LAW OFF ICES Of
`WALKUP, MELODIA, KELLY £2. SCHOENBERGER
`A PROFESSKNVM CORPORAHON
`650 CALIFORNIA STREET, 26““ FLOOR
`SANFRANCISCO,CAL1FORN:A 941082615
`T; <41 5) 981—7210 . F; <41 5) 391—6965
`
`F I L ED
`
`8AM Mange) QOUNTY
`MAR 2 6 2039
`
`MATTHEW D. DAVIS (State Bar #141986)
`mdavi$@walkup1awoffice.Com
`SPENCER J. PAHLKE (State Bar #250914)
`spahlke@walkup1awoffice .com
`ATTORNEYS FOR PLAINTIFFS
`BRICEIDA LOPEZ AND JOSE SOLIS
`SUPERIOR COURT OF THE STATE OF CALIFORNIA
`COUNTY OF SAN MATEO
`
`BRICEIDA LOPEZ, an individual, JOSE
`SOLIS, an individual,
`
`Plaintiffs,
`
`V.
`PAUL BONIFACIO, an individual,
`MARGARET HYUN, an individual,
`AMERIGAS PROPANE, L.P., a business
`entity, AMERIGAS PROPANE, INC, a
`corporation, AMERIGAS, INC, a
`corporation, and DOES ONE through
`ONE-HUNDRED, inclusive,
`Defendants.
`
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`Case No. 18CIV01696
`DECLARATION 0F MATTHEW D.
`DAVIS IN SUPPORT OF PLAINTIFF
`BRICEIDA LOPEZ’S MOTION TO
`COMPEL DEFENDANT AMERIGAS
`PROPANE, LP. TO PROVIDE
`SUPPLEMENTAL RESPONSES TO
`PLAINTIFF’S SPECIAL
`INTERROGATORIES, SET ONE (1)
`9/ 5/ l?
`Date:
`Time:
`9:00 a.m.
`Dept; Law & Motion
`Filed Concurrently With NOTICE OF
`MOTION AND MOTION; MP&A ISO
`MOTION; SEPARATE STATEMENT
`ISO MOTION; ISO MOTION;
`PROPOSED ORDER; AND PROOF 0F
`SERVICE
`Action Filed:
`Trial Date:
`
`April 6, 2018
`November 18. 2019
`
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`
`1.
`
`I, Matthew D. Davis, declare as follows:
`I am an attm‘ney duly admitted t0 practice before this Court and all
`courtS in the State 0f California. I am a partner With Walkup, Melodia, Kelly &
`Schoenberger, attorneys 0f record for plaintiffs Briceida Lopez and Jose Solis. Except
`
`1
`DECLARATION OF MATTHEW D. DAVIS IN SUPPORT OF PLAINTIFF’S MOTION TO COMPEL
`FURTHER RESPONSES TO SPECIAL INTERROGATORIES - CASE NO. 1803701696
`
`28
`LAW {)FHCFS OF
`WAI‘KUZ“, MELODW KELLY
`G: SCHOENBERGER
`A "KW V ““ka (,ORPOKA Ht)?»
`650 CA1 IFORNIA STMET
`ZHH HOUR
`SAN FRANC‘SCO, CA 94108
`(1H3) 9814‘? IO
`
`

