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Robert B, Mullen (State Bar No. 136346)
AT&T SERVICES, INC.-LEGAL DEPARTMENT
430 Bush St, 3" Floor
San Francisco, CA 94108 ELECTRONICALLY
robert.mullen@att.com FILED
Tel: (415) 268-9498 Superior Court of California,
Fax: (415) 543-0418 County of San Francisco
11/15/2018
David V. Roth (State Bar No. 194648) Clerk of the Court
BY: LESLIE GOMEZ
Deputy Clerk
dvr@manningllp.com
Emily I Ellse (State Bar No. 299579)
eie@manningllp.com
MANNING & KASS
ELLROD, RAMIREZ, TRESTER LLP
333 Bush Street, 27" Floor
San Francisco, California 94104
Tel: (415) 217-6990
Fax: (415) 217-6999
Attorneys for Defendant,
PACIFIC BELL TELEPHONE COMPANY dba
AT&T CALIFORNIA, erroneously sued as
AT&T Corp. (DOE 1) and AT&T Services, Inc.
(DOE 2)
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
KARA L. ESBORG, Case No. CGC-16-553614
Plaintiff, NOTICE OF ENTRY OF ORDER
v.
COMCAST CORP.; COMCAST OF
CALIFORNIA III, INC.; COMCAST CABLE
COMMUNICATIONS, LLC; WAVE
DIVISION HOLDINGS, LLC, ALEKSANDR
FRID & MARINA FRID, individually and as
trustees of their revocable trust; PAUL H. LUI
& KAMT. LUI, individually and as trustees of
their revocable trust; PAUL H. LUI & KAM
T. LUI, individually and as trustees of their
revocable trust; and DOES 1 to 100,
Defendants.
TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that on November 14, 2018 the Honorable Thomas Cohen,
Judge Pro Tem of the San Francisco County Superior Court entered an Order Granting Defendant
NOTICE OF ENTRY OF ORDERManninc& Kass
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Pacific Bell Telephone Company DBA AT&T California and AT&T Services' Motion to Compel
Responses to Request for Production of Documents.
A true and correct copy of the Order is attached hereto and made part hereof as Exhibit A.
DATED: November 14, 2018 MANNING & KASS
ELLROD, RAMIREZ, TRESTER LLP
By:
David V. Roth
Attorneys for Defendant,
PACIFIC BELL TELEPHONE COMPANY dba
AT&T CALIFORNIA, erroneously sued as AT&T
Corp. (DOE 1) and AT&T Services, Inc. (DOE 2)
2
NOTICE OF ENTRY OF ORDERAnne toe
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PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF SAN FRANCISCO
At the time of service, I was over 18 years of age and not a party to this action. I am
employed in the County of San Francisco, State of California. My business address is One
California Street, Suite 900, San Francisco, CA 94111.
On November 15, 2018, I served true copies of the following document(s) described as
NOTICE OF ENTRY OF ORDER on the interested parties in this action as follows:
SEE ATTACHED SERVICE LIST
BY ELECTRONIC SERVICE: | electronically served the document(s) described above
via File & ServeXpress, on the recipients designated on the Transaction Receipt located on the
File & ServeXPress website (https://secure. fileandservexpress.com) pursuant to the Court Order
establishing the case website and authorizing service of documents.
BY MAIL: I enclosed the document(s) in a sealed envelope or package addressed to the
persons at the addresses listed in the Service List and placed the envelope for collection and
mailing, following our ordinary business practices. I am readily familiar with the practice of
Manning & Kass, Ellrod, Ramirez, Trester LLP for collecting and processing correspondence for
mailing. On the same day that correspondence is placed for collection and mailing, it is deposited
in the ordinary course of business with the United States Postal Service, in a sealed envelope with
postage fully prepaid. I am a resident or employed in the county where the mailing occurred. The
envelope was placed in the mail at San Francisco, California.
I declare under penalty of perjury under the laws o ate.of California that the
foregoing is true and correct.
