On April 17, 2018 a
Motion-Secondary
was filed
involving a dispute between
Trujillo, Bryan,
Trujillo, Cindy,
and
Does 1-20,
Does 1-50,
Magee, Stephen,
Sac Aero Flying Club, Inc.,
for (23) Unlimited Other PI/PD/WD
in the District Court of San Mateo County.
Preview
Electlmnitally
Eunmm Eu: Hufimmcmnq H 5m
Hg.-
cm 1 1/22/201 9
By 1::annually”—
Demand:
MICHAEL S. DANKO, ESQ. SBN 111359
mdanko@dankolaw.com
SHAWN R. MILLER, ESQ. SBN 238447
smiller@dankolaw.com
DANKO MEREDITH
333 Twin Dolphin Drive, Suite 145
Redwood Shores, CA 94065
Telephone: (650) 453-3600
Facsimile: (650) 394-8672
Attorneys for Plaintiffs
BRYAN TRUJILLO and CINDY TRUJILLO
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN MATEO
10 UNLIMITED CIVIL JURISDICTION
11 BRYAN TRUJILLO and CINDY TRUJILLO, Case No. 18CIV01901
12 Plaintiffs, DECLARATION OF DANIEL DUNN IN
SUPPORT OF PLAINTIFFS’
13 V. OPPOSITION TO DEFENDANTS
STEPHEN MAGEE’S AND AERO
14 STEPHEN MAGEE, SAC AERO FLYING FLYING CLUB, INC.’S DISCOVERY
CLUB, INC., AND DOES 1 -
50, MOTIONS REGARDING CINDY
15 TRUJILLO.
Defendants
16
17 Date: December 9, 2019
Time: 9:00 am.
18 Dept: Law and Motion
19 Complaint filed: April 17, 2018
Trial Date: February 10, 2020
20
21
22 I, Daniel Dunn, declare as follows:
23 1. I am employed by Danko Meredith as an Office Assistant. Ihave personal knowledge
24 0f the following facts, and if called upon to d0 so, could and would testify competently therein.
25 2. Part 0f my regular, daily job duties at Danko Meredith includes processing the mail.
26 Processing the mail consists 0f opening, scanning, and then electronically and physically
27 distributing all case-related incoming mail.
28 -1-
DECLARATION OF DANIEL DUNN IN SUPPORT OF PLAINTIFFS’ OPPOSITION TO
DEFENDANTS STEPHEN MAGEE’S AND AERO FLYING CLUB, INC.’S DISCOVERY
MOTIONS REGARDING CINDY TRUJILLO.
3. On Friday, August 9, 2019, I opened the mail. There was an envelope from Michaelis,
Montanari & Johnson in the mail delivery. Iremoved the contents of the envelope, scanned,
AWN saved, and emailed the entire contents of the envelope that was delivered. A true and correct
copy 0f the email that I drafted and sent to Claire Choo, among others, with the scanned copies
of the discovery that was received is attached hereto as Exhibit A.
4. There were four separate discovery documents included in the envelope I opened on
August
KOOOQQUI 9, 2019. Each of the discovely documents received was directed to Plaintiff Bryan
Trujillo. The contents of the envelope included:
a. Requests for Production, Set N0. Three to Plaintiff Bryan Trujillo;
10 b. Special Interrogatories Propounded to Plaintiff Bryan Trujillo, Set No. One;
11 c. Requests for Admissions, Set No. One, Propounded to Bryan Trujillo; and
12 d. Form Interrogatories- General Set No. Two to Bryan Trujillo.
13 5. Ihave no recollection of opening mail in August 2019 containing discovery propounded
14 solely to Plaintiff Cindy ijillo.
15
16 Ideclare under penalty of perjury under the laws of the State 0f California that the
17 foregoing istrue and correct.
18 Executed this 22nd of November 2019 atRedwood Shores, California.
19
20
<94
Daniel Dunfi
$\—
V
21
22
23
24
25
26
27
28 -2-
DECLARATION OF DANIEL DUNN IN SUPPORT OF PLAINTIFFS’ OPPOSITION TO
DEFENDANTS STEPHEN MAGEE’S AND AERO FLYING CLUB, INC.’S DISCOVERY
MOTIONS REGARDING CINDY TRUJILLO.
