On October 23, 2020 a
Motion-Secondary
was filed
involving a dispute between
Kharbawy, A. Sameh El,
and
Board Of Trustees Of California State Of University,
Castro, Joseph I.,
Fu, Xuanning,
Hamm, Daryl L.,
Jimenez-Sandoval, Saul,
Zelenzy, Lynnette,
for 15 Unlimited - Other Employment
in the District Court of Fresno County.
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FILED by Superior Cfoufl
Elerzfo'nicaily PM
County of Los Angeles on 03/01/2021 03:59
of California, Coun. by
E. Salcido.Deputy Clerk
Sherri R. Carter, Executive OfficerlClerk of
Jésse J. Maddox, Bax No 219091
jmaddox@lcwlegal. com
Nathan T. Jackson, Bar N0. 285620
njackson@lcwlegal. com
LIEBERT CASSIDY WHITMORE
A Professional Law Corporation
5250 North Palm Ave, Suite 31 0
Fresno, California 93704
Telephone: 559.256.7800
Facsimile: 559.449.4535
Attorneys for Defendant BOARD OF TRUSTEES OF
CALIFORNIA STATE UNIVERSITY
\OOONO‘s
SUPERIOR COURT OF THE STATE OF CALEORNIA
COUNTY OF LOS ANGELES 2 1 CE CG 0 2 2 1 4
A. SAMEH EL KHARBAWY, Case No.2 2OLBCV00465
l0 Plaintiff, [ASSIGNED FOR ALL PURPOSES TO
3 MICHAEL VICENCIA, DEPT. S26]
Sum:
93704
Whitman:
v.
Con
Avc. Complaint Filed: OctoberZ 2020
[.nw BOARD OF TRUSTEES OF
(Jussidy
Palm
CALIFORNIA STATE UNIVERSITY;
Frcsno.iCnIifin'niu
DECLARATION OF ELIZABETH KAO FN
North
Professional
DARRYL L. HAMM, an individual; .
SUPPORT-OF DEFENDANT BOARD OF
Llcbert
LYNNETTE ZELEZNY, an individual; TRUSTEES OF CALIFORNIA STATE
5250 JOSEPH I. CASTRO, an individual; UNIVERSITY’S MOTION T0 TRANSFER
A
SAUL JMENEZ—SANDOVAL, an CASE TO FRESNO COUNTY
individual; XUANNING FU, an
individual; AND DOES 1 through 50, Date: March 25, 2021
Time:
'
8:30 am
Petitioner. Dept: S26
I, ELIZABETH KAO, declare as follows:
1. Ihave persona} knowledge of each matter stated herein, and if called upon to do so,
'
I coyild and would ¢9mpét§nt1y tgstify to each matter set forth herein.
7 '
'2’. '
I am éfi‘éfiflyéhifilofid by California State UniVersity, Fresno (“Fresno State”).
My job title ls Director of Environmental Health & Safety, and Risk Manager. Ihave been
J
’employed by Fresno State contlnuously since 1995.
///
1
Declaration of ElizabethKao
9510433.} FR007-003
4.1.“
3. Ireside in Fresno County, California. I do not have a residence in Los Angeles,
and itwould be inconvenient ifI had to appear in Los Angeles County for proceedings relating to
Plaintist lawsuit. My interactions With Plaintiff over the years have all pertained to my official
role as a Fresno State‘employee, in relation to conduct and events that occurred in Fresno County,
and in relation to Plaintiff’s role as a Professor at Fresno State. Any documents I possess that
could possibly relate to Plaintiff are also located in Fresno County.
4. Ihave never personally interacted With Plaintiff in Los Angeles County.
I declare under penalty of peljury under the laws of the state of California that the
folregoing is_true and correct.
Executed on February fl, 2021, at Fresno, California
310
Corporation
Suite
93704
Whilmorc
an
Ave,
Cassidy
Culilbnlin
Palm
%@% Elizabeth Kao
North
l’rul‘cssionul
Fresno,
l,ichurl
5230
A
2
Declaration of ElizabethKao
9510433.] FR007—003
afinuuu‘
.g
QRNM
M.: 2:."1, THE DOCUMENT TO WHICH THIS CERTIFICATE IS
0&5.
ATTACHED IS A FULL, TRUE. AND CORRECT COPY
OF THE ORIGINAL ON FILE AND OF RECORD IN
MYOFHCE.