`

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`as t0 matters stated 0n information and belief, I have personal knowledge 0f the facts
`set forth herein, and if called as a Witness, I could and would competently testify
`thereto. AS t0 matters states 0n information and belief, I have good faith, fact-based
`reasons for believing them t0 be true. I make this declaration in support 0f plaintiff
`Briceida Lopez’s Motions T0 Compel And For Sanctions Against Defendant AmeriGas
`Propane LP.
`
`I am the lead attorney 0n this matter. In the course 0f our firm’s
`2.
`investigation and during this litigation, I have reviewed numerous documents,
`including the reports 0f the investigation of the fire that gives rise t0 this lawsuit and
`that were prepared by the Placer County Sheriffs Department, the North Tahoe Fire
`Protection District, and the Squaw Valley Fire Department. Those voluminous
`documents state that the fire that gives rise t0 this lawsuit happened at a vacation
`home located at 1509 Christy Lane in Squaw Valley, Placer County, California. The
`documents state that the fire occurred during a period 0f heavy snow and started at
`about 7:09 p.m. 0n March 17, 2018. The investigators concluded that the fire was
`caused when leaked propane gas ignited as plaintiffs were cleaning the home. None
`0f the defendants have disputed these basic facts. Fire investigators also concluded
`that the propane leaked from cracks in pipes in the propane delivery system just
`outside the south wall 0f the house. Attached hereto as Exhibit 1 is a true and
`correct copy 0f one such report, prepared by members 0f the Sheriffs Department,
`that reached that conclusion.
`Defendant AmeriGas Propane, L.P. (hereafter, “AmeriGaS”) has
`8.
`admitted that it supplied propane t0 the Christy Lane house before the fire, including
`a delivery 0n January 12, 2018. Attached hereto as Exhibit 2 is a true and correct
`copy 0f AmeriGas’s responses t0 plaintiff Briceida Lopez’s first set of special
`interrogatories, and it makes these admigsions in response t0 interrogatories nos. 1
`and 2.
`
`28
`LAW OFFKCES OF
`WALKUP, MELODIA, KELLY
`8L SCHOENBERGER
`mmomsmmx (,Ukmkmmx
`650 CALIFORNIA S TRtH
`26‘YH FLOOR
`SAN FRANCXSCO) CA 94108
`(615} 981 ‘7210
`
`2
`DECLARATION OF MATTHEW D. DAVIS IN SUPPORT OF PLAINTIFF’S MOTION TO COMPEL
`FURTHER RESPONSES TO SPECIAL INTERROGATORIES - CASE NO. 18CIV01696
`
`

`

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`Defendants Paul Bonifacio and Margaret Huyn owned the Christy Lane
`4.
`home at the time 0f the fire (I Visited the site in the fall of 2018 and observed that the
`fire completely destroyed the home). They are residents 0f San Mateo County and
`they are not parties t0 these motions.
`I have reviewed thousands 0f pages 0f medical records for my clients
`5.
`Briceida Lopez and Jose Solis. I have also met with them in person 0n at least four
`occasions. I have also had a professional photographer take photographs 0f their burn
`injuries. Those photographs and the medical records have all been produced t0 the
`defendants, including AmeriGas Propane, L.P. I have also consulted with medical
`experts who have evaluated my clients’ injuries. Based 0n all 0f this, I am informed
`and believe that Ms. Lopez suffered “full thickness” third degree burns t0 70% 0f the
`skin 0n her body, including her entire face, and that Mr. Solis suffered third degree
`burns to about 25% 0f the skin 0n his body. Both plaintiffs underwent numerous
`surgeries and medical procedures, including extensive skin graft procedures and both
`have disfiguring scars. Ms. Lopez developed severe infections during her acute
`recovery and doctors told her family that she would not likely survive, but she did.
`N0 defendant hag queStioned the severity and life-long nature 0f plaintiffs’ injuries. If
`there is any question about the horrific nature 0f plaintiffs’ injuries, I can submit
`current photographs 0f the plaintiffs either under seal 01' for an in camera review.
`I searched the internet and located web pages and websites associated
`6.
`With defendant AmeriGas Propane, L.P. and its parent and affiliated companies,
`including co-defendants AmeriGas, Inc. and AmeriGas Propane, Inc. Attached hereto
`as Exhibit 3 is a true and correct copy of Such a webpage that I Viewed and printed
`as a PDF file 0n March 18, 2019. The webpage states in part: “We are the nation’s
`largeSt retail propane marketer, serving approximately 1.8 million customers in all
`50 states from approximately 1,900 distribution locations. We conduct our business
`principally through our subsidiary AmeriGas Propane, LP.”
`
`28
`LAW O¥FGCES OF
`WALKUP, MELODW KELLY
`8L SCHDENBERGER
`A PRO: t swams, (inkmkm u A
`650 CALIFORNM STREET
`26TH FLOOR
`SAN FRANCISCO, CA 94108
`(415} 981 7210
`
`3
`DECLARATION OF MATTHEW D. DAVIS IN SUPPORT OF PLAINTIFF’S MOTION TO COMPEL
`FURTHER RESPONSES TO SPECIAL INTERROGATORIES - CASE NO. 18CIV01696
`
`