Executed on November 15, 2018, at San Fra
3
NOTICE OF ENTRY OF ORDEREXHIBIT AManninc& Kass
Extrop, RAMIREZ, TRESTER wr
aarovon La
Robert B. Mullen (State Bar No. 136346)
E D
AT&T SERVICES, INC.-LEGAL DEPARTMENT subecot ca dratlria
430 Bush St, 3" Floor
San Francisco, CA 94108
robert.mullen@att.com
Tel: (415) 268-9498
Fax: (415) 543-0418
David V. Roth (State Bar No. 194648)
dvr@manningllp.com
Emily I Ellse (State Bar No. 299579)
eie@manningllp.com
Mark R. Wilson (State Bar No. 293474)
mxw@manningllp.com
MANNING & KASS
ELLROD, RAMIREZ, TRESTER LLP
1 California Street, Suite 900
San Francisco, California 94111
Tel: (415) 217-6990
Fax: (415) 217-6999
Attorneys for Defendant,
PACIFIC BELL TELEPHONE COMPANY dba
AT&T CALIFORNIA, erroneously sued as
AT&T Corp. (DOE 1) and AT&T Services, Inc.
(DOE 2)
NOV 14 2018
CLERK OF THE COURT
BY: LINDA FO
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
KARA L. ESBORG,
Plaintiff,
v.
COMCAST CORP.; COMCAST OF
CALIFORNIA III, INC.; COMCAST CABLE
COMMUNICATIONS, LLC; WAVE
DIVISION HOLDINGS, LLC; ALEKSANDR
FRID & MARINA FRID, individually and as
trustees of their revocable trust, PAUL H. LUI
& KAM T. LUI, individually and as trustees of
their revocable trust, PAUL H. LUI & KAM
T. LUI, individually and as trustees of their
revocable trust; and DOES 1 to 100,
Defendants.
Case No. CGC-16-553614
|] ORDER GRANTING
DEFENDANT PACIFIC BELL
TELEPHONE COMPANY DBA AT&T
CALIFORNIA AND AT&T SERVICES'
MOTION TO COMPEL RESPONSES TO
REQUEST FOR PRODUCTION OF
DOCUMENTS AND REQUEST FOR
SANCTIONS
DISCOVERY
Hearing Date: November 14, 2018
Time: 9:00 a.m.
Dept.: 302
Defendants PACIFIC BELL TELEPHONE COMPANY dba AT&T CALIFORNIA and
AT&T SERVICES, INC.'s motion to compel responses to request for production of documents came
4810-5546-9434.1
(PROEPOSED] ORDER GRANTING MOTION TO COMPEL AND REQUEST FOR SANCTIONSManninc& Kass
ELLROD, RAMIREZ, TRESTER wp
on for hearing before this Court on November 14, 2018, at 9:00 a.m. After full consideration of the
matter, this Court finds as follows:
The motion is denied in part and granted in part as follows. Plaintiff belatedly provided
verification to her responses to Requests for Production. Requests 11-14 were overly broad, but
Plaintiff's responses were not unequivocal. She stated that she had produced numerous documents, but
she did not state that such documents represented the universe of such documents in her custody and
control. The parties are ordered to meet and confer within 10 days and to attempt to agree on more
narrowly tailored requests for production. Plaintiff shall within 15 days serve verified responses to
those requests. Such responses may state, if true, that all responsive documents have already been
served. If not all responsive documents have not previously been produced, they shall be within 15
days. Plaintiff may also assert any proper objections. This order is without prejudice to Pacific Bell
Telephone bringing a further motion to compel for Requests 11-14 as modified. No sanctions.
IT IS SO ORDERED.
NOV 14 2018
Dated: Couns Couen
Hon. VWHOMAS Coven
Judge of the Superior Court - Pan TEM
4810-5546-9434.1 2
4§2ROPOSED] ORDER GRANTING MOTION TO COMPEL AND REQUEST FOR SANCTIONSManninc& Kass
ELLROD, RAMIREZ, TRESTER up
SERVICE LIST
Esborg v. Comcast Corp., et al.
CGC-16-553614
Christopher B. Dolan, Esq.
Quinton B. Cutlip, Esq.
Megan R. Irish, Esq.
DOLAN LAW FIRM, PC
1438 Market St.
San Francisco, CA 94102
Tel: (415) 942-6624
Fax: (415) 421-2830
Email: quinton.cutlip@cbdlaw.com
megan. irish@dolanlawfirm.com
Robert B. Mullen, Esq.
AT&T SERVICES, INC. - LEGAL DEPT.
430 Bush St., 3“ Floor
San Francisco, CA 94108
Tel: (415) 268-9498
Fax: (415) 543-0418
Email: robert.mullen@att.com
Jose A. Montalvo, Esq.
