Motion,Ex Parte: PENINSULA OPEN SPACE TRUST vs. ERNEST J. MCNABB, et al

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                  Andrew J. Wiegel, Esq., (SBN 075204)
             2    G. Ryan Patrick, Esq., (SBN 275517)
             3    WIEGEL LAW GROUP, PLC
                  414 Gough Street
             4    San Francisco, CA 94102-4464
                  (415) 552-8230                                                                    3/5/2021
             5    andrew@wiegellawgroup.com
             6    ryan@wiegellawgroup.com

             7    Attorneys for Defendants:
                  ERNEST J. MCNABB, Individually and as
             8    Trustee of the ERNEST J. MCNABB REVOCABLE
             9    LIVING TRUST DATED 11/19/1990

            10                                    SUPERIOR COURT OF CALIFORNIA
            11                                            COUNTY OF SAN MATEO
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                  PENINSULA OPEN SPACE TRUST,                               Case No. 20-CIV-02349
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                  Plaintiff,
            14                                                              DECLARATION OF G. RYAN
                  vs.                                                       PATRICK REGARDING MEET &
            15                                                              CONFER WITH GARY DAMBACHER
                  REDWOOD TRUST DEED SERVICES,
            16    INC., a California Corporation; ERNEST                    PRIOR TO FILING DEMURRER
                  J. MCNABB, individually and as Trustee
            17    of the Ernest J. McNabb Revocable                         Date:      March 12, 2021
                  Living Trust Dated 11/19/1990; LOUIS                      Time:      9:00 A.M.
            18    J. ARATA, individually; LAURA                             Dept. 21, Courtroom 2J
                  ARATA, individually, as the Co-
            19    Executor and Representative of the                        Hon. Robert D. Foiles
                  Estate of Gary J. Arata, Deceased, and as
            20    sole successor trustee of the John and
                  Grace Arata 2004 Trust Executed August
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                  11, 2004; and DOES 1-20.
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                  Defendants.
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                         DECLARATION OF G. RYAN PATRICK RE MEET & CONFER PRIOR TO FILING DEMURRER
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                  LAURA J. ARATA, as sole and
             2    successor trustee of the John and Grace
                  Arata 2004 Trust, dated August 11, 2004,
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                  Cross Complainant,
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                  vs.
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                  ERNEST J. MCNABB, individually and
                  as Trustee of the Ernest J. McNABB
             7    Revocable Living Trust dated
                  11/19/1990; REDWOOD TRUST DEED
             8    SERVICES, INC., a California
                  Corporation; HILLCREST REAL
             9    ESTATE INC., A California
                  Corporation; WILLIAM JACOB
            10    MAIER; and ROES 1-50, inclusive
            11    Cross-Defendants.
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            13         I, G. Ryan Patrick, declare:
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                       1.   I am an attorney duly licensed to practice law before all courts in the State of California.
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                       2.   The Wiegel Law Group is counsel of record for Defendant/Cross-Defendant Ernest J.
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                  McNabb in this action.        I presently practice law as an associate attorney with the Wiegel Law
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            18    Group firm.

            19         3.   I have personal knowledge of the facts stated herein and if called to testify thereto, I
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                  could and would be able to do so in accordance with the witness requirements set forth in
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                  California’s Evidence Code.
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                       4.   I have submitted this declaration in response to the false claim made by Laura Arata’s
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            24    attorney, Gary Dambacher, that our firm did not meet and confer with Mr. Dambacher prior to

            25    filing our demurrer.
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                       5.   On October 5, 2020, Andrew J. Wiegel and I had a conference call with Mr. Dambacher
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                  that lasted approximately 1 hour.        During that call, Mr. Wiegel and I discussed the points on
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                         DECLARATION OF G. RYAN PATRICK RE MEET & CONFER PRIOR TO FILING DEMURRER
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             1    which we intended to file a demurrer to Laura Arata’s cross-complaint and proposals for global
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                  resolution of the case.
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                           I declare under penalty of perjury that the facts stated herein are true and correct.
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             6    Executed on March 5, 2020, in the City and County of San Francisco, CA.

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                                                      /s/ G. Ryan Patrick
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                                                               G. Ryan Patrick
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                         DECLARATION OF G. RYAN PATRICK RE MEET & CONFER PRIOR TO FILING DEMURRER
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