Motion-Secondary: TIMOTHY A BONNICI VS. CHARLES MCMACKIN ET AL

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                                LAW OFFICES of R. Michael Lieberman

1398 Post Street, San Francisco, California 94109

TEL! 425-929-3197 ® FAX! 415-929-3476

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R. MICHAEL LIEBERMAN (SBN 120831) ELECTRONICALLY
LAW OFFICES OF R. MICHAEL LIEBERMAN FILED
1398 POST STREET
SAN FRANCISCO, CALIFORNIA 94109

TELEPHONE: (415) 929-3197 12/08/2017
FAX: (415) 929-3476 BY:KALENE APOLONIO

Deputy Clerk

Superior Court of California,
County of San Francisco

Attorneys for Defendants
CARROLL HENRY and CHARLES MCMACKIN

SUPERIOR COURT - STATE OF CALIFORNIA

COUNTY OF SAN FRANCISCO ~ UNLIMITED JURISDICTION

TIMOTHY A. BONNICI, an NO. CGC 17-557688
individual
Reservation No. 11091215-18
Plaintiff,
DECLARATION OF R. MICHAEL
vs. LIEBERMAN IN SUPPORT OF
DEFENDANTS’ DEMURRER TO
CHARLES MCMACKIN, an PLAINTIFF’S COMPLAINT
individual, CARROLL HENRY, an
individual, and DOES I TO 200, DATE: DECEMBER 15, 2017
inclusive, TIME: 9:30 A.M.
DEPARTMENT NO.: 302
Defendants. TRIAL DATE: NONE SET
ATTACHED DOCUMENTS: NO

HON. HAROLD E. KAHN

1/ DECLARATION OF R. MICHAEL LIEBERMAN IN SUPPORT OF DEFENDANTS’
DEMURRER TO PLAINTIFF'S COMPLAINTLAW OFFICES of R. Michael Lieberman

1398 Post Street, San Francisco, California 94109

TEL: 415-929-3197 © PAX: 415-929-3476

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I, R. MICHAEL LIEBERMAN, do hereby declare:

1. I am an attorney at law licensed to practice law in the States of
California and Nevada. I have personal knowledge of the facts stated herein
| and, if called as a witness, could and would testify competently to those facts

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based upon that knowledge.

2. I make this Declaration regarding defendants’ Demurrer to

) plaintiff's Complaint in this Case.

3. As of the date defendants’ Reply would have been due, defendant
| HENRY’s counsel have not received plaintiff BONNICI’s Opposition.

| 4, On the morning of the date before defendants’ Reply would have
been due, defendants’ counsel checked the Court’s website, which indicates
that plaintiff BONNICI has not filed an Opposition.

I declare under penalty of perjury wu: e laws of the State of

| California that the foregoing is true and corgect.

DATE: December 8, 2017

"MICHAEL LIEBERMAN

2/ DECLARATION OF R. MICHAEL LIEBERMAN IN SUPPORT OF DEFENDANTS’
|| DEMURRER TO PLAINTIFF'S COMPLAINTLAW OFFICES of R. Michael Lieberman
1398 Post Street, San Francisco, California 94109

TEL: 435-929-3197 © FAX: 615-929-3476

PROOF OF SERVICE
I, MONICA TAURIELLO, declare:

Iam over the age of eighteen years, not a party to this action and
am employed in the City and County of San Francisco at 1398 Post Street,
San Francisco, California 94109.

On December 8, 2017, I served the within document(s) entitled:

DECLARATION OF R. MICHAEL LIEBERMAN IN SUPPORT OF
DEFENDANTS’ DEMURRER TO PLAINTIFF’S COMPLAINT

by fax and by placing in the United States Mail a true and correct copy
thereof in a sealed envelope, with postage thereon fully prepaid,
addressed to:

GINO J. MOLINARI

LAW OFFICES OF GINO J. MOLINARI
3366 22%? STREET

SAN FRANCISCO, CA 94110

FAX: 415-648-3130

I declare under penalty of perjury under. laws, of the State of

California that the foregoing is true

DATED: December 8, 2017

INICA TAURIELLO

3/ DECLARATION OF R. MICHAEL LIEBERMAN IN SUPPORT OF DEFENDANTS’
DEMURRER TO PLAINTIFF'S COMPLAINT