LAW OFFICES OF JOHN A. BIARD
401 Lennon Lane, Suite 125
Walnut Creek, CA 94598
Tel: (925) 945-4491
Fax: (855) 668-5559
Email: iamontal(@travelers.com
Charlene Rosack, Esq.
HARTSUYKER, STRATMAN &
WILLIAMS-ABREGO
San Francisco Branch Legal Office
505 14™ St., Suite 400
Oakland, CA 94612-1913
Tel: (510) 457-3440
Fax: (510) 238-8968
Email: charlene.rosack@farmersinsurance.com
Paul A. Bigly, Esq.
Owen T. Rooney Esq.
FREEMAN MATHIS & GARY, LLP
44 Montgomery St., Suite 2080
San Francisco, CA 94104
Tel: (415) 627-9000
Fax: (213) 615-7100
Email: pbigley@fmglaw.com
orooney@fmglaw.com
Attorney for Plaintiff,
KARA L, ESBORG
By Electronic Service
Co-Counsel for Defendant,
PACIFIC BELL TELEPHONE COMPANY
dba AT&T CALIFORNIA, erroneously sued
as AT&T Corp. (DOE 1) and AT&T
Services, Inc. (DOE 2)
By Mail
Attorney for Defendant,
WAVEDIVISION HOLDINGS, LLC
By Mail
Attorney for Defendants,
ALEKSANDR FRID & MARINA FRID
individually, and as Trustees of their
Revocable Trust
By Electronic Service
Attorneys for Defendant,
COMCAST OF CALIFORNIA, HI, INC.
By Mail
NOTICE OF ENTRY OF ORDERManninc@ Kass
ELLRop, RAMIREZ, TRESTER wp
James R. Picker, Esq.
PHILIP M. ANDERSEN & ASSOCIATES
Employees of the Corporate Law Department
State Farm Mutual Automobile Insurance Co.
6210 Stoneridge Mall Road, Suite 550
Pleasanton, CA 94588
Tel: (925) 225-6828
Fax: (855) 732-9437
Email: james.r.picker.gca0@statefarm.com
5
Attorneys for Defendants,
PAUL H. LUI & KAM T. LUI, individually
and as Trustees of their Revocable Trust
By Electronic Service
NOTICE OF ENTRY OF ORDER
Preview
Manninc& Kass ELLRoD, RAMIREZ, TRESTER uw anos co ODO wm Ia DH BF WN Rw NM MN NY NN DN NB ee me od A A Bob NH =| S © OIA A HW FF WN | Robert B, Mullen (State Bar No. 136346) AT&T SERVICES, INC.-LEGAL DEPARTMENT 430 Bush St, 3" Floor San Francisco, CA 94108 ELECTRONICALLY robert.mullen@att.com FILED Tel: (415) 268-9498 Superior Court of California, Fax: (415) 543-0418 County of San Francisco 11/15/2018 David V. Roth (State Bar No. 194648) Clerk of the Court BY: LESLIE GOMEZ Deputy Clerk dvr@manningllp.com Emily I Ellse (State Bar No. 299579) eie@manningllp.com MANNING & KASS ELLROD, RAMIREZ, TRESTER LLP 333 Bush Street, 27" Floor San Francisco, California 94104 Tel: (415) 217-6990 Fax: (415) 217-6999 Attorneys for Defendant, PACIFIC BELL TELEPHONE COMPANY dba AT&T CALIFORNIA, erroneously sued as AT&T Corp. (DOE 1) and AT&T Services, Inc. (DOE 2) SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO KARA L. ESBORG, Case No. CGC-16-553614 Plaintiff, NOTICE OF ENTRY OF ORDER v. COMCAST CORP.; COMCAST OF CALIFORNIA III, INC.; COMCAST CABLE COMMUNICATIONS, LLC; WAVE DIVISION HOLDINGS, LLC, ALEKSANDR FRID & MARINA FRID, individually and as trustees of their revocable trust; PAUL H. LUI & KAMT. LUI, individually and as trustees of their revocable trust; PAUL H. LUI & KAM T. LUI, individually and as trustees of their revocable trust; and DOES 1 to 100, Defendants. TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that on November 14, 2018 the Honorable Thomas Cohen, Judge Pro Tem of the San Francisco County Superior Court entered an Order Granting Defendant NOTICE OF ENTRY OF ORDERManninc& Kass ELLRoD, RAMIREZ, TRESTER ur Coe IN DW PB WN & RP NM YB NY RY NY NR NY Ye em ee ee RB Se eo YW A A BRB YBN &— FSO wm A AH BF WwW YD HF OD Pacific Bell Telephone Company DBA AT&T California and AT&T Services' Motion to Compel Responses to Request for Production of Documents. A true and correct copy of the Order is attached hereto and made part hereof as Exhibit A. DATED: November 14, 2018 MANNING & KASS ELLROD, RAMIREZ, TRESTER LLP By: David V. Roth Attorneys for Defendant, PACIFIC BELL TELEPHONE COMPANY dba AT&T CALIFORNIA, erroneously sued as AT&T Corp. (DOE 1) and AT&T Services, Inc. (DOE 2) 2 NOTICE OF ENTRY OF ORDERAnne toe Manninc& Kass ELLROD, RAMIREZ, TRESTER uP coo wm I DH RF WN NN YN NOM NY DB ee eee RBRNRRRBRE SERV A BRE BHR EA PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF SAN FRANCISCO At the time of service, I was over 18 years of age and not a party to this action. I am employed in the County of San Francisco, State of California. My business address is One California Street, Suite 900, San Francisco, CA 94111. On November 15, 2018, I served true copies of the following document(s) described as NOTICE OF ENTRY OF ORDER on the interested parties in this action as follows: SEE ATTACHED SERVICE LIST BY ELECTRONIC SERVICE: | electronically served the document(s) described above via File & ServeXpress, on the recipients designated on the Transaction Receipt located on the File & ServeXPress website (https://secure. fileandservexpress.com) pursuant to the Court Order establishing the case website and authorizing service of documents. BY MAIL: I enclosed the document(s) in a sealed envelope or package addressed to the persons at the addresses listed in the Service List and placed the envelope for collection and mailing, following our ordinary business practices. I am readily familiar with the practice of Manning & Kass, Ellrod, Ramirez, Trester LLP for collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service, in a sealed envelope with postage fully prepaid. I am a resident or employed in the county where the mailing occurred. The envelope was placed in the mail at San Francisco, California. I declare under penalty of perjury under the laws o ate.of California that the foregoing is true and correct. Executed on November 15, 2018, at San Fra 3 NOTICE OF ENTRY OF ORDEREXHIBIT AManninc& Kass Extrop, RAMIREZ, TRESTER wr aarovon La Robert B. Mullen (State Bar No. 136346) E D AT&T SERVICES, INC.-LEGAL DEPARTMENT subecot ca dratlria 430 Bush St, 3" Floor San Francisco, CA 94108 robert.mullen@att.com Tel: (415) 268-9498 Fax: (415) 543-0418 David V. Roth (State Bar No. 194648) dvr@manningllp.com Emily I Ellse (State Bar No. 299579) eie@manningllp.com Mark R. Wilson (State Bar No. 293474) mxw@manningllp.com MANNING & KASS ELLROD, RAMIREZ, TRESTER LLP 1 California Street, Suite 900 San Francisco, California 94111 Tel: (415) 217-6990 Fax: (415) 217-6999 Attorneys for Defendant, PACIFIC BELL TELEPHONE COMPANY dba AT&T CALIFORNIA, erroneously sued as AT&T Corp. (DOE 1) and AT&T Services, Inc. (DOE 2) NOV 14 2018 CLERK OF THE COURT BY: LINDA FO SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO KARA L. ESBORG, Plaintiff, v. COMCAST CORP.; COMCAST OF CALIFORNIA III, INC.; COMCAST CABLE COMMUNICATIONS, LLC; WAVE DIVISION HOLDINGS, LLC; ALEKSANDR FRID & MARINA FRID, individually and as trustees of their revocable trust, PAUL H. LUI & KAM T. LUI, individually and as trustees of their revocable trust, PAUL H. LUI & KAM T. LUI, individually and as trustees of their revocable trust; and DOES 1 to 100, Defendants. Case No. CGC-16-553614 |] ORDER GRANTING DEFENDANT PACIFIC BELL TELEPHONE COMPANY DBA AT&T CALIFORNIA AND AT&T SERVICES' MOTION TO COMPEL RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS AND REQUEST FOR SANCTIONS DISCOVERY Hearing Date: November 14, 2018 Time: 9:00 a.m. Dept.: 302 Defendants PACIFIC BELL TELEPHONE COMPANY dba AT&T CALIFORNIA and AT&T SERVICES, INC.'s motion to compel