On October 31, 2011 a Motion,Ex Parte was filed involving a dispute between Allstate Insurance Company, Eseifan, Sanaa, Eseifan, Yasmine, