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Case 8:16-cv-00591-SVW-PLA Document 46-1 Filed 03/02/17 Page 1 of 3 Page ID #:478

Jeremy D. Jass, SBN 279466


1 Jeremy@jasslaw.com
JASS LAW
2 4510 E. Pacific Coast Highway, Suite 400
Long Beach, CA 90804
3 Telephone: (562) 340-6299
Facsimile: (562) 340-6422
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Attorneys for Plaintiff
5 ALEXA CURTIN
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8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
ALEXA CURTIN,
10 CASE NO. 8:16-cv-00591-SVW-PLA
11 The Hon. Stephen V. Wilson
Plaintiff,
12 DECLARATION OF JEREMY D.
13 JASS IN SUPPORT OF
APPLICATION FOR ENTRY OF
14 vs. DEFAULT
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COUNTY OF ORANGE; NICHOLAS
17 LEE CAROPINO, individually and as
18 Deputy Sheriff for the County of
Orange; and DOES 1 through 50,
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Defendants,
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4837-0524-1923.2
DECLARATION OF JEREMY D. JASS IN SUPPORT OF APPLICATION FOR ENTRY OF DEFAULT
Case 8:16-cv-00591-SVW-PLA Document 46-1 Filed 03/02/17 Page 2 of 3 Page ID #:479

1 I, Jeremy D. Jass, declare:


2 1. I am a member in good standing with the California Bar and an
3 attorney licensed to practice before the Courts in the State of California, as well as
4 the United States District Court for the Central District of California. I am the
5 attorney of record for the Plaintiff, Alexa Curtin, in the herein civil rights case.
6 2. Based upon information and belief, I have personal knowledge of the
7 facts set forth herein, and if called upon to do so, I could and would competently
8 testify thereto. This declaration is offered by Plaintiff in support of the Application
9 for Entry of Default.
10 3. Defendant Nicholas Lee Caropino was served pursuant to Rule 4 of the
11 Federal Rules of Civil Procedure on December 29, 2016.
12 4. Under Rule 12, Defendant Nicholas Lee Caropino was required to
13 plead or otherwise respond to the Second Amended Complaint by January 19, 2017.
14 I agreed to grant a request by counsel for Defendant County of Orange to not seek
15 Entry of Default before the end of February, 2017; as the Board of the County of
16 Orange was determining whether they would provide Defendant Nicholas Lee
17 Caropino defense counsel.
18 5. I have recently been informed by Counsel for Defendant County of
19 Orange that the County of Orange has refused to provide Defendant Nicholas Lee
20 Caropino defense counsel.
21 6. Defendant Nicholas Lee Caropino has failed to serve or file a pleading
22 or otherwise respond to the Second Amended Complaint. The applicable time limit
23 for responding to the Second Amended Complaint has expired.
24 7. Defendant Nicholas Lee Caropino is not a minor or an incompetent
25 person.
26 8. Defendant Nicholas Lee Caropino is not currently in the military
27 service, and therefore the Servicemembers Civil Relief Act does not apply.
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4837-0524-1923.2 1
DECLARATION OF JEREMY D. JASS IN SUPPORT OF JOINT STIPULATION RE MOTION TO COMPEL
Case 8:16-cv-00591-SVW-PLA Document 46-1 Filed 03/02/17 Page 3 of 3 Page ID #:480

1 9. I have attached this declaration a true and correct copy of the proof of
2 service on file with this Court for the above-named Defendant.
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4 I declare under the penalty of perjury that the foregoing is true and correct.
5 Executed on March 1, 2017, in Long Beach, California.
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10 Jeremy D. Jass
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4837-0524-1923.2 2
DECLARATION OF JEREMY D. JASS IN SUPPORT OF JOINT STIPULATION RE MOTION TO COMPEL