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Jake Wallace, Qui Tam Plaintiff Qui Tam Plaintiff Exempt from The California Judicial Council
Wallace, Qui Tam, Plaintiff, V. Defendants, Yolo County Supervisor(s):Mike Mc Gowan; Duane Chamberlain; Mariko Yomada; Frank Sieferman; Helen Thompson. County Council: Case No: CV06-581 Declaration in Support of Motion for Coordination California Code of Civil Procedure 404
Jake Wallace, Qui Tam, Plaintiff v. Defendants, Calaveras Board of Supervisors; Merita Callway; Victoria Erickson; Tom Tryon; Bill Claudino: Probation Officers; Teri Hall; Alan Sullivan; Rich Manders: County Council James Jones: Asst. County Council David Sirias: District Attorney Jeff Tuttle: Sheriff Dennis Downum Case No.: CV 32550
Declaration in Support of Motion for CoordinationTO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: I, Jake Wallace, declare and state as follows; I am the Qui Tam Plaintiff, representing "All Parties Plaintiff". On April 5, 2006 I filed a California False Claims Act suit against the defendants whose principal office is located in San Andreas, California. On April 13, 2005 I filed a California False Claims Act (FCA) suit against the defendants whose principal office is located in Woodland, California. These two FCA suits were filed in two California counties as the Qui Tam Plaintiff with mistake or excusable neglect understood at that time that when filing under the California False Claims Act, that cases located in different counties required two separate claims. Qui Tam Plaintiff has concluded that coordination set forth in California Code of Civil Procedure Section 404 is appropriate as (1) the common question of fact and law predominates; (2) the common question of fact or law is significant in all of the actions to be coordinated; (3) one judge hearing all the actions for all purposes in a selected site will promote the ends of justice, preserve the convenience of the parties and witnesses, advance the efficient use of judicial resources, avoid inconsistent rulings, and increase the likelihood of settlement. There will be no significant delay. I know of no prejudice to any party as a result of granting consolidation set forth in California Code of Civil Procedure Section 404. This declaration is made in good faith for the reasons set forth above and not for the purposes of delay. For the foregoing reasons, the declaring party, respectfully submits the "Declaration in Support of Motion for Coordination", to consolidate the Wallace v. Yolo and Wallace v. Calaveras. I declare under penalty of perjury that the foregoing is true and correct. Dated: June 27, 2006 _______________________ On Behalf of the State of California |