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WENDY E. MUSELL, State Bar #203507ELISA J. STEWART, State Bar #219557
23456789
STEWART & MUSELL, LLP351 California Street, Suite 700
San Francisco, CA 94104
Telephone: (415) 593-0083Facsimile:
(415) 520-0920Attorneys for Plaintiff ADURE R. VELAZQUEZ
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SACRAMENTO
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ADURE R. VELAZQUEZ,
PLAINTIFF,
V.
THE CALIFORNIA DEPARTMENT OFPARKS AND RECREATION; MANUELLOPEZ and DOES 1-20, inclusive.
DEFENDANTSCase No.:
34-2012-00126610
NOTICE OF ERRATA TO THE
DECLARATION OF CHERYLTAYLOR IN SUPPORT OF
PLAINTIFF'S MOTION TO
DISQUALIFY DEPUTY ATTORNEY
AND THE ATTORNEY GENERAL'S
OFFICE FROM REPRESENTING
DEFENDANT DEPARTMENT OFPARKS AND RECREATION
Date:
August 30, 2012
Time:
2:00 PM
Dept.:
53
Judge:
Hon. David I. BrownTrial Date: Not SetAction Filed: June 25, 2012
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TO THE COURT, ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
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PLEASE TAKE NOTICE that the Declaration of Cheryl Taylor in Support of Plaintiff's
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Motion to Disqualify Deputy Attorney General and The Attorney General's Office from
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Representing Defendant Department of Parks and Recreation filed by Plaintiff on August 3, 2012
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(attached hereto as Exhibit 1), is hereby being revised to correct an inadvertent error pertaining to
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a date in paragraph 13 of the Declaration of Cheryl Taylor. Attached hereto as Exhibit 2 is the
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Pagel
NOTICE OF ERRATA TO THE DECLARATION OF CHERYL TAYLOR IN SUPPORT OF PLAINTIFF'S MOTION TODISQUALIFY DEPUTY ATTORNEY AND THE ATTORNEY GENERAL'S OFFICE FROM REPRESENTINGDEFENDANT DEPARTMENT OF PARKS AND RECREATION
Case No.: 34-2012-00126610
To: Deputy Attorney General Mark J. TarnalynPage 3 of 2012-0B-14 16:33:57
(
G
MT)
Prom: Elise Stewart
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Amended Declaration of Cheryl Taylor executed on August 13, 2012, describing and correcting
2the error of the Declaration of Cheryl Taylor filed on August 3, 2012.3Respectfully submitted,4Dated: August 14, 2012STEWART & MUSELL, LLP56By:7ISA J. Sr TWARTAttorneys for Plaintif 8
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Page 2
NOTICE OF ERRATA TO THE DECLARATION OF CHERYL TAYLOR IN SUPPORT OF PLAINTIFF'S MOTION TODISQUALIFY DEPUTY ATTORNEY AND THE ATTORNEY GENERAL'S OFFICE FROM REPRESENTINGDEFENDANT DEPARTMENT OF PARKS AND RECREATION
Case No.:
34-2012-00126610
To: IDeputy Attorney General Ma rlc J. -I-a mkalyn Page 4 of '201 2-08-1 4 1S:33:57 (GN/1-1-)
From: Elise Stewat
PROOF OF SERVICE
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I am employed in the City and County of San Francisco, State of California. I am over 18years of age and not a party to the above-entitled action. My business address is Stewart &
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Musell, LLP, Attorneys at Law, 351 California Street, Suite #700, San Francisco, CA 94104. Onthe execution date below and in the manner stated herein, I served the following documents:
NOTICE OF ERRATA TO THE DECLARATION OF CHERYL TAYLOR IN SUPPORTOF PLAINTIFF'S MOTION TO DISQUALIFY DEPUTY ATTORNEY AND THEATTORNEY GENERAL'S OFFICE FROM REPRESENTING DEFENDANTDEPARTMENT OF PARKS AND RECREATION
[ X ] BY RRST CLASS U.S. MAIL. I am readily familiar with Stewart
&
Musell, LLP's
practice
for
collection and processing of correspondence for mailing with the United StatesPostal Service. I placed a true copy of the documents in a sealed envelope with first class postagefully prepaid for collection and mailing
following
our ordinary business's practice for collectingand processing correspondence for mailing. On the same day, that correspondence is placed forcollection and mailing, it is deposited in the ordinary course of business with the United States
Postal Service.
[ X ] BY FASCIMILE. caused the transmission of the above-described documents by
facsimile to the offices of the addressee(s) listed below. No error was reported by the faxmachine used.
H
BY FED EX. I caused such document(s) to be placed for FedEx collection and delivery at
San Francisco, Califonia, I am readily familiar with the firm's practice of collection and
processing correspondence for FedEx mailing. Under that practice, it would be deposited with
theFed& office on that same day with instructions for overnight delivery, fully prepaid, at San
Francisco, California in the ordinary course of business. I am aware that on motion of the partyserved, service is presumed invalid if the FedEx delivery date is more than one day after date of deposit with the local FedEx ofice, pursuant to this affidavit.
[
[ BY PERSONAL SERVICE. I caused the document(s) to be delivered by hand to the officesof the addressee(s) pursuant to CCP §101I, via Nationwide Legal, Inc.The name and address of each person to whom the documents were served is as follows:21Mark I. Tamblyn Lynne 0. StockerDeputy Attorney General Andrada & Associates, APC1300 I Street, Suite 125 180 Grand Avenue23P.O. Box 944255 Suite 225Sacramento, CA 94244-2550 Oakland, CA 9461224 Fax: 916-324-5567 Fax: 510-287-4161
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I declare under penalty of perjury under the laws of the State of California that the foregoingis true and correct and that this declaration was executed on
August 14, 2012
at San Francisco,
California.
istina M. Clark
PROOF OF SERVICE
Case No. 34-2012-00126610
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Affidavit on State Parks Funding
Affidavit regarding when an ex-parks employee told investigators about hidden money inside the department's bank accounts.
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