`

`A true and COTrect copy 0f the operative complaint in this case, filed 0n
`7.
`September 20, 2018, an “amended complaint for damages,” is attached hereto as
`Exhibit 4. The complaint alleges that AmeriGas repeatedly violated Placer County’s
`propane safety ordinance. That ordinance mandated that residential propane
`systems in high snowfall areas, such as the subject vacation house, meet certain
`safety standards that are intended t0 prevent cracked pipes and dangerous propane
`leaks. The ordinance also mandated that propane vendors, such as AmeriGas, inspect
`residential propane systems 0n an annual basis t0 ensure that they meet the high
`snowfall safety standards. The ordinance makes it illegal for a propane vendor t0
`supply propane t0 a home if that residence’s propane system does not meet the
`ordinance’s high snowfall safety standards. The complaint alleges that the propane
`system at the vacation house violated the ordinance’s safety standards, that
`AmeriGas never inSpected the house’s propane system, and that AmeriGas instead
`repeatedly delivered propane t0 the house. The complaint alleges that AmeriGaS’S
`Violations 0f the ordinance were a substantial factor in causing the cracked pipes, the
`propane leak, the resulting fire and plaintiffs’ injuries, and that AmeriGas faces
`negligence per se liability. Exhibit 4 at 1N 13-15, 37-89.)
`On November 28, 2018, my firm served by mail 0n AmeriGas 26 Special
`8.
`interrogatories, first set, propounded by plaintiff Briceida Lopez. A true and correct
`copy 0f these interrogatories is attached as Exhibit 2. Based 0n the deadline set
`forth in the Civil Discovery Act, AmeriGas’s reSponses were due by January 2, 2019.
`(COP § 2030.260.)
`AmeriGas did not timely respond t0 either the special interrogatories 0r
`9.
`the document requests. I notified Keith Gillette, counsel for AmeriGas, that
`AmeriGaS had failed t0 respond t0 the discovery. I sent a number 0f emails t0 Mr.
`Gillette and had several conversations, during which I implored and insisted that
`AmeriGras produce documents and respond to the discovery as soon as possible. I
`emphasized that this was only the first wave 0f discovery, that plaintiffs needed the
`4
`DECLARATION OF MATTHEW D. DAVIS IN SUPPORT OF PLAINTIFF’S MOTION TO COMPEL
`FURTHER RESPONSES TO SPECIAL INTERROGATORIES - CASE NO. 18CIV01696
`
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`28
`LAW OFFICES OF
`WALKUP, MELODIA, KELLY
`81 SCHOENBERGER
`Amumewmm (,oRmm/xnox
`650 CAL IFORNIA STREET
`2 'I'H H OR
`6
`SAN FRANCISCO, CA 94308
`MIS) 98} 7210
`
`

`

`responses and documents before it could Send the next wave of discovery and take
`depositions, and that the parties had a November 19, 2019 trial date. I fairly and
`accurately recounted these communications in the meet-and-confer letter that I sent
`to Mr. Gillette 0n March ’7, 2019, a true and correct copy 0f which is attached hereto
`as Exhibit 6.
`On March 4, 2019, AmeriGaS served responses t0 Lopez’s first set 0f
`10.
`Special interrogatories, a true and correct copy 0f Which are attached hereto as
`Exhibit 5.
`Upon reviewing AmeriGaS’s responses t0 the document requessts, I
`11.
`immediately notified Mr. Gillette that I was extremely disappointed in the responses.
`I followed that up With a detailed letter 0n March 7, 2019, which is Exhibit 6. Given
`the extreme delay in the responses, the serious deficiencies, and the prejudice t0
`plaintiffs With resspect t0 preparing for a November trial, my letter demanded that
`AmeriGas agree by March 12 t0 provide the amended reSponses requested, and t0
`produce the amended responses and documentg by March 18, 2019. AmeriGas’s
`counsel did not timely respond t0 the meet-and-confer letter. Instead, on March 18,
`AmeriGas’s counsel sent a 0ne~paragraph email Stating, “We will provide our
`responge [t0 the letter] Within the next week.” A true and correct copy 0f that email is
`attached hereto as Exhibit 7. AS 0f the filing 0f this motion, AmeriGas has neither
`provided supplemental re$p0nSes nor produced additional documents.
`T0 date, AmeriGas has produced less than 150 pages 0f documents.
`12.
`AmeriGas produced hard copies only. The pmduction has been haphazard and
`unorganized. AmeriGas has only Bate stamped some documents. Some pages are
`illegible. AmeriGas produced no ESI in its native format, but did produce What
`appear t0 be printouts 0f screen shots. AmeriGas’s production dees not include a
`Single guideline, policy 0r procedure. AmeriGas neither produced the documents as
`they are kept in the course 0f business nor labeled them t0 correspond t0 a demand.
`I declare under penaity 0f perjury under the laws 0f the State 0f Califarnia
`5
`DECLARATION OF MATTHEW D. DAVIS IN SUPPORT OF PLAINTIFF’S MOTION TO COMPEL
`FURTHER RESPONSES TO SPECIAL INTERROGATORIES - CASE NO. 18CIV01696
`
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`28
`LAW OFHCM Of
`WALKUP, MELODW KELLY
`& SCHOENBERGER
`A Pkwiéwc mm mkwflmmm
`650 CAHHRNM SIREN
`26W! FL O
`SAN FRANCISCO, CA 94108
`(415)981-HID
`
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`

