. at 15:10—22; see also id. at 16:13—17:4 [witness again explaining that “there are numerous 26 different affiliations of the AmeriGas name” and that he is “not directly familiar with their 27 association with the organization’fl.) 28 /// LAW OFFICES OF WALKUP, h(ELODIA, KELLY SLSCHOENBERGER ApnorzssmNAL CORPORATION 650 CALIFORNIA STREET 2 26TH FLOOR SAN FRANCISCO. CA 94108 981 ~721 0 (41 5) PLAINTIFFS’ OBJECTIONS TO ANIERIGAS DEFENDANTS’ EVIDENCE - CASE NO. 18CIV01696 Additionally, when the witness was asked to describe both his current and prior job duties at AmeriGas Propane, L.P., his responses revealed that he is not currently doing nor has he ever done any work that would expose him :[ofirst—hand knowledge of the corporate structure and relationships between the various AmeriGas entities. (See Wagner Depo. at 14:13—15:9 [explaining that in his current position, he deals primarily with federal, state, and local codes and standards, offering interpretations thereof and interacting with regulatory agencies to ensure compliance therewith]; see also id.at 32:16—35:8 and Exhibit 98 thereto [explaining that \OOOQON previously, his role was to ensure that AmeriGas Propane, L.P., has an “effective safety training program[]” so itsemployees can “understand and avoid the risks associated with theirjobs”].) 10 Against this backdrop, it isquite plain that the matter stated in paragraph 3 of the witness’s 11 declaration is not based on his personal knowledge. The statement is,therefore, inadmissible. 12 OBJECTION NO. 2 13 Material Obiected T0: Wagner Decl. at 1:13—15 (1f4): “AmeriGas Propane, Inc. is the 14 former general partner of AmeriGas Propane, L.P. As the result of a recent transaction unrelated 15 t0 this lawsuit, the current general partner of AmeriGas Propane, L.P. isnow non—party, AmeriGas 16 Propane GP, LLC, also a separate entity.” 17 Grounds for Obiection No. 2_: Lack 0f personal knowledge (Evid. Code, § 702, subd. 18 (a)); failure to set forth admissible evidence in a supporting declaration (Code Civ. Proc., § 437C, 19 subd. (d)). 20 Exglanation: As explained above (see Obj ection No. 1), although the witness claims that 21 the facts set forth in his declaration are based on his “own personal knowledge,” his deposition 22 testimony on August 6, 2019, makes clear that he actually has no idea how the various AmeriGas 23 entities are related to one another. (See Wagner Depo. at 12:12—22, 14:13—15:22, 16:13—17:4, 24 32: 1 6—35z8; see also Exhibit 98.) Thus, the statement in paragraph 4 of the witness’s declaration 25 is not based on his personal knowledge and consequently, it isinadmissible. 26 /// 27 /// 28 /// LAW OFFICES OF WALKUP, MELODIA, KELLY SLSCHOENBERGER A PROFISSIONAL CORPORATION 650 CALIFORNIA STREET 3 F00R SAN FRANCISCO, CA 941 08 981-7210 (415) PLAINTIFFS’ OBJECTIONS TO AMERIGAS DEFENDANTS’ EVIDENCE - CASE NO. 18CIV01696 OBJECTION N0. 3 Material Obiected To: Wagner Decl. at 1:18—19 (third sentence of 11 5): “It [referring to #WN AmeriGas Propane, L.P.] isalso a subsidiary of AmeriGas Propane, Inc.” Grognds for Obiection N0. 3: Lack of personal knowledge (Evid. Code, § 702, subd. (a)); failure to set forth admissible evidence in a supporting declaration (Code Civ. Proc., § 437e, subd. (d)). \DWVQUI Explanation: As explained above (see Objection No. 1), although the witness claims that the facts set forth in his declaration are based on his “own personal knowledge,” his deposition testimony on August 6, 2019, makes clear that he actually has no idea how the various AmeriGas 10 entities are related t0 one another. (See Wagner Depo. at 12:12—22, 14:13—15:22, 16:13—17z4, 11 32:16—35:8; see aIso Exhibit 98.) Thus, the statement in the third sentence ofparagraph 5 of the 12 witness’s declaration isnot based on his personal knowledge and consequently, it isinadmissible. 