Motion,Ex Parte: LUKMAN DOTSON ET AL VS. EUROMOTORS, INC. ET AL

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                                1     BREE A. ULLMAN,            SBN 288764
                      LAW OFFICE OF BREE A               ULLMAN
                2     1054 Keith Avenue
                      Berkeley, California 94708                                                                 ELECTRONICALLY
                      Tele12hone: (425)    318-0708
                3
                      Email: bree.esq@gmail.com                                                                     F  I  L   E  D
                                                                                                                 Superior Court of California,
                4                                                                                                 County of San Francisco
                      HUNTER PYLE, SBN 191125
                      TANYA TAMBLING,               SBN 262979                                                       08/12/2022
                5                                                                                                Clerk of the Court
                      JOHN J. DARIN.SBN 323730                                                                     BY: RONNIE OTERO
                6     ANDREA        A. NUNEZ,      SBN 340062                                                                 Deputy Clerk
                      HUNTER PYLE LAW
                      505 14th Street, Suite 600
                7     Oakland, California 94612
                      Telephone:    (510) 444-4400
                8     Facsimile: (510) 444-4410
                      Email: hunter@hunterpylelaw.com
                9              jdarin@hunterpylelaw.com
               10     Attorneys for Plaintiffs
              11                      IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
               12                                   FOR THE COUNTY OF SAN FRANCISCO
              13
                     LUKMAN DOTSON; ADEAJAI DOTSON; and                             Case No. CGC-20-587463
                     ALI HABIBVAND,
              15                                                                    DECLARATION OF ANNE VODE IN
                                                     Plaintiffs,                    SUPPORT OF PLAINTIFFS' MOTION
               16     vs.                                                           TO CONTINUE TRIAL

                     EUROMOTORS,           INC. DBA MERCEDES-                        Date:         ,September 6, 2022
                     BENZ OF SAN FRANCISCO, a California                             Time:          9:30 a.m.
               18
                     corporation; DARIN        SPARROW, an individual;               Dept:          206
                     and DOES 1-20, inclusive,                                       Judge:        Hon. Samuel K. Feng
               20                                                                    Action Filed:           November 3, 2020
                              Defendants.
              21                                                                     Trial Date:             September     7, 2022

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                        DECLARATION OF ANNE VODE IN SUPPORT OF PLAINTIFFS' MOTION TO CONTINUE TRIAL
                 1   I, Anne Vode, declare      as follows:

                 2            1.       I am a licensed    California   Private  Investigator,  license  number    PI 12115.    My

                 3   business address    is Mercury    Investigations,   P.O. Box 3031,      Antioch,   CA 94531,    phone    number

                 4   (510) 268-9810.     I have had    my private investigator's license in good standing         continuously    since

                 5   March    3, 1987. I am also currently     a Contra   Costa Licensed     Process Server     No. 1043. I have been

                 6   a registered   process server   in California   in good standing     for over 33 years.

                 7            2.       I submit   this declaration   in support  of the Motion     to Continue   Trial filed herewith

                 8   by Plaintiffs Lukman      Dotson, Adeajai     Dotson, and Ali Habibvand        ("Plaintiffs").  I have personal     ·

                 9   knowledge     of the facts set forth   in this declaration   and could and would testify      competently     to

               10   them.

               11             3.       Since  June of 2022,    Mercury    Investigations    has been retained    ten times   by Hunter

               12   Pyle Law, co-counsel       along  with the law office ofBree A. Ullman          for Plaintiffs in the above-

               13    captioned   action, to serve deposition     notices and subpoenas      on  various third-party    witnesses.   My

               14    services  have included    searching    for these  witnesses'   addresses,  running    plate searches on parkvd

               15    vehicles to confirm    the correct   addresses,  attempting    service  on the witnesses    personally, enlisted

               16    process servers to attempt     service on the process servers where geographic           restrictions  rendered

               17    service  by me impractical,     and reporting   back to Hunter Pyle      Law where service      has proved
               18    unsuccessful.

               19             4.       During   this time,  Mercury    Investigations   has successfully    served the following

               20    third-party witnesses:    Rick   Brenner, Koorosh      Ghahremani,     Vivian   Fei, Sarn1ad He1mez, John
               21    Boggs, and Jordan      Taylor.

               22             5.       Mercury    Investigations   has been unable t