`that the foregoing is true and correct.
`Executed 0n this 25th day 0f March, 2019, at San Francisco, California.
`
`Matthew D. Davis
`
`1
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`QCDN)
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`LAW cwwct‘s 0r
`WALKUP, Mmovm, KELLY
`81 SCHQENBERGER
`”XEK‘ézgfélgfifivéxéET
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`(116)981-7710
`
`6
`DECLARATION OF MATTHEW D. DAVIS IN SUPPORT OF PLAINTIFF’S MOTION TO COMPEL
`FURTHER RESPONSES TO SPECIAL INTERROGATORIES - CASE NO. 1801\701696
`
`

`

`EXHIBIT 1
`
`

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`O3~22-”l8 10:12 FROM”
`PLACER COL
`GEO CGDE
`Squaw Valley
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`T-848
`P001 0/0015 F~238
`'Y SHERIFF I CORONERI MA! -_.1AL'$ UI'HU:
`NARRATIVE REPORT
`} omeaL {X} suppLEMEMM-‘w
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`801 845004
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`fire.
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`03-17.48
`2100 hours
`l received a cat! from Sgt Hunt advising that Squaw Valley Fire was investigating a
`residential fire in Squaw Vaney which involved one mam and one female victim.
`Sgt Hunt stated both were transported to Renown Hospitat m Reno NV the female
`taken by CareFiight
`t responded to Renown Hospital and contacted th‘e staff in regards to the victims of the
`fl
`Was. advised that (V1) Jose Satis was in blue room 17 and (V2) Bricedia Lopez was in
`red mom 16.
`i waa taken ta Bricedia's room first and spake to hex; critical care nurse. The nurse
`canfirmed Bricedia was the female ,invoiva in the rasidential fire in Squaw Vatley and stated
`she had been transported by CareFtht to Renown
`lwas told Brioedia was heavily sedated due to severe bums on approximately 70% of
`her body.
`tobtserved Bricedia lying supine cn‘ a haspital he‘d with breathing fubea in har mauth
`and nase. Brice’dia was ccmpleteiy covered in btankets from her neck to her feet, with only
`her head being exposed;
`BrE‘cadia s face was swoflan with b isters btackened skin and several amass of missing
`skin due to bums Bricedfa s ayebrdws were s nged almost comptetety aft“ aiong with her hair
`line being burnt as well.
`
`’
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`
`Rapaned 3y; Detective Frykbarg #63
`03/20118
`Date:
`
`Fags 1
`
`Approved By: .
`
`

`

`POOH/OO’IS F488
`03-22—’18 10:13 FROM—
`T-948
`PLACER COL... :‘Y SHERIFF I CORONER I MArwdAL's UI—Hur;
`NARRATIVE REPORT
`REPom uumaen
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`‘ Squaw Vailey
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`
`The nurse requested the Spanish translator present at the time of intake to return to the
`ro'om to assist me with any questions
`The translator Jackie stated Bricedia was somewhat cohereht when she arrived and
`was telling Jackie what happened
`,hBricadia said she was cleaning a house with her husband when she smelied something
`funny coming from the dryer She asked her husband to come look at it and when he opened
`the dryer it exmoded.
`Not much information was obtained due to her treatment.
`l then responded to Jose‘s room and through a virtual .transtator he told me the
`following:
`
`Jose stated he and his wife, Bridedia wens cleaning a house in Squaw Valley
`Jose did not know the address but said they were doing it for a friend because she was
`out oftown
`He recalied getting‘to the 'hodse and that Bricedia was downstairs doing laundly.
`He said she called him down baoause she smelled something funny and wanted him fa
`look at 1!.
`Jose went dawn stairs and he also could smell something funny coming tram the
`washerand dryer area. Jase said he bent dawn ta look inside the dryer and when he
`opened it flames shot out.
`
`Roported By: Detective Frykberg #63
`03/26l18
`Data:
`
`Page 2
`
`Approved By:
`
`

