On May 07, 2019 a
Party Discovery
was filed
involving a dispute between
Bertrand, David G,
Churchill-Johnson, Dorothy,
and
Berry, Jessica,
for Unlimited Defamation (13)
in the District Court of Santa Barbara County.
Preview
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JESSICA BERRY - DEC 20.2019
Box 541' " "' '
P.O.
AM
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Darrel E. Par r.éxecutlve Officer .
Santa Ynez, California 93460 BY
Tel:,(650) 515-0161 .
I?noontmaa. Deputy
e-mail: iceskateordie@gmail.com ,
\DOOQONUIAOJN
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SANTA BARBARA-ANACAPA DIVISION
K
DAVID BERTAND, An Individual; CASE #: 19CV02429
DOROTHY CHURCHILL-
JOHNSON, an individual, DEFENDANT’S OPPOSITION
TO PLAINTIFF’S MOTION FOR
Plaintiffs, MONETARY SAN CTIONS
vs. & DEFENDANT’S OPPOSITION
TO PLAINTIFF’S REQUEST
JESSICA BERRY, Aii Individual, FOR ADMISSIONS DEEMED AS
and DOES 1 through 100, inclusive, ADMITTED
Defendant Assigned to: Honorable Judge
Sterne ‘
NNNNNNN'NNr—ti—i—y—ii—ti—Ai—ii—I—Ai—t
TO ALL PARTIES AND THEIR COUNSEL OF RECORD: JESSICA BERRY DOES
HEREBY 'OPPOSE
“\IONUIAMNHOVPOOQ_G\UIIAOJNHG
PLAINTIFF’S MOTION AS FOLLOWS:
1. I,JESSICA BERRY, have provided the Plaintiffs, David G. Bertrand and
Dorothy Churchill:Johnson, with my RESPONSES TOPLAINTIFF.’ S REQUESTS
FOR ADMISSIONS, SET 1; and the service of my responses was made upon their
counsel Mark Coffin on December 3, 2019.
2. ~
All of my responses to Plaintiff s Form Interrogatories, Special Interrogatories,-
and document production requests, were similarly served upon their counsel Mark
Coffin on December 20, 2019.
3. I have no money or ability to pay for sanctions, also no financing which might
have provided that I could hire legal representation for myself on this matter;
Page 1of2
possibly those things wouldihave allowed a more timely delivery of all discovery
1
responses.
2
3 It is intention to and forthcoming on all issues regarding
4. my sincere be cooperative
4 this case. It was never my intention to ignore or abuse the discovery process.
5 .
MY PRAYER TO THE COURT:
6
7 I REQUEST THAT THE COURT PROVIDE FORGIVENESS IN THIS INSTAN CE
DUE TO MY SPECIAL CIRCUMSTANCES.
8
, 9
I, JESSICA BERRY, do hereby declare that the above information is true and
10 correct, and that this declaration is being submitted for review to the Santa Barbara
Superior Court, Anacapa Division, and for review by the Honorable Judge Colleen K.
11
Sterne.
12
‘13
14 ,
15 ficv oww .2 -
lP/Ka/I‘l
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. Case #. C/Jeésica‘Berry, Defendant// Date
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Page 2of2
)—I
PROOF OF SERVICE BY MAIL
2 STATE OF CALIFORNIA, COUNTY OF SANTA BARBARA
3 David Bertrand v. Jessica Berrv
4 Santa Barbara Superior Court, Anacapa Divison, Case No.: 19CV02429
5 I am employed in the County of Santa Barbara, State of California. I am over
6
the age of 18 and not a party to the within action; my business address is 418 E.
Canon Perdido St., Santa Barbara, California 93101.
7
On December 20, 2019 I served the parties in this action the foregoing documents:
8
9 DEFENDANT’S OPPOSITION MOTION FOR MONETARY SAN CTIONS &_
OPPOSITION TO PLAINTIFF’S REQUEST FOR ADMISSIONS DEEMED AS
10 ADMITTED
11
XXX By placing true copies thereof enclosed in a sealed envelope with First Class
12 Postage fully paid and addressed as follows:
13
Mark T. Coffin, Esq,
14 21 E. Carrillo Street, Suite 240
Santa Barbara, ‘
CA 93101
15 . .
16
I am "readily familiar" with the firm's practice of collection and processing
17 correspondence for mailing. Under that practice it would be deposited with the U. S.
Postal Service on that same day with postage thereon fully prepaid at Santa
18
Barbara, California in the ordinary course of business. I am aware that on motion Of ~
19 the party served, service is presumed invalid if postal cancellation date or postage
meter date is more than one day after date of deposit for mailing.
20
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Executed on December 20, 2019 at Santa Barbara, California.
