Hovsepian v. Apple, Inc.

Filing 1224

Hovsepian v. Apple, Inc.

Doc. 1224

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JOHN HOUSTON SCOTT SBN 72578 LIZABETH N. dE VRIES SBN 227215 THE SCOTT LAW FIRM 1375 Sutter Street, Suite 222 San Francisco, CA 94109 Telephone: [phone] Facsimile: [phone] Attorneys for the Plaintiff

U N I T E D STATES DISTRICT COURT 8 N O R T H E RN DISTRICT OF CALIFORNIA 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I, JOHN HOUSTON SCOTT, declare as follows: 1. I am licensed to practice in the State of California and I have been admitted to Defendants. DATE: September 9, 2005 TIME: 10:00 a.m. DEPT: Magistrate Judge to be assigned Plaintiff, vs. SAN RAMON VALLEY UNIFIED SCHOOL DISTRICT and DOES 1 through 25, inclusive, LAURA E. CARRASCO, Case No. C04 2395 CRB DECLARATION OF JOHN HOUSTON SCOTT IN SUPPORT OF AND MOTION TO COMPEL DISCOVERY FROM DEFENDANT SAN RAMON VALLEY SCHOOL DISTRICT; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF [Civil L. R. 37, Fed. R. Civ. P. 26, 37]

practice before this court. I am familiar with the facts and issues in this action and I have personal knowledge of the matters stated herein and if called as a witness I could and would competently testify to said facts and each of them. I submit this declaration in support of the Motion to Compel Discovery from San Ramon Valley School District. /// 1
D E C L AR A T IO N OF JOHN HOUSTON SCOTT IN SUPPORT OF AND MOTION TO COMPEL DISCOVERY

Dockets.Justia.com

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2.

I believe all of the attached documents are true and correct copies as described below

that relate to Defendants' termination of Laura E. Carrasco in 2002. 3. For the Court's convenience, attached hereto as Exhibit 1 is a true and correct copy in

of the Plaintiff's Request for the production of Documents, Set Two. ("Discovery Request"). 4. Attached hereto as Exhibit 2 is a true and correct copy of the Defendant San Ramon

Valley Unified School District's Response to Plaintiff's Request for the Production of Documents. ("Discovery Response"). 5. Attached hereto as Exhibit 3 is a true and correct copy of plaintiff's first written

attempt to meet and confer with the defendant dated May 10, 2005. 6. Attached hereto as Exhibit 4 is a true and correct copy of Excerpts from the

deposition of Mr. David Lake, taken on June 10, 2005. ("Lake Depo"). 7. Attached hereto as Exhibit 5 is a true and correct copy of plaintiff's second written

attempt to meet and confer with the defendant dated June 14, 2005. 8. Attached hereto as Exhibit 6 is a true and correct copy of defendant's written

response to plaintiff's attempts to meet and confer dated June 16, 2005. 9. Attached hereto as Exhibit 7 is a true and correct copy of plaintiff's written request to

counsel for Sodexho, pursuant to counsel for the defendant's request, dated June 23, 2005. 10. Attached hereto as Exhibit 8 is a true and correct copy of the petition submitted to the

School Board by Laura Carrasco on October 8, 2005. ("Petition"). 11. Attached hereto as Exhibit 9 is a true and correct copy of the Notice of Prediscplinary

Hearing provided to Laura Carrasco ("Notice"). 12. Attached hereto as Exhibit 10 is a true and correct copy of Excerpts from the

deposition of Mr. Larry Shannon, taken on March 22, 2005 ("Shannon Depo"). 13. Attached hereto as Exhibit 11 is a true and correct copy of Larry Shannon's Resume,

provided to the Plaintiff on March 22, 2005. ("Shannon Resume"). 2
D E C L AR A T IO N OF JOHN HOUSTON SCOTT IN SUPPORT OF AND MOTION TO COMPEL DISCOVERY

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14.

Attached hereto as Exhibit 12 is a true and correct copy of the Agreement between

San Ramon Valley School District, Service Employees International Union (SEIU) and Laura Carrasco, attached as Exhibit #3 to the Notice. ("Suspension Agreement"). 15. Attached hereto as Exhibit 13 is a true and correct copy of the response to the

District's Notice from Carrasco, attached to the Notice. ("Carrasco's Response"). I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that this declaration was executed on July 25, 2005 at San Francisco, California.

/s/ John Houston Scott John Houston Scott

F : \C a s e s\ C a se s - Active\Carrasco, Laura\Pleadings\Motion to Compel\Decl Scott.wpd

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D E C L AR A T IO N OF JOHN HOUSTON SCOTT IN SUPPORT OF AND MOTION TO COMPEL DISCOVERY