`

`90012/0015 F-238
`T-948
`03-22-318 10:18 FROM—
`PLACER COL... .‘Y SHERIFF I CORONER I MAharlAL'S UI-HUI:
`NARRATIVE REPORT
`GEO CODE
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`1 ORIGINAL [X] suppLEMEmmv
`301 8-3004
`Squaw Valley
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`. Jose said he told his wife they needed to get out of the house and rémember
`running outside as fast as they could. Jaw said hejumped into the snowto stop the
`burning and was thmwing snow on Eficedia to stop her from burning.
`l relayed this information to Detective Lasagna, via can phone. whe was on scans 0f
`the fire. Detective Lasagna asked to speak to Jose. via speakgr phone. with some additiona!
`questions. See his report for further.
`{observed Jose with bandaging'on both of his hands. arms. his lower torso and both of
`his sides. Jose's entire head, and nose wereqcovared 'In bandages with enly his eyes and
`mouth showing. Josefs eyes were swoflen shut and his musiache and eyebrows were
`a severety singed.
`Matched as his nu‘rse applied more’ bandages to his back and ob3erved biisters,
`peeling and blackened skin on rims! of his back. I also obaerved his right upper leg to be
`bandaged with the rest of his lower extr'emfties covered with biankets.
`As l’ was concmding my interview, CareFiight arrived and I was told both Jose and
`Bricedia were being transported to UC Dave Burn Center for speciaiized treatment of their
`injuries.
`l spoke briefly to the social worker who stated she was able to cohtact Bricedia’s sister,
`Silvia. who‘lives in Truckee. She pmvided me with a contact number for Silvia 775-223-6391
`and said her address was 101 DO-Estates Dr #M10. Truckee, CA.
`t was advised Truckee Poiice De‘partment’ had contacted Silvia and she was on her way
`to UC Davés with a famiry friend and Bricedia's son.
`
`'
`
`Reported By: Detective Frykberg #63
`03I20I18
`fi Date;
`
`Page 3
`
`Approved By:
`
`

`

`03~22-’18 10:14 FROM—
`PLACER COI
`GEO CODE
`Squaw Valley-
`
`P0013/0075 F~238
`T~948
`FY SHERIFF I CORDNERI MAanAL'S UH‘IU;
`NARRATIVE REPORT
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`l attempted to get a physical address {oi Jose and Bricedia's address but was told they
`just moved to Truckee and it was only known they lived in Sierra Viilage.
`l received a phone call fmm Bricedia’s sister-in-law. Sandra who was very concerned
`about the condition of Bricedia and Jose She stated she was unable to get ahold of anyone
`concerning the iwo but was told by hospital staff she could ca" me with questions
`l told Sandra what had occurfed and stated they Were being transferred to UC Davis for
`fuflher treatment.
`l was aware of a silver Jeep Cherokee parked at the scene who we assumed belonged
`to the coupte and asked Sandra to confirm who it belonged to Sandra stated it was Jose s
`Jeep and that they owned a couple other vehiblés too but not one of them were witnessed at
`50$fie
`
`Phatos and interviews with Jose booked into evidence. See attached preperty record.
`Nothing Further.
`
`Rammed By: Detective Frykberg #63
`0312mm
`Date:
`
`Page 4
`
`r
`
`Approved By: Q.‘
`
`6
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`h PLAcaR COUNTY SHERiFF's'LDEPARTMENT nmmmm
`NARRATNE REPORT
`18’3”“:
`CCNHECTED REPORTS
`[ 103mm. REPORT [X] SUPPLEMENHRY '
`VICTIM:
`Lopez/Soiis
`
`'
`
`.
`
`CREME TYPE:
`AAA Squaw Valley Fire
`3/1 7/1 8 2100hrs
`I received a call from Def. Sgt. Hunt, asking if i would respond to the residence at 1509
`A Christy Ln‘ in Squaw Vaney to investigate a possibte suspicious fire at the residence. I
`learned that two house cieaners had been i’n the aforementioned residence when an
`explosion occurred inside while they were doing laundry.
`The Mo escaped the residence but had substantial burns covering their bodiefs. They
`were transported to Reno's Renown Hospitaf. Bet. Frykberg was in mute to the
`hospital to try and get a batter statement from the two individuals.
`I arrived on scene and was briefed by Fire Chief investigator Craig Harvey withv
`Truckee Fire and Fire Chief Allen Riley with Squaw Vaney Fire. They told me that they
`had gatten information from a neighbor, witness, to the east of the residence. The
`neighbor had smelled gas prior to the exptosion' and fire.
`The witness said renters at 1509 had left the “residence hours earlier andtha’t house
`cleaners had come to ctean the house when the explosion occurred. The witness was
`watching fireworks with his family from inside their rental home next door. The
`fireworks were going off from across the vauey at the Resort at Squaw Creek. They
`‘ thaard and exptasion that was not from the fireworks that sounded like it came from
`wast of them. They looked outside and saw flames shooting up from the hause next
`door
`‘ At this point in the investigation l found the residence was still on fire and too
`hazardous to enter. The plan with fire‘ peréonnel was to let the fire bum out to limit the
`possible fan Hazards of the two starry structure. The investigation would begin at first
`light in the morning when the fire was out. The investigation could better be done
`during daylight hours.
`
`1
`
`03-223 18 10:11 FROM—
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`T—848
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`P0008/0015 9288
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`Reporting Officer: J.Lasagna #31
`Date: 311 9’18
`
`'
`
`