I
JUL 26 2M
ATTEST:
SHERRI H. CARTER
Executive Officer/Clerk of the Superior
Co
/\/\/ .
les.
DEPUTY
Document Filed Date
March 01, 2021
Case Filing Date
October 23, 2020
Category
15 Unlimited - Other Employment
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FILED by Superior Cfoufl Elerzfo'nicaily PM County of Los Angeles on 03/01/2021 03:59 of California, Coun. by E. Salcido.Deputy Clerk Sherri R. Carter, Executive OfficerlClerk of Jésse J. Maddox, Bax No 219091 jmaddox@lcwlegal. com Nathan T. Jackson, Bar N0. 285620 njackson@lcwlegal. com LIEBERT CASSIDY WHITMORE A Professional Law Corporation 5250 North Palm Ave, Suite 31 0 Fresno, California 93704 Telephone: 559.256.7800 Facsimile: 559.449.4535 Attorneys for Defendant BOARD OF TRUSTEES OF CALIFORNIA STATE UNIVERSITY \OOONO‘s SUPERIOR COURT OF THE STATE OF CALEORNIA COUNTY OF LOS ANGELES 2 1 CE CG 0 2 2 1 4 A. SAMEH EL KHARBAWY, Case No.2 2OLBCV00465 l0 Plaintiff, [ASSIGNED FOR ALL PURPOSES TO 3 MICHAEL VICENCIA, DEPT. S26] Sum: 93704 Whitman: v. Con Avc. Complaint Filed: OctoberZ 2020 [.nw BOARD OF TRUSTEES OF (Jussidy Palm CALIFORNIA STATE UNIVERSITY; Frcsno.iCnIifin'niu DECLARATION OF ELIZABETH KAO FN North Professional DARRYL L. HAMM, an individual; . SUPPORT-OF DEFENDANT BOARD OF Llcbert LYNNETTE ZELEZNY, an individual; TRUSTEES OF CALIFORNIA STATE 5250 JOSEPH I. CASTRO, an individual; UNIVERSITY’S MOTION T0 TRANSFER A SAUL JMENEZ—SANDOVAL, an CASE TO FRESNO COUNTY individual; XUANNING FU, an individual; AND DOES 1 through 50, Date: March 25, 2021 Time: ' 8:30 am Petitioner. Dept: S26 I, ELIZABETH KAO, declare as follows: 1. Ihave persona} knowledge of each matter stated herein, and if called upon to do so, ' I coyild and would ¢9mpét§nt1y tgstify to each matter set forth herein. 7 ' '2’. ' I am éfi‘éfiflyéhifilofid by California State UniVersity, Fresno (“Fresno State”). My job title ls Director of Environmental Health & Safety, and Risk Manager. Ihave been J ’employed by Fresno State contlnuously since 1995. /// 1 Declaration of ElizabethKao 9510433.} FR007-003 4.1.“ 3. Ireside in Fresno County, California. I do not have a residence in Los Angeles, and itwould be inconvenient ifI had to appear in Los Angeles County for proceedings relating to Plaintist lawsuit. My interactions With Plaintiff over the years have all pertained to my official role as a Fresno State‘employee, in relation to conduct and events that occurred in Fresno County, and in relation to Plaintiff’s role as a Professor at Fresno State. Any documents I possess that could possibly relate to Plaintiff are also located in Fresno County. 4. Ihave never personally interacted With Plaintiff in Los Angeles County. I declare under penalty of peljury under the laws of the state of California that the folregoing is_true and correct. Executed on February fl, 2021, at Fresno, California 310 Corporation Suite 93704 Whilmorc an Ave, Cassidy Culilbnlin Palm %@% Elizabeth Kao North l’rul‘cssionul Fresno, l,ichurl 5230 A 2 Declaration of ElizabethKao 9510433.] FR007—003 afinuuu‘ .g QRNM M.: 2:."1, THE DOCUMENT TO WHICH THIS CERTIFICATE IS 0&5. ATTACHED IS A FULL, TRUE. AND CORRECT COPY OF THE ORIGINAL ON FILE AND OF RECORD IN MYOFHCE. I JUL 26 2M ATTEST: SHERRI H. CARTER Executive Officer/Clerk of the Superior Co /\/\/ . les. DEPUTY