On September 20, 2016 a
Motion-Secondary
was filed
involving a dispute between
Maria Canul,
and
for civil
in the District Court of Santa Clara County.
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16CV300096
Santa Clara — Civil
Electronically Filed
Fred W. Schwinn (SBN 225575)
by Superior Court of CA,
Raeon R. Roulston (SBN 255622)
Matthew C. Salmonsen (SBN 302854) County of Santa Clara,
CONSUMER LAW CENTER, INC. on 2/17/2021 3:41 PM
1435 Koll Circle, Suite 104 Reviewed By: R. Walker
San Jose, California 95112-4610 Case #16CV300096
Telephone Number: (408) 294-6100 Envelope: 5858403
Facsimile Number: (408) 294-6190
Email Address: fred.schwinn@sjconsumerlaw.com
Attorneys for Defendant/Cross-Complainant
MARIA ANTONIA CANUL
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SANTA CLARA
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VELOCITY INVESTMENTS, LLC, Case No. 16CV300096
ll (Unlimited Civil Case)
Plaintiff,
12 v. SUPPLEMENTAL DECLARATION OF
13 MATTHEW C. SALMONSEN IN SUPPORT
MARIA ANTONIA CANUL,
OF MOTION TO COMPEL FURTHER
14 Defendant. RESPONSES TO INTERROGATORIES,
REQUEST FOR PRODUCTION OF
15 DOCUMENTS, DOCUMENTS
RESPONSIVE THERETO, AND FOR
16
MONETARY SANCTIONS AGAINST
17 VELOCITY INVESTMENTS, LLC
18 [C.C.P. §§ 2030.300 and 2031.310]
AND RELATED CROSS-ACTION.
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20 I, Matthew C. Salmonsen, declare as follows:
21 1 Tam an attorney at law duly licensed to practice before all the courts of the State of
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California and am an associate attorney at the law firm Consumer Law Center, Inc., attorneys of record
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for Defendant/Cross-Complainant, MARIA ANTONIA CANUL (hereinafter “CANUL”).
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2. I have personal knowledge of the following facts, and if called as a witness, I could
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26 and would competently testify thereto.
27 3 I spent an additional 6.5 hours in reviewing the opposition papers and drafting
28
CANUL’s reply memorandum in support of her motion. Accordingly, the party that I represent requests
-1-
SUPPLEMENTAL DECLARATION Case No. 16CV300096
1 monetary sanctions in the amount of $7,765.72 in this matter (8.9 hours for the moving papers and 6.5
hours drafting CANUL’s Reply x $500.00, plus $65.72 for filing fees).
I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct.
Executed this 17" day of February, 2021, at San Jose, California.
/s/ Matthew C. Salmonsen
Matthew C. Salmonsen
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SUPPLEMENTAL DECLARATION Case No. 16CV300096
Document Filed Date
February 17, 2021
Case Filing Date
September 20, 2016
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16CV300096 Santa Clara — Civil Electronically Filed Fred W. Schwinn (SBN 225575) by Superior Court of CA, Raeon R. Roulston (SBN 255622) Matthew C. Salmonsen (SBN 302854) County of Santa Clara, CONSUMER LAW CENTER, INC. on 2/17/2021 3:41 PM 1435 Koll Circle, Suite 104 Reviewed By: R. Walker San Jose, California 95112-4610 Case #16CV300096 Telephone Number: (408) 294-6100 Envelope: 5858403 Facsimile Number: (408) 294-6190 Email Address: fred.schwinn@sjconsumerlaw.com Attorneys for Defendant/Cross-Complainant MARIA ANTONIA CANUL SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA 10 VELOCITY INVESTMENTS, LLC, Case No. 16CV300096 ll (Unlimited Civil Case) Plaintiff, 12 v. SUPPLEMENTAL DECLARATION OF 13 MATTHEW C. SALMONSEN IN SUPPORT MARIA ANTONIA CANUL, OF MOTION TO COMPEL FURTHER 14 Defendant. RESPONSES TO INTERROGATORIES, REQUEST FOR PRODUCTION OF 15 DOCUMENTS, DOCUMENTS RESPONSIVE THERETO, AND FOR 16 MONETARY SANCTIONS AGAINST 17 VELOCITY INVESTMENTS, LLC 18 [C.C.P. §§ 2030.300 and 2031.310] AND RELATED CROSS-ACTION. 19 20 I, Matthew C. Salmonsen, declare as follows: 21 1 Tam an attorney at law duly licensed to practice before all the courts of the State of 22 California and am an associate attorney at the law firm Consumer Law Center, Inc., attorneys of record 23 for Defendant/Cross-Complainant, MARIA ANTONIA CANUL (hereinafter “CANUL”). 24 2. I have personal knowledge of the following facts, and if called as a witness, I could 25 26 and would competently testify thereto. 27 3 I spent an additional 6.5 hours in reviewing the opposition papers and drafting 28 CANUL’s reply memorandum in support of her motion. Accordingly, the party that I represent requests -1- SUPPLEMENTAL DECLARATION Case No. 16CV300096 1 monetary sanctions in the amount of $7,765.72 in this matter (8.9 hours for the moving papers and 6.5 hours drafting CANUL’s Reply x $500.00, plus $65.72 for filing fees). I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed this 17" day of February, 2021, at San Jose, California. /s/ Matthew C. Salmonsen Matthew C. Salmonsen 10 ll 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -2- SUPPLEMENTAL DECLARATION Case No. 16CV300096