`

`08-22-“28 10:11 FROM-
`P00077001?) F-238
`T 948
`PLACER COUNTY SHERIFF’S DEPARTMENT Rama? Human
`13‘3““ w
`NARRATNE REPORT
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`[ lomamm. REPORT [X] SUPPLEMENTARY
`came TYPE:
`warm;
`AAA Squaw Valley Fire
`Lobez/Solis
`A preiiminary look at the residence that evening indicated that an explosion occurred
`in the southwest corner of the residence. Entire window frames were blown out on the
`southwest comer and some were lying 15 yards from the structure in the snow
`Possible ignitinn points were found at the washer dryer and gas water heater I burner
`‘ for Jacuzzi In that end of the residence.
`Det Frykberg cal ed me from the hospital where she was with the male house cleaner
`Jose Alonzo Sofia Chief Harvey and I spoke to Frykberg and a Spanish translator who
`was with Jose via speaker phone. We asked Jose questions. We learned that Jose
`and Bricedia Lopez had arrived tb ciean 1509 Christy Ln sometime after 1700hrs.
`They were doing laundry and both went downstairs to a email area in the residence
`where the washer and dryer were located
`They couid smell a strange smeu 'at the dryer. Jose opened the dryer door to iook
`inside of it and see if he coutd figure out where the smefl was coming from At that
`point the axptosion occurrad and flames fined the small room Both Jose and Bricedia
`ran up the stairs from the room with their clothing on fire They ran outside and rotted m
`the snow to put out the flames They were then transported to the hospita!
`Bricedia was sedated and taro injured to speak with Frykberg.
`Both'Harvey and l believed the fire/explosion to be propane related due to the witness
`and victim’s statements. The area of the explosion was in the lowest point of the
`residence where propane might settle. Au of the homes in the area are on prapane gas
`systems. We adjourned for the evening and would meet back up at 063mm in the
`morning té begin further investigatians.
`
`0630hr5, 3/1 8/18
`Chief Harvey Had already found the propane tank undar a snow load before I arrived.
`He toid me that they had found no damage at the tank or regulator. We then began to
`fl o
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`Reporting Ofii r
`Date: 3."!
`3&6? ‘/
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`P0008/0015 F238
`O3~22~’18 10:11 FROM“-
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`183‘”
`NARRATIVE REPORT
`CONNECTEU REPORTS
`[ 1031mm. 35mm [X] surmmenmfiv
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`warm:
`AAA Squaw Vailev Fire
`LopezISolis
`investigate where the gas line came 'upefrom the ground on the south aide of the
`house. Wa amid tell that additional gas lines had run Up from the ground and had
`probably bean affixed ta the outside exterior of the structure with pipe ctamps. These
`lines were found on the ground at base of the‘foundation. The fines ran west toward
`the southwest corner of the residence. There was a metal snow shed box at a
`regulator. Evidence on the remaining southwest wail still standing indicated that the ~
`lines were affixed to the wall with pipe clamps a screws.
`
`[I
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`MetaISnow Shed CoverlAttachment Point on Wat!
`Pipe Ctamp Hanger a
`We uncovered debris from the lin'eg and foam! what appeared to be a pre fire break in
`the gas tine where it went down to a gaé vaive located on the south wall. This break
`appeared pre fire due t0 the fact that the pipe fitting was fitted with soot and ash, The
`meta! was charred and had no clean meta! "break that may have indicated a post fire
`break.
`
`Reporting Want: J.Laaagna #31
`Date: 3n9H 8
`
`

