On December 03, 2013 a Request,Application was filed involving a dispute between Karidis-Koepke, Nancy, Koepke, Harold, and A.B.C. Mobile Systems, A.B.C. Mobile Systems, Individually And As, American Honda Motor Co. Inc., Bell Industries, Inc., Bell Industries Inc., Individually And As, Belnortel Corporation, D.B.A. A.B.C. Mobile Brake, Borgwarner Morse Tec, Inc., Borgwarner Morse Tec Inc., Individually And As, Burlingame Auto Supply, Continental Automotive Systems, Inc., Cooper Industries Llc, Cooper Industries, Llc, Individually And As, Don L. Morris, Inc., First Doe Through Four Hundredth Doe, Inclusive, Fmc Corporation-John Bean Automotive Equipment, Fmc Technologies, Inc., Individually And As, Folsom Auto Supply, Ford Motor Company, Foreland Parts, Inc.,, Genuine Parts Company, H.M. Royal, Inc., Honeywell International, Inc., Fka Allied Signal,, Kelsey-Hayes Company, Lear Siegler Diversified Holdings Corp.,, Les Vogel Chevrolet Company, Metropolitan Life Insurance Company, Morton International, Inc., A Rohm And Haas, Morton International, Llc, Formerly Known As, National Automotive Parts Association, Parker Hannifin Corporation, Parker Hannifin Corporation, Individually And As, Pneumo Abex Llc, Individually And As Successor In, Rox Automotive, Shell Oil Company, Specialty Foreign Auto Parts, Inc., Erroneously, The Budd Company, Thyssenkrupp Budd Company Sued As "The Budd, Toyota Motor Sales, U.S.A., Inc., University Distributors, Inc., Erroneously Sued, Volkswagen Group Of America, Inc., W. Berry Hurley Corporation, D.B.A. Federal Auto, Karidis-Koepke, Nancy, Koepke, Harold, The Hertz Corporation, for civil in the District Court of San Francisco County.
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Gordon & Rees LLP 1111 Broadway, Suite 1700 Oakland, CA 94607 2 won MICHAEL J. PIETRYKOWSKI (SBN: 118677) mpietrykowski@gordonrees.com RICHARD R. AMES (SBN: 185822) ELECTRONICALLY rames@gordonrees.com FILED GORDON & REES LLP Superior Court of California, 1111 Broadway, Suite 1700 County of San Francisco Oakland, CA 94607 JUN 18 2014 Telephone: (510) 463-8600 Facsimile: (510) 984-1721 Clerk of the Court BY: ROMY RISK Lane . Deputy Clerk Attorneys for Plaintiff in Intervention THE CHARTER OAK FIRE INSURANCE COMPANY, intervening on behalf of A.B.C. MOBILE SYSTEMS, a suspended corporation SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Harold Koepke and Nancy Karidis-Koepke CASE NO. CGC-13-276217 Plaintiffs, DECLARATION OF RICHARD R. AMES IN SUPPORT OF EX PARTE APPLICATION OF PLAINTIFF IN INTERVENTION THE CHARTER OAK FIRE INSURANCE COMPANY, INTERVENING ON BEHALF OF A.B.C. MOBILE SYSTEMS, A vs. Ford Motor Company, et al. Defendants. SUSPENDED CORPORATION FOR RELIEF FROM EXPERT WITNESS DISCLOSURE DEADLINE, OR IN THE ALTERNATIVE, AN ORDER SHORTENING TIME The Charter Oak Fire Insurance Company, intervening on behalf of A.B.C. Mobile Systems, a suspended corporation. Plaintiff in Intervention, Accompanying Documents i. Ex Parte Application 2, Memorandum of Points & Authorities 3. [Proposed] Order vs. Harold Koepke and Nancy Karidis-Koepke Date: June 18, 2014 Time: 11:00 am Dept: 503 Judge: Hon. Teri L. Jackson Defendants in Intervention. SS SS SSS Om Se Action Filed: December 3, 2014 Trial Date: June £6, 2014 I, Richard R. Ames, declare: 1 Tam an attorney duly licensed to practice before the courts of the State of California, I practice with Gordon & Rees LLP, counsel of record for Plaintiff in Intervention The Charter Oak Fire Insurance Company, intervening on behalf of A.B.C. Mobile Systems, a -l- DECLARATION OF RICHARD R. AMES IN SUPPORT OF EX PARTE APPLICATION FOR RELIEF FROM EXPERT WITNESS DISCLOSURE DEADLINEGordon & Rees LLP 1111 Broadway, Suite 1700 Oakland, CA 94607 2 won suspended corporation (“Charter Oak”). The facts stated herein are true of my own personal knowledge. I make this declaration in support of Charter Oak’s Ex Parte Application for Relief from Expert Witness Disclosure Deadline, or in the alternative, an order shortening time. 2. Filed herewith as Exhibit A is a true and correct copy of Charter Oak’s answer to Plaintiffs’ complaint in this matter, 3. Filed herewith as Exhibit B is a true and correct copy of May 16, 2014 correspondence from Charter Oak to Plaintiffs’ counsel. Charter Oak received no response to this correspondence. 4. Filed herewith as Exhibit C is a true and correct copy of Charter Oak’s designation of expert witnesses served on May 27, 2014. 5. Filed herewith as Exhibit D is a true and correct copy of Plaintiffs’ objections to Charter Oak’s designation of expert witnesses. 6. Filed herewith as Exhibit E is a true and correct copy of June 10, 2014 correspondence from Charter Oak to Plaintiffs’ counsel. Charter Oak received no response to this correspondence. 7. Filed herewith as Exhibit F is a true and correct copy of June 11, 2014 correspondence between Charter Oak and Plaintiffs’ counsel. Charter Oak had placed approximately five phone calls to Plaintiffs counsel regarding the issues encompassed by this motion on or around this date. 8. Filed herewith as Exhibit G is a true and correct copy of June 16, 2014 correspondence from Charter Oak to Plaintiffs’ counsel. Charter Oak recevied no response to this correspondence. 9. Filed herewith as Exhibit H is a true and correct copy of the ex parte notice served on all parties on June 17, 2014 prior to 10:00 am. Charter Oak has received no response to this notice. 10. At my direction, my office contacted the Court’s clerk to inquire whether an informal conference was required to be held, and to schedule such a conference, prior to the filing of this application. | am informed and believe that that the Court’s clerk stated that the 2. DECLARATION OF RICHARD R. AMES IN SUPPORT OF EX PARTE APPLICATION FOR RELIEF FROM EXPERT WITNESS DISCLOSURE DEADLINE1 |] Court may order such a conference to be held after this application was filed. T declare under penalty of perjury under the laws of the State of California that the 2 won foregoing is true and correct. 5 Executed June 17, 2014 at Oakland, California. 6 OY ae 8 Richard R. Ames Oakland, CA 94607 Gordon & Rees LLP 1111 Broadway, Suite 1700 iosnossrones oy. 5 DECLARATION OF RICHARD R. AMES IN SUPPORT OF EX PARTE APPLICATION FOR RELIEF FROM EXPERT WITNESS DISCLOSURE DEADLINE