HomeMy WebLinkAbout21CV-0734 - Declaration Filed_Christine Dietrick1 -
DECLARATION OF CHRISTINE DIETRICK IN SUPPORT OF OPPOSITION
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BEST BEST & KRIEGER LLP JEFFREY V.
DUNN, Bar No.
131926 jeffrey.dunn@bbklaw.com DANIEL L.
RICHARDS, Bar No.
315552 daniel.richards@bbklaw.com
BEST BEST & KRIEGER LLP 18101 Von
Karman Avenue, Suite
1000 Irvine, California 92612
Telephone: (949) 263-2600
Facsimile: (949) 260-0972 Attorneys for Defendants and
Respondents City of San Luis Obispo and City Council of and
for the City of San Luis Obispo EXEMPT
FROM FILING FEES PURSUANT TO
GOVERNMENT CODE SECTION 6103 SUPERIOR COURT OF
THE STATE OF CALIFORNIA COUNTY
OF SAN LUIS
OBISPO NHC SLO,
LLC,
Petitioner and Plaintiffs, v. CITY OF
SAN LUIS OBISPO; CITY COUNCIL OF AND FOR
THE CITY OF SAN LUIS OBISPO;
AND
DOES 1-
10,
INCLUSIVE, Defendants and Respondents.
Case No. 21CV-
0734 Judge: Rita
Federman DECLARATION OF CHRISTINE
DIETRICK IN SUPPORT OF
OPPOSITION TO PLAINTIFF NHC SLO, LLC’
S EX PARTE
APPLICATION FOR TEMPORARY RESTRAINING ORDER
AND ORDER TO
SHOW
CAUSE RE: PRELIMINARY INJUNCTION
Date: January 31, 2022 Time:
8:30
a.
m.
Dept: 2 ELECTRONICALLY FILED 1/28/
2 -
DECLARATION OF CHRISTINE DIETRICK IN SUPPORT OF OPPOSITION
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BEST BEST & KRIEGER LLP
DECLARATION OF CHRISTINE DIETRICK I, Christine
Dietrick, declare as follows: 1.I have personal knowledge of the following facts, and if called
to testify thereto, I could and
would do so competently. 2.I am the City Attorney for the City
of San Luis Obispo.3. On October 9, 2020, I received a letter from Paul F. Ready
of Farmer & Ready, a Law Corporation, sent on behalf of Valnette Garcia, Helios Dayspring, and
NHC SLO, LLC. This letter provided information concerning Helios Dayspring’s transfer of
ownership interest in NHC SLO, LLC to Valnette Garcia. Attached hereto as Exhibit A is a true and
correct
copy of this letter. I declare under penalty of perjury under the laws of the State
of California that the forgoing is true and correct. Executed this 28th day of January, 2022,
at
San Luis
Obispo, California. Christine Dietrick
EXHIBIT A
PROOF OF SERVICE
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BEST BEST &KRIEGER LLPATTORNEYS AT LAW18101VON
KARMAN AVENUE,SUITE 1000IRVINE,CALIFORNIA 92612Proof of Service By Overnight Delivery I am a citizen of the
United States and employed in Orange County, California. I am over the age of eighteen years and not
a party to the within-entitled action. My business address is 18101 Von Karman
Avenue, Suite 1000, Irvine, California 92612. On January 28, 2022, I deposited with Federal
Express, a true and correct copy of
the within document(s): DECLARATION OF CHRISTINE DIETRICK IN
SUPPORT OF OPPOSITION TO PLAINTIFF NHC
SLO, LLC’S EX PARTE APPLICATION FOR
TEMPORARY RESTRAINING ORDER AND ORDER TO SHOW
CAUSE RE:
PRELIMINARY INJUNCTION in
a sealed envelope, addressed as
follows: John Armstrong Armstrong
Law Group 23232 Peralta
Drive, Suite
102 Laguna Hills, CA
92653 Tel. 949-942-6069 john@armstronglawgroup.co Attorneys for Petitioner/Plaintiff Following
ordinary business practices, the envelope was sealed and placed for collection by Federal Express on this date,
and would, in the ordinary course of business,
be retrieved by Federal Express for overnight delivery on this date. I declare under penalty of perjury
under the laws of
the State of California that the above is
true and