13 OBJECTION NO. 4 14 Material Obiected To: Wagner Decl. at 1:20—21 (fl 6): “Each of the aforementioned 15 AmeriGas Defendants is a separate corporate entity from one another, maintains their own 16 corporate records, finances, and separate assets and liabilities.” 17 Grounds for Obiection No. 4: Lack of personal knowledge (Evid. Code, § 702, subd. 18 (a)); secondary evidence rule (Evid. Code, § 1523); failure to set forth admissible evidence in a 19 supporting declaration (Code Civ. Proc., § 437C, subd. (d)). 20 Exglanation: As explained above (see Obj ection No. 1), although the witness claims that 21 the facts set forth in his declaration are based on his “own personal knowledge,” his deposition 22 testimony on August 6, 2019, makes clear that he actually has no idea how the various AmeriGas 23 entities are related to one another. (See Wagner Depo. at 12:12—22, 14:13—15:22, 16:13—1724, 24 32:16—35z8; see also Exhibit 98.) Thus, the statement in paragraph 6 of the witness’s declaration 25 is not based on his personal knowledge and consequently, it isinadmissible. 26 Moreover, oral testimony is inadmissible to prove the content of a writing unless the 27 proponent can show that one of the exceptions set forth in subdivisions (b), (c), or (d) of Evidence 28 Code section 1523 (hereafter, “section 1523”) applies. (Evid. Code, § 1523, subd. (a).) Thus, the LAW OFFICLS 0r WALKUP, Minoma, KELLY SCHOB‘IBERGER 6L A PROFESSIONAL CORPORATION 650 CALIFORNIA STREET 4 26TH FLOOR SAN FRANCISCO, CA 94105 931-7210 (415) PLAINTIFFS’ OBJECTIONS TO AMERIGAS DEFENDANTS’ EVIDENCE - CASE NO. 18CIV01696 witness’s statements regarding-the existence and contents ofthegAmeriGas entities’ corporate and financial records are inadmissible urfleSS'Defendants. can show that, an exception applies. Under subdivisions (b) and (c) of section 1523, oral testimony'is admissible if'the proponent does not have possession or control offhe original or a copy of thewriting and one of \ODOflQUI-PUJNy—t several other conditions exists. Subdivision (d) of section 152.3 fec‘og‘nizes’ an exception ‘for voluminous writings. Here,.Defendantisfhave. made no attempt t0 show that they d0 not possess or control a copy (or the original) of their own corporateand financial records. Nor have Defendants made any effort to showthat they cannot produce a copy of those records due 'to their size. Instead, Defendants have simply failed t0 produce the documents they now wish to rely upon, H o despite the presmnptive ease With which :such documents could have been produced. Thus, the p—I F" exceptions set fofih in subdivisions (b), (c), and (d) of Section 1523 do not apply, and any N 1—- testimony regarding the-existen'ce and terms of the purported comorate and financial records ofthe U) i—n various AmeriGas entities is inadmissible; p—- -# Dated: December 31, 2019 ‘WALKUP, MELo 1A J SCHOENBERGER k)! rad ON )—-A V u—A 00 r-—- MATltHEv's‘fD. SPENCER J VALERIE N. ROSE DAVIS PAHLKE .. V Attorneys for Plaintiffs \9 i-d BRICEIDALQPEZ AND JOSE SOLIS O [\J N) H NN U3. {\J N —P¢ U’l [\J N ON N \J 28 LAW OFFICES 0F WALKUI’, MELODIA, I&LLY Sn SCHOENBERGER Ammisswm cokmu (cm 650 CALIFORNIA STREET 5 26TH FLOOR SAN FRANUSCO. CA BMDB (415) 981nm“) PLATNTIFFS’ OBJECTIONS TO‘ AMBRIGAS DEFENDANTS’ EVIDENCE- CASE ,NO. IBCIVO 1696