responses to request for production of documents came 4810-5546-9434.1 (PROEPOSED] ORDER GRANTING MOTION TO COMPEL AND REQUEST FOR SANCTIONSManninc& Kass ELLROD, RAMIREZ, TRESTER wp on for hearing before this Court on November 14, 2018, at 9:00 a.m. After full consideration of the matter, this Court finds as follows: The motion is denied in part and granted in part as follows. Plaintiff belatedly provided verification to her responses to Requests for Production. Requests 11-14 were overly broad, but Plaintiff's responses were not unequivocal. She stated that she had produced numerous documents, but she did not state that such documents represented the universe of such documents in her custody and control. The parties are ordered to meet and confer within 10 days and to attempt to agree on more narrowly tailored requests for production. Plaintiff shall within 15 days serve verified responses to those requests. Such responses may state, if true, that all responsive documents have already been served. If not all responsive documents have not previously been produced, they shall be within 15 days. Plaintiff may also assert any proper objections. This order is without prejudice to Pacific Bell Telephone bringing a further motion to compel for Requests 11-14 as modified. No sanctions. IT IS SO ORDERED. NOV 14 2018 Dated: Couns Couen Hon. VWHOMAS Coven Judge of the Superior Court - Pan TEM 4810-5546-9434.1 2 4§2ROPOSED] ORDER GRANTING MOTION TO COMPEL AND REQUEST FOR SANCTIONSManninc& Kass ELLROD, RAMIREZ, TRESTER up SERVICE LIST Esborg v. Comcast Corp., et al. CGC-16-553614 Christopher B. Dolan, Esq. Quinton B. Cutlip, Esq. Megan R. Irish, Esq. DOLAN LAW FIRM, PC 1438 Market St. San Francisco, CA 94102 Tel: (415) 942-6624 Fax: (415) 421-2830 Email: quinton.cutlip@cbdlaw.com megan. irish@dolanlawfirm.com Robert B. Mullen, Esq. AT&T SERVICES, INC. - LEGAL DEPT. 430 Bush St., 3“ Floor San Francisco, CA 94108 Tel: (415) 268-9498 Fax: (415) 543-0418 Email: robert.mullen@att.com Jose A. Montalvo, Esq. LAW OFFICES OF JOHN A. BIARD 401 Lennon Lane, Suite 125 Walnut Creek, CA 94598 Tel: (925) 945-4491 Fax: (855) 668-5559 Email: iamontal(@travelers.com Charlene Rosack, Esq. HARTSUYKER, STRATMAN & WILLIAMS-ABREGO San Francisco Branch Legal Office 505 14™ St., Suite 400 Oakland, CA 94612-1913 Tel: (510) 457-3440 Fax: (510) 238-8968 Email: charlene.rosack@farmersinsurance.com Paul A. Bigly, Esq. Owen T. Rooney Esq. FREEMAN MATHIS & GARY, LLP 44 Montgomery St., Suite 2080 San Francisco, CA 94104 Tel: (415) 627-9000 Fax: (213) 615-7100 Email: pbigley@fmglaw.com orooney@fmglaw.com Attorney for Plaintiff, KARA L, ESBORG By Electronic Service Co-Counsel for Defendant, PACIFIC BELL TELEPHONE COMPANY dba AT&T CALIFORNIA, erroneously sued as AT&T Corp. (DOE 1) and AT&T Services, Inc. (DOE 2) By Mail Attorney for Defendant, WAVEDIVISION HOLDINGS, LLC By Mail Attorney for Defendants, ALEKSANDR FRID & MARINA FRID individually, and as Trustees of their Revocable Trust By Electronic Service Attorneys for Defendant, COMCAST OF CALIFORNIA, HI, INC. By Mail NOTICE OF ENTRY OF ORDERManninc@ Kass ELLRop, RAMIREZ, TRESTER wp James R. Picker, Esq. PHILIP M. ANDERSEN & ASSOCIATES Employees of the Corporate Law Department State Farm Mutual Automobile Insurance Co. 6210 Stoneridge Mall Road, Suite 550 Pleasanton, CA 94588 Tel: (925) 225-6828 Fax: (855) 732-9437 Email: james.r.picker.gca0@statefarm.com 5 Attorneys for Defendants, PAUL H. LUI & KAM T. LUI, individually and as Trustees of their Revocable Trust By Electronic Service NOTICE OF ENTRY OF ORDER