Motion-Secondary: ALIDA MAZARIEGOS vs VANGUARD CLEANING SYSTEMS, INC

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                                7/2/2021
 1   Michael A. Hood (State Bar No. 71258)
     JACKSON LEWIS P.C.
 2   200 Spectrum Center Drive, Suite 500
     Irvine, California 92618-5005
 3   Telephone: (949) 885-1374
     Facsimile: (949) 885-1380
 4   E-mail: Michael.Hood@jacksonlewis.com
 5   Fraser A. McAlpine (State Bar No. 248554)
     Adam V. Truong (State Bar No. 318896)
 6   JACKSON LEWIS P.C.
     50 California Street, 9th Floor
 7   San Francisco, California 94111-4615
     Telephone: (415) 394-9400
 8   Facsimile: (415) 394-9401
     E-mail: Fraser.McAlpine@jacksonlewis.com
 9   E-mail: Adam.Truong@jacksonlewis.com
10   Attorneys for Defendants
     RR FRANCHISING, INC., BUDDHA
11   CAPITAL CORPORATION and WINE
     COUNTRY VENTURES, INC.
12

13                         SUPERIOR COURT OF THE STATE OF CALIFORNIA

14                                         COUNTY OF SAN MATEO

15   ALIDA MAZARIEGOS, PAULA                                  Case No. 20-CIV-04267
     GONZALEZ, and JAIME AMAYA
16                                                            Class Action - Complex Designation
             Plaintiffs, on behalf of themselves and
17           all others similarly situated,                   Assigned for All Purposes to
                                                              Hon. Nancy L. Fineman, Dept. 4
18           v.
                                                              DECLARATION OF ADAM L.
19   VANGUARD CLEANING SYSTEMS, INC.;                         LOUNSBURY IN SUPPORT OF
     RR FRANCHISING, INC., D/B/A                              APPLICATION FOR ADMISSION
20   VANGUARD CLEANING SYSTEMS OF                             PRO HAC VICE
     SOUTHERN CALIFORNIA AND D/B/A
21   VANGUARD CLEANING SYSTEMS OF                             Dept.:        4, Ctrm. 8B
     NORTHERN CALIFORNIA; BUDDHA                              Judge:        Hon. Nancy L. Fineman
22   CAPITAL CORPORATION, D/B/A
     VANGUARD CLEANING SYSTEMS OF
23   SACRAMENTO, D/B/A VANGUARD                               Complaint Filed:      10/01/2020
     CLEANING SYSTEMS OF THE CENTRAL                          Trial Date:           Not Set
24   VALLEY, AND D/B/A VANGUARD
     CLEANING SYSTEMS OF THE CENTRAL
25   COAST; AND WINE COUNTRY
     VENTURES, INC. D/B/A VANGUARD
26   CLEANING SYSTEMS OF THE NORTH
     BAY, AND DOES 1 THROUGH 10,
27   INCLUSIVE,

28                   Defendants.

                                                           1
     Declaration of Adam L. Lounsbury ISO Application for Admission Pro Hac Vice        Case No. 20-C1V-04267
 1            I, Adam L. Lounsbury, declare as follows:
 2            1.      I am a United States citizen over the age of 18 years. I am competent to testify to
 3   the matters set forth in this Declaration. I make this Declaration in support of my Application to
 4   be admitted Pro Hac Vice as counsel for Defendants RR FRANCHISING, INC., BUDDHA
 5   CAPITAL CORPORATION and WINE COUNTRY VENTURES, INC. in the matter captioned
 6   above.
 7            2.      I am a member in good standing of the State Bar of Virginia (Virginia Bar
 8   ID #89847) and not a member of the State Bar of California. Certificate of Good Standing
 9   attached as Exhibit 1. I am not a resident of California, nor am I employed or regularly engaged
10   in substantial business, professional, or other activities in California. I am a resident of Virginia.
11            My business address is:
12                    Adam L. Lounsbury
                      JACKSON LEWIS P.C.
13                    701 East Byrd Street, 17th Floor
                      Richmond, Virginia 23219-4500
14                    Telephone: (804) 649-0404
                      Facsimile: (804) 649-0403
15                    E-mail: Adam.Lounsbury@jacksonlewis.com

16            My residence address is:

17                    Adam L. Lounsbury
                      1581 Horsepen Hills Road
18                    Maidens, Virginia 23102-2409

19            3.      I am a member in good standing of the following courts, and am not currently

20   suspended or disbarred in any court:

21                           State of New York (1st Dept.): Admitted 05/04/2009;

22                           U.S. District Court, New York Eastern District: Admitted 03/30/2010;

23                           U.S. District Court, New York Southern District: Admitted 03/30/2010;

24                           U.S. Court of Appeals, 2nd Circuit: Admitted 02/24/2011;

25                           State of Virginia: Admitted 01/19/2016;

26                           U.S. District Court, Virginia Eastern District: Admitted 10/22/2018; and

27                           U.S. District Court, Virginia Western District: Admitted 12/17/2018.

28   ///

                                                           2
     Declaration of Adam L. Lounsbury ISO Application for Admission Pro Hac Vice     Case No. 20-C1V-04267
 1            4.       I have been admitted pro hac vice in the following courts in the preceding two
 2   years USDC – District of Connecticut.
 3            5.       I am General Counsel of RR Franchising, Inc., and in that capacity I am the best
 4   lawyer to appear on its behalf in the above-entitled action.              As General Counsel for RR
 5   Franchising, Inc., I understand the history of RR Franchising, Inc. and its relationship to the
 6   other named Defendants doing business as sole proprietorships. Knowledge of this history is
 7   relevant to RR Franchising, Inc.’s defense of the claims made by Plaintiff in this action.
 8            6.       The required fee was paid this date to the State Bar of California by counsel of
 9   record shown on the caption above. The name, address, and telephone number of the active
10   member of the State Bar of California who is attorney of record appears in the caption above.
11            I declare, under penalty of perjury, under the laws of the State of California that the
12   foregoing is true and correct to the best of my personal knowledge.
13            Executed this 2nd day of July, 2021, in Richmond, Virginia.

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15                                                             ___________________________________
                                                                     Adam L. Lounsbury
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28   4824-0575-2276, v. 1


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     Declaration of Adam L. Lounsbury ISO Application for Admission Pro Hac Vice      Case No. 20-C1V-04267
EXHIBIT 1
AO 136RD (Rev. 8/93)




                  CERTIFICATE OF GOOD STANDING

UNITED STATES OF AMERICA



EASTERN DISTRICT OF VIRGINIA


         I, FERNANDO GALINDO, Clerk of the United States District Court for the

Eastern District of Virginia, Richmond Division,

         DO HEREBY CERTIFY that           Adam Lewis Lounsbury , ID #89847,

was admitted to practice in said Court on        October 22, 2018    and is in good

standing as a member of the bar of said Court.

                                    FERNANDO GALINDO, CLERK


                                    By:     ( --Ift     i' 4 4 A
                                                      Deputy Clerk

Dated at Richmond, Virginia
on     January 20, 2021     .