1 OLIVAREZ MADRUGA LEMIEUX O’NEILL, LLP

Terence J. Gallagher – SBN 192341

2 tgallagher@omlolaw.com
Paul A. Aguilar – SBN 305624
3 paguilar@omlolaw.com
500 South Grand Avenue – 12th Floor
4 Los Angeles, CA 90071
Tel: (213) 744-0099
5 Fax: (213) 744-0093
6 Attorneys for Defendant,
COMPTON UNIFIED SCHOOL DISTRICT
7

8 SUPERIOR COURT OF THE STATE OF CALIFORNIA

9 COUNTY OF LOS ANGELES
10 [Exempt from filing fees by Gov. Code § 6103]
11 RETHENA FLOWERS an individual, ) Case No.: 19 CMCV 00133
) Judge: Honorable Thomas D. Long
12 Plaintiff, ) Dept.: A
)
13 vs. ) DEFENDANT COMPTON UNIFIED SCHOOL
) DISTRICT’S NOTICE OF TAKING THE
14 COMPTON UNIFIED SCHOOL DISTRICT; ) DEPOSITION OF WITNESS MACK MARTIN
and DOES 1 to 25, Inclusive, )
15 ) Date: September 30, 2021
Defendants. ) Time: 10:00 a.m.
16 ) Location: Video Conference
)
17 )
)
18 ) Complaint Filed: April 19, 2019
) Trial Date: November 15, 2021
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1 NOTICE OF TAKING DEPO OF MACK MARTIN

 1 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:

2 PLEASE TAKE NOTICE that pursuant to California Code of Civil Procedure section

3 2025.010, et seq., Defendant COMPTON UNIFIED SCHOOL DISTRICT (“Defendant”), through its

4 attorneys of record, will take the deposition of MACK MARTIN, by remote videoconferencing on

5 September 30, 2021, at 10:00 a.m. Instructions for connection to the videoconference are as follows:

6 -Join by computer: https://zoom.us/j/7746995971

7 -Join by smart device "Zoom Cloud Meetings" app; Choose "Join a Meeting"

8 -Enter meeting ID: 7746995971 Password: 1190297

9 The videoconference deposition will take place before a duly qualified court reporter or before
10 any notary public authorized to administer oaths in the State of California who will not be in the same

11 location as the witness. Defendants intend to cause the proceedings to be recorded stenographically

12 and by videotape. This videotape deposition is intended for possible use at trial under Code of Civil

13 Procedure section 2025.620. This video deposition will continue day to day, excepting Saturdays,

14 Sundays, and holidays, until completed, or as may be mutually agreed by the parties or the Court.

15 PLEASE TAKE FURTHER NOTICE that if an interpreter is required to translate testimony,

16 written notice of same must be given at least five (5) working days before the deposition date, and the

17 specific language and/or dialect thereby designated.

18 PLEASE BE ADVISED that if there are any court reporter and/or interpreter fees incurred for

19 failing to appear for a confirmed deposition, then the deponent is responsible for such incurred fees.

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21 Dated: September 15, 2021 OLIVAREZ MADRUGA LEMIEUX O’NEILL, LLP

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23 By:
Paul A. Aguilar
24 Attorneys for Defendant, COMPTON UNIFIED
SCHOOL DISTRICT
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2 NOTICE OF TAKING DEPO OF MACK MARTIN

 PROOF OF SERVICE
1
By Email
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3 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES

4 I am employed in the County of Los Angeles, State of California. I am over the age of
5 eighteen years and am not a party to the within action. My business address is 500 South Grand
Avenue, 12th Floor, Los Angeles, CA 90071.
6
On September 15, 2021, I served a true and correct copy of the foregoing document entitled:
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DEFENDANT COMPTON UNIFIED SCHOOL DISTRICT’S NOTICE OF TAKING THE
8 DEPOSITION OF WITNESS MACK MARTIN
9
on the interested parties in this action by placing the document in a sealed envelope and addressed as
10 follows:

11 Tristan G. Pelayes, Esq. Attorneys for Plaintiff, RETHENA

Tom Yu, Esq. FLOWERS
12
LAW OFFICE OF PELAYES & YU APC
13 10803 Foothill Boulevard, Suite 112 Tel: (909) 481-3833
Rancho Cucamonga, CA 91730 Fax: (909) 801-7004
14 Email: tgp@pelayes-yu.com
tyu@pelayes-yu.com
15 sm@pelayes-yu.com
clc@pelayes-yu.com
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17
BY ELECTRONIC TRANSMISSION - Pursuant to Cal. Rules of Court, Emergency rule 12,
18 I transmitted a PDF version of this document by electronic mail to the persons at the addresses
listed above using the e-mail address(es) indicated. The service transmission was reported as
19 complete, and a copy of Receipt/Confirmation Page will be maintained with the original
20 document in this office.

21 (State) I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
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Executed on September 15, 2021, at Los Angeles, CA.
23
Sherry Smith
24 Printed Name Signature
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3 NOTICE OF TAKING DEPO OF MACK MARTIN