22 I declare under penalty of perjury under the laws of the State of California that
the above is true and correct.
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NM
Document Filed Date
December 20, 2019
Case Filing Date
May 07, 2019
Category
Unlimited Defamation (13)
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I L “flfifi‘vfifim SM???" E D ' . ’ H JESSICA BERRY - DEC 20.2019 Box 541' " "' ' P.O. AM ' Darrel E. Par r.éxecutlve Officer . Santa Ynez, California 93460 BY Tel:,(650) 515-0161 . I?noontmaa. Deputy e-mail: iceskateordie@gmail.com , \DOOQONUIAOJN SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA BARBARA-ANACAPA DIVISION K DAVID BERTAND, An Individual; CASE #: 19CV02429 DOROTHY CHURCHILL- JOHNSON, an individual, DEFENDANT’S OPPOSITION TO PLAINTIFF’S MOTION FOR Plaintiffs, MONETARY SAN CTIONS vs. & DEFENDANT’S OPPOSITION TO PLAINTIFF’S REQUEST JESSICA BERRY, Aii Individual, FOR ADMISSIONS DEEMED AS and DOES 1 through 100, inclusive, ADMITTED Defendant Assigned to: Honorable Judge Sterne ‘ NNNNNNN'NNr—ti—i—y—ii—ti—Ai—ii—I—Ai—t TO ALL PARTIES AND THEIR COUNSEL OF RECORD: JESSICA BERRY DOES HEREBY 'OPPOSE “\IONUIAMNHOVPOOQ_G\UIIAOJNHG PLAINTIFF’S MOTION AS FOLLOWS: 1. I,JESSICA BERRY, have provided the Plaintiffs, David G. Bertrand and Dorothy Churchill:Johnson, with my RESPONSES TOPLAINTIFF.’ S REQUESTS FOR ADMISSIONS, SET 1; and the service of my responses was made upon their counsel Mark Coffin on December 3, 2019. 2. ~ All of my responses to Plaintiff s Form Interrogatories, Special Interrogatories,- and document production requests, were similarly served upon their counsel Mark Coffin on December 20, 2019. 3. I have no money or ability to pay for sanctions, also no financing which might have provided that I could hire legal representation for myself on this matter; Page 1of2 possibly those things wouldihave allowed a more timely delivery of all discovery 1 responses. 2 3 It is intention to and forthcoming on all issues regarding 4. my sincere be cooperative 4 this case. It was never my intention to ignore or abuse the discovery process. 5 . MY PRAYER TO THE COURT: 6 7 I REQUEST THAT THE COURT PROVIDE FORGIVENESS IN THIS INSTAN CE DUE TO MY SPECIAL CIRCUMSTANCES. 8 , 9 I, JESSICA BERRY, do hereby declare that the above information is true and 10 correct, and that this declaration is being submitted for review to the Santa Barbara Superior Court, Anacapa Division, and for review by the Honorable Judge Colleen K. 11 Sterne. 12 ‘13 14 , 15 ficv oww .2 - lP/Ka/I‘l 16 . Case #. C/Jeésica‘Berry, Defendant// Date ‘ 17 18 19 20 21 22 23 24 25 26 27 28 Page 2of2 )—I PROOF OF SERVICE BY MAIL 2 STATE OF CALIFORNIA, COUNTY OF SANTA BARBARA 3 David Bertrand v. Jessica Berrv 4 Santa Barbara Superior Court, Anacapa Divison, Case No.: 19CV02429 5 I am employed in the County of Santa Barbara, State of California. I am over 6 the age of 18 and not a party to the within action; my business address is 418 E. Canon Perdido St., Santa Barbara, California 93101. 7 On December 20, 2019 I served the parties in this action the foregoing documents: 8 9 DEFENDANT’S OPPOSITION MOTION FOR MONETARY SAN CTIONS &_ OPPOSITION TO PLAINTIFF’S REQUEST FOR ADMISSIONS DEEMED AS 10 ADMITTED 11 XXX By placing true copies thereof enclosed in a sealed envelope with First Class 12 Postage fully paid and addressed as follows: 13 Mark T. Coffin, Esq, 14 21 E. Carrillo Street, Suite 240 Santa Barbara, ‘ CA 93101 15 . . 16 I am "readily familiar" with the firm's practice of collection and processing 17 correspondence for mailing. Under that practice it would be deposited with the U. S. Postal Service on that same day with postage thereon fully prepaid at Santa 18 Barbara, California in the ordinary course of business. I am aware that on motion Of ~ 19 the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing. 20 21 Executed on December 20, 2019 at Santa Barbara, California. 22 I declare under penalty of perjury under the laws of the State of California that the above is true and correct. 23 24 25 26 V 2% Francisco W R0 1' guez 27 NM