Document for BIG WASHINGTON, LLC VS FRY ET AL

• 
• 
• 
• 

						
                                
Preview
                                1    William L. Alexander (State Bar Number 126607)
                      Elizabeth Estrada (State Bar Number 232302)
                 2    Alexander & Associates, PLC
                 3    1925 G Street
                      Bakersfield, CA      93301
                 4    Phone: (661) 316-7888
                      Email:    walexander@alexander-law.com; elizabeth@alexander-law.com
                 5
                 6    Attorneys for Defendants, Thomas H. Fry and Ruth M. Fry
                      as Trustees of the T & R Fry Family Trust
                 7
                 8                            SUPERIOR COURT OF THE STATE OF CALIFORNIA

                 9                              COUNTY OF KERN – METROPOLITAN DIVISION

                10
                11                                                                )  Case No.     BCV-17-102341 BCB
                       BIG WASHINGTON, LLC, a California
                       Limited Liability Company,                                 )
                12
                                                                                  )  DECLARATION OF ELIZABETH
                13                                      Plaintiff,                )  ESTRADA IN SUPPORT OF OPPOSITION
                                                                                  )  OF DEFENDANTS TO PLAINTIFF’S EX
                14                                                                )  PARTE APPLICATION TO ADVANCE
                       vs.
                                                                                  )  DEPOSITION DATE FOR STEPHANIE
                15                                                                )  SMITH SET BY THE COURT
                       BENHONG (AMERICA) RECYCLING CO.
                16     LTD, a California Limited Liability Company;               )
                       and THOMAS H. FRY and RUTH M. FRY as                       )  Assigned to:       Hon. Bernard C. Barmann
                17     Trustees of the T & R FRY FAMILY TRUST;                    )  Div.:             H
                       and DOES 1 – 100, inclusive,                               )
                18                                                                )  Date:   March 3, 2022
                19                                       Defendants.              )  Time: 8:30 a.m.
                                                                                  )  Div.:   H
                20                                                                )
                                                                                  )  Complaint Filed:       October 6, 2017
                21                                                                )  Trial Date:    May 31, 2022
                22                                                                )
                                                                                  )
                23
                24             I, ELIZABETH ESTRADA, declare as follows:
                25             1.       I am an attorney licensed to practice law before the Courts of the State of California.                I
                26    am an associate attorney at Alexander & Associates, PLC, counsel of record for defendants, Thomas
                27    H. Fry and Ruth M. Fry, Trustees of the T & R Fry Family Trust.                As such, I have personal knowledge
                28    of the facts set forth in this declaration and if called upon to testify, I would and could competently

                                                                                   1
     Alexander & Associates
       Attorneys at Law
        1925 G Street
     Bakersfield, CA 93301
       (661) 316-7888
                        DECLARATION OF ELIZABETH ESTRADA IN SUPPORT OF FRYS’ OPPOSITION TO BIG WASHINGTON’S
                                EX PARTE APPLICATION TO ADVANCE THE DEPOSITION DATE FOR STEPHANIE SMITH
                 1     testify to such facts.
                 2              2.       My office is involved in a case that was scheduled to commence a 10-day jury trial on
                 3     March 7, 2022.      We had been informed, however, that we would be trailing.                 We received notice on
                 4     March 2, 2022 that our matter is likely to commence March 8, 2022 and that the trial court is dark
                 5     from March 14, 2022 through March 18, 2022.                We believe, therefore, that we likely will be in trial
                 6     through March 31, 2022.
                 7              I declare under penalty of perjury under the laws of the State of California that the foregoing
                 8     is true and correct.    Executed this 2nd day of February in Bakersfield, California.
                 9
                10
                                                                              Elizabeth        Estrada
                                                                             _______________________________
                11
                                                                             ELIZABETH ESTRADA
                12
                13
                14
                15
                16
                17
                18
                19
                20
                21
                22
                23
                24
                25
                26
                27
                28

                                                                                   2
     Alexander & Associates
       Attorneys at Law
        1925 G Street
     Bakersfield, CA 93301
       (661) 316-7888
                        DECLARATION OF ELIZABETH ESTRADA IN SUPPORT OF FRYS’ OPPOSITION TO BIG WASHINGTON’S
                                EX PARTE APPLICATION TO ADVANCE THE DEPOSITION DATE FOR STEPHANIE SMITH