On February 05, 2020 a
Order to Show Cause
was filed
involving a dispute between
Law Offices Of Paul H. Nathan,
Sun, Helen,
and
Does 1 To 100,
Li, Weilin,
for PERSONAL INJURY/PROPERTY DAMAGE - VEHICLE RELATED
in the District Court of San Francisco County.
Preview
1 Michael A. Horowitz, Esq. (SBN 151239)
THE BARNES FIRM, L.C.
2 555 12th St., Suite 1470 ELECTRONICALLY
Oakland, CA 94607 F I L E D
3 Telephone: (800) 800-0000 Superior Court of California,
County of San Francisco
Facsimile: (888) 800-7050
4 Email: Michael.horowitz@thebarnesfirm.com 09/02/2021
Clerk of the Court
5 BY: CAROL BALISTRERI
Deputy Clerk
Attorney for Plaintiff:
6 HELEN SUN
7
8 SUPERIOR COURT FOR THE STATE OF CALIFORNIA
9 COUNTY OF SAN FRANCISCO
10
HELEN SUN, ) Case No.: CGC-20-582737
11 ) [Assigned to: Hon. Dept. ]
)
12 )
Plaintiff, ) ATTORNEY’S REPLY TO ORDER TO
13 ) SHOW CAUSE
vs. )
14 )
) DATE: 09/21/21
WEILIN LI and DOES 1 to 100, ) TIME: 10:30 AM
15
) DEPT. 610
16 Defendants. )
)
17 ) Complaint Filed: February 5, 2020
)
18 )
)
19
20 Comes now Michael A. Horowitz, attorney of record for plaintiff Zama Richard,
21 and responds to the Court’s Order to Show Cause as follows:
22 Arbitration has not been completed, despite the Court’s August deadline. The
23 Arbitration instead is scheduled for December 8 (9), a date which all parties and the
24 appointed arbitrator are available.
25 Your declarant apologies to the Court for not being more diligent in scheduling
26 the hearing sooner.
27 //
28 //
1
ATTORNEY’S DECLARATION RE: OSC
1 It is respectfully requested that no sanctions, including specifically terminating
2 sanctions, be issued against your declarant or against plaintiff, as the case presents
3 significant damages.
4 I declare under penalty of perjury under the laws of California that the foregoing
5 is true and accurate.
6
7 Dated: September 2, 2021 THE BARNES FIRM, L.C.
8
9 By: ___________________________
Michael A. Horowitz, Esq.
10 Attorneys for Plaintiff
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ATTORNEY’S DECLARATION RE: OSC
1 PROOF OF SERVICE
I am employed in the County of Alameda, State of California. I am over the age of 18 and not
2 a party to the within action. My business address is 555 12 th St., Suite 1470, Oakland, California
94607. On the date specified below, I served the foregoing documents described as
3
4 ATTORNEY’S REPLY TO ORDER TO SHOW CAUSE
5 on the interested parties in this action by placing a true copy thereof enclosed in a sealed
envelope addressed as follows:
6
James R. Picker, Esq.
7
PHILIP M. ANDERSEN & ASSOCIATES
8 4450 Rosewood Drive, Suite 450
Pleasanton, CA 94588
9 Phone: (925) 225-6838
Fax: (855) 732-9437
10 Email: james.picker@statefarm.com
11 Email: cali.law-pleasanton-service.081o02@statefarm.com
Attorneys for Defendant, WEILIN LI
12
[X] ONLY BY ELECTRONIC TRANSMISSION. By e-mailing the document(s) to the
13 persons at the e-mail address(es) listed above pursuant to California Code of Civil
Procedure section 1010.6 (e) (1). No electronic message or other indication that the
14
transmission was unsuccessful was received within a reasonable time after the
15 transmission.
16 [ ] PERSONAL: I caused such envelope to be delivered by hand to the office of the
addressee pursuant to C.C.P. § 1011.
17
18 [ ] VIA OVERNIGHT MAIL: I caused such envelope to be delivered by hand to the office of
the addressee in an overnight delivery package pursuant to C.C.P. §1013 (c).
19
[ ] VIA FACSIMILE: I caused such document to be transmitted to the facsimile machine of the
20 addressee pursuant to C.C.P. § 1013 (e). Said document was transmitted from
The Barnes Firm, L. C., in Oakland, California, on the date as set forth herein.
21
I declare under penalty of perjury under the laws of California that the above is true and correct.
22
Executed on September 2, 2021, at Oakland, California.