`

`9mm
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`T-848
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`08-223 '18 10:1 2 FROM-
`POOOQ/OO’I 5 Fm238
`PLACER coumv SHERIFF’S DEPARTMENT ammumn
`NARRATIVE REPORT
`18‘6”“
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`Lopaz/Sofis
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`CRIME WPE:
`AAA Squaw Vaflev Fire
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`I coutd find no indications ofifoutpiay 0r suspicious circumstances in rexation t0 the
`cauae of the fire; I; is beiieved that, the heavy snows that had accumutated over {ha
`past week had recenfly ahed from the metal roof cm the south side of the residence,
`shearing tha‘matal propane gas Rina“ The) 933 had pooiad in the lower muthwem
`comer area of the residence and the house cleahers causad an ignition gource when
`doing laundry which set Qfi the expiosion. '
`
`Reporting amcer: J.Lasagna #31
`Date: 3119118 ~
`
`

`

`03-22318 10:10 FROM~
`PLACER CCU
`GEO CODE
`T26
`
`.
`
`T-848
`P0003/0015 F—288
`Y SHERIFF l UURUNEK I MAL... IAL'fi UI'HUE
`NARRATWE REPORT
`REPOR? NUMBER
`1 SUPPLEMENTARV
`{X} ORIGINAL [
`3018-3004
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`NARRATNE
`On 03/17/2018 at approximately 1911 hours Deputy Prero and I were dispatched to 1509
`Christy Ln. Olympic Vailey CA regarding a reéidential strubture fire and possible explosion. It
`was unknown if the structure was occupied. We both responded code 3 and arrived 0n scene
`at 1915 hours. Upon my arrival, the residence was completeiy engulfed in flames. We were
`unable to approach the home to see if it was occupied due-to the extreme heat and flames. l
`updated P050 Dispatch with this information.
`Deputy Prero and I began evacuatingsurround residences in case the fire spread. AH houses
`immediately adjacent to the fire were either empty or we evacuated them. Fire personnel
`arrived on scene at 191 7 houra and we began assisting with hose deployment and road
`closures. Muttiple other PCSO deputies responded to assist with traffic control.
`I found a veniae‘ in the drivgway of the residence. (CA:5WQL988) and logged the reggstration
`information. It was later discovered that this vehicle betcng to (IP)SOLIS who was one of the
`people inside of the house when it exploded.
`“ Sgt. Bourassa responded to the scene and began coordinating law enforcement assistance to
`Cal Fire.
`Prior to PCSO arrivai, two people whq wake inside of the house when the house exploded
`extricated themseIVes and were later met by responding fire parsonnei. They were
`subsequantly transported by ambulance to a large parking lot at Squaw Valiey where they
`.w’ere‘ met by a Life Flight helicopter.
`The female subject who was inside of the house had suffered bums to most of her body and
`was unable to taik due to being in” shack. She was loaded onto the Life Flight Heficopter and
`flown to Renown Medical Center in Reno for treatment. Iwas unabie to obtain her information
`or a statement due to the emergency medical treatment she was receiving and due to her
`condition.
`The mate subject was being treated in the back of a North Lake Tahoe Ambulance, He aiso
`suffered extensive burning from the explosion, however not as severe as the femaie subject. t
`
`,
`
`\
`
`Reported By: B. Shaw #231
`03f1812018
`Date:
`
`-
`
`Page 1
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`y ApprovedBy2WfimV4 21m
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`~
`
`OB-22-‘18 10:10 FROM~
`. PLACER COL
`GEO CODE
`1'25
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`CRIME
`Amea Agency Aqsm- ea: Fire
`
`’
`
`T~948
`P0004/0015 F-238
`‘Y SHERIFF I UQRUNER'I MAIW.1AL'$ UH'IUE
`NARRATIVE REPQRT
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`Repeat numazn
`3018—3004
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`.was able to talk to him and identify him as (I‘P)SOLIS,‘ Jose. (IP)SOLIS appeared to be in
`severe pain, but provided me with a brief statement. He stated the foilowing in su‘mmary:
`T OF
`OLIS
`He wax at the residence to‘clean the house with the female subject. They are house cieaners
`and were hired by the owners of the residence to clean it. He was doing the laundry when he
`opened the dryer. When he opened the dryer, there was a largé expiosian. He was not sure
`what caused it. He did not notice anything suspicious or anything that would cause the
`explosion. '
`NARRATIVECQNL
`This was an “he was able to provide me prior to being transported by ambulance to Renown
`Medical Center in Reno.
`Sgt. Bourasaa contacted P080, Detectives and notified them 0f this incident. Members of the
`Detective Bureau rgsponded. Refer to their supptement for further.
`“Deputy Prero and I assisted with traffic cantrol until approximateiy 2230 hours.
`END OF REPORT
`
`.
`
`'
`
`Reported By: a. Shaw #231 '
`Date: osmalzow
`
`A
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`Page 2
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`‘
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`ApprovedBy:fiM5M “
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`ms suflmd as a mutt0mm expiosion. One‘onhe occubaaits stated that the explasiouand fire was accidental am:mm was
`suapioious. PCSO Detectives notified of this madam and they responded to the amt: and to the hospital to conduct
`P080 assisted with evacuation of nearby homes and traffic control throughout- the duration of this incident.
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`