EXHIBIT A
Daniel Dunn
From: Daniel Dunn
Sent: Friday,August O9, 2019 11:43 AM
To: Mike Danko; Kristine Meredith; Claire Y. Choo; Paula Welch
Subject: RE Discoveries in the Trujillo Case
Attachments: RFA—l Magee to TrujilloB.pdf; RPD—3 Magee to TrujilloB.pdf; SROG—l Magee to TrujilloB.pdf;
FROG-2 Magee to TrujilloB.pdf
M-Files->Truji||o->Discovery->RFA—1 Magee to Trujillo B
M-Files->Truji||o->Discovery->RPD-3 to Trujillo B
M-Files->Truji||o->Discovery->SROG-1 Magee to Trujillo B
M-Files->Truji||o->Discovery->FROG-2 Magee to Trujillo B
Document Filed Date
November 22, 2019
Case Filing Date
April 17, 2018
Category
(23) Unlimited Other PI/PD/WD
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Electlmnitally Eunmm Eu: Hufimmcmnq H 5m Hg.- cm 1 1/22/201 9 By 1::annually”— Demand: MICHAEL S. DANKO, ESQ. SBN 111359 mdanko@dankolaw.com SHAWN R. MILLER, ESQ. SBN 238447 smiller@dankolaw.com DANKO MEREDITH 333 Twin Dolphin Drive, Suite 145 Redwood Shores, CA 94065 Telephone: (650) 453-3600 Facsimile: (650) 394-8672 Attorneys for Plaintiffs BRYAN TRUJILLO and CINDY TRUJILLO SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN MATEO 10 UNLIMITED CIVIL JURISDICTION 11 BRYAN TRUJILLO and CINDY TRUJILLO, Case No. 18CIV01901 12 Plaintiffs, DECLARATION OF DANIEL DUNN IN SUPPORT OF PLAINTIFFS’ 13 V. OPPOSITION TO DEFENDANTS STEPHEN MAGEE’S AND AERO 14 STEPHEN MAGEE, SAC AERO FLYING FLYING CLUB, INC.’S DISCOVERY CLUB, INC., AND DOES 1 - 50, MOTIONS REGARDING CINDY 15 TRUJILLO. Defendants 16 17 Date: December 9, 2019 Time: 9:00 am. 18 Dept: Law and Motion 19 Complaint filed: April 17, 2018 Trial Date: February 10, 2020 20 21 22 I, Daniel Dunn, declare as follows: 23 1. I am employed by Danko Meredith as an Office Assistant. Ihave personal knowledge 24 0f the following facts, and if called upon to d0 so, could and would testify competently therein. 25 2. Part 0f my regular, daily job duties at Danko Meredith includes processing the mail. 26 Processing the mail consists 0f opening, scanning, and then electronically and physically 27 distributing all case-related incoming mail. 28 -1- DECLARATION OF DANIEL DUNN IN SUPPORT OF PLAINTIFFS’ OPPOSITION TO DEFENDANTS STEPHEN MAGEE’S AND AERO FLYING CLUB, INC.’S DISCOVERY MOTIONS REGARDING CINDY TRUJILLO. 3. On Friday, August 9, 2019, I opened the mail. There was an envelope from Michaelis, Montanari & Johnson in the mail delivery. Iremoved the contents of the envelope, scanned, AWN saved, and emailed the entire contents of the envelope that was delivered. A true and correct copy 0f the email that I drafted and sent to Claire Choo, among others, with the scanned copies of the discovery that was received is attached hereto as Exhibit A. 4. There were four separate discovery documents included in the envelope I opened on August KOOOQQUI 9, 2019. Each of the discovely documents received was directed to Plaintiff Bryan Trujillo. The contents of the envelope included: a. Requests for Production, Set N0. Three to Plaintiff Bryan Trujillo; 10 b. Special Interrogatories Propounded to Plaintiff Bryan Trujillo, Set No. One; 11 c. Requests for Admissions, Set No. One, Propounded to Bryan Trujillo; and 12 d. Form Interrogatories- General Set No. Two to Bryan Trujillo. 13 5. Ihave no recollection of opening mail in August 2019 containing discovery propounded 14 solely to Plaintiff Cindy ijillo. 15 16 Ideclare under penalty of perjury under the laws of the State 0f California that the 17 foregoing istrue and correct. 18 Executed this 22nd of November 2019 atRedwood Shores, California. 19 20 <94 Daniel Dunfi $\— V 21 22 23 24 25 26 27 28 -2- DECLARATION OF DANIEL DUNN IN SUPPORT OF PLAINTIFFS’ OPPOSITION TO DEFENDANTS STEPHEN MAGEE’S AND AERO FLYING CLUB, INC.’S DISCOVERY MOTIONS REGARDING CINDY TRUJILLO. EXHIBIT A Daniel Dunn From: Daniel Dunn Sent: Friday,August O9, 2019 11:43 AM To: Mike Danko; Kristine Meredith; Claire Y. Choo; Paula Welch Subject: RE Discoveries in the Trujillo Case Attachments: RFA—l Magee to TrujilloB.pdf; RPD—3 Magee to TrujilloB.pdf; SROG—l Magee to TrujilloB.pdf; FROG-2 Magee to TrujilloB.pdf M-Files->Truji||o->Discovery->RFA—1 Magee to Trujillo B M-Files->Truji||o->Discovery->RPD-3 to Trujillo B M-Files->Truji||o->Discovery->SROG-1 Magee to Trujillo B M-Files->Truji||o->Discovery->FROG-2 Magee to Trujillo B