23
_________________________
24 MICHELLE M. MILLER
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_____________________________________________________________________________________________________
PROOF OF SERVICE
Document Filed Date
September 02, 2021
Case Filing Date
February 05, 2020
Category
PERSONAL INJURY/PROPERTY DAMAGE - VEHICLE RELATED
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1 Michael A. Horowitz, Esq. (SBN 151239) THE BARNES FIRM, L.C. 2 555 12th St., Suite 1470 ELECTRONICALLY Oakland, CA 94607 F I L E D 3 Telephone: (800) 800-0000 Superior Court of California, County of San Francisco Facsimile: (888) 800-7050 4 Email: Michael.horowitz@thebarnesfirm.com 09/02/2021 Clerk of the Court 5 BY: CAROL BALISTRERI Deputy Clerk Attorney for Plaintiff: 6 HELEN SUN 7 8 SUPERIOR COURT FOR THE STATE OF CALIFORNIA 9 COUNTY OF SAN FRANCISCO 10 HELEN SUN, ) Case No.: CGC-20-582737 11 ) [Assigned to: Hon. Dept. ] ) 12 ) Plaintiff, ) ATTORNEY’S REPLY TO ORDER TO 13 ) SHOW CAUSE vs. ) 14 ) ) DATE: 09/21/21 WEILIN LI and DOES 1 to 100, ) TIME: 10:30 AM 15 ) DEPT. 610 16 Defendants. ) ) 17 ) Complaint Filed: February 5, 2020 ) 18 ) ) 19 20 Comes now Michael A. Horowitz, attorney of record for plaintiff Zama Richard, 21 and responds to the Court’s Order to Show Cause as follows: 22 Arbitration has not been completed, despite the Court’s August deadline. The 23 Arbitration instead is scheduled for December 8 (9), a date which all parties and the 24 appointed arbitrator are available. 25 Your declarant apologies to the Court for not being more diligent in scheduling 26 the hearing sooner. 27 // 28 // 1 ATTORNEY’S DECLARATION RE: OSC 1 It is respectfully requested that no sanctions, including specifically terminating 2 sanctions, be issued against your declarant or against plaintiff, as the case presents 3 significant damages. 4 I declare under penalty of perjury under the laws of California that the foregoing 5 is true and accurate. 6 7 Dated: September 2, 2021 THE BARNES FIRM, L.C. 8 9 By: ___________________________ Michael A. Horowitz, Esq. 10 Attorneys for Plaintiff 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 ATTORNEY’S DECLARATION RE: OSC 1 PROOF OF SERVICE I am employed in the County of Alameda, State of California. I am over the age of 18 and not 2 a party to the within action. My business address is 555 12 th St., Suite 1470, Oakland, California 94607. On the date specified below, I served the foregoing documents described as 3 4 ATTORNEY’S REPLY TO ORDER TO SHOW CAUSE 5 on the interested parties in this action by placing a true copy thereof enclosed in a sealed envelope addressed as follows: 6 James R. Picker, Esq. 7 PHILIP M. ANDERSEN & ASSOCIATES 8 4450 Rosewood Drive, Suite 450 Pleasanton, CA 94588 9 Phone: (925) 225-6838 Fax: (855) 732-9437 10 Email: james.picker@statefarm.com 11 Email: cali.law-pleasanton-service.081o02@statefarm.com Attorneys for Defendant, WEILIN LI 12 [X] ONLY BY ELECTRONIC TRANSMISSION. By e-mailing the document(s) to the 13 persons at the e-mail address(es) listed above pursuant to California Code of Civil Procedure section 1010.6 (e) (1). No electronic message or other indication that the 14 transmission was unsuccessful was received within a reasonable time after the 15 transmission. 16 [ ] PERSONAL: I caused such envelope to be delivered by hand to the office of the addressee pursuant to C.C.P. § 1011. 17 18 [ ] VIA OVERNIGHT MAIL: I caused such envelope to be delivered by hand to the office of the addressee in an overnight delivery package pursuant to C.C.P. §1013 (c). 19 [ ] VIA FACSIMILE: I caused such document to be transmitted to the facsimile machine of the 20 addressee pursuant to C.C.P. § 1013 (e). Said document was transmitted from The Barnes Firm, L. C., in Oakland, California, on the date as set forth herein. 21 I declare under penalty of perjury under the laws of California that the above is true and correct. 22 Executed on September 2, 2021, at Oakland, California. 23 _________________________ 24 MICHELLE M. MILLER 25 26 27 28 1 _____________________________________________________________________________________________________ PROOF OF SERVICE