`

`EXHIBIT 2
`
`

`

`lAW Offlflfi OT
`WALKUP, MELODIA, KELLY s: SCHOENBERGER
`A PROFESSDNM CORPORAUON
`650 CAUFORNIA STREET, 26'“ FLOOR
`SAN FRANCISCO, CALIFORNIA 94108-261 5
`T: (41 S) 981 ~72“) v F: (41S) 391~6965
`
`MATTHEW D. DAVIS (State Bar #141986)
`mdaviflwalkuplawoflicesom
`SPENCER J. PAHLKE (State Bar #250914)
`3 ahlke@walku lawoffice.com
`A&TORNEYS F0 PLAINTIFFS
`BRICEIDA LOPEZ AND JOSE SOLIS
`SUPERIOR COURT OF THE STATE 0F CALIFORNIA
`COUNTY OF SAN MATEO
`
`BRICEIDA LOPEZ, an individual, JOSE
`SOLIS, an individual,
`
`Plaintifl's,
`
`Case No. IBCIV01696
`PLAINTIFF BRICEIDA LOPEZ’S
`REQUEST FOR SPECIAL
`INTERROGATIRES T0
`DEFENDANT AMERIGAS
`PROPANE, LP, SET ONE
`Action Filed:
`April 6, 2018
`Unassigned
`Trial Date:
`
`v.
`V PAUL BONIFACIO, an individual,
`MARGARET HYUN, an individual,
`AMERIGAS PROPANE, L.P., a business
`entity, AMERIGAS PROPANE, INC, a
`corporation, AMERIGAS, INC, a
`oration, and DOES ONE through
`co
`O E-HUNDRED, inclusive,
`Defendants.
`PROPOUNDING PARTY: Plaintiff BRICEIDA LOPEZ
`RESPONDING PARTY:
`Defendant AMERIGAS PROPANE, LP
`SET NUMBER:
`One (1)
`The instructions of the Judicial Council form interrogatories are incorporated
`herein by reference.
`The definitions of the Judicial Council form interrogatories are incorporated
`herein by reference, to wit: INCIDENT; YOU 0R ANYONE ACTING ON YOUR
`BEHALF; PERSON; DOCUMENT; HEALTH CARE PROVIDER; ADDRESS.
`In addition, for purposes of this set of special interrogatories, the following
`1
`PLAINTIFF BRICEIDA LOPEZ'S REQUEST FOR SPECIAL INTERROGATIRES TO DEFENDANT
`AMERIGAS PROPANE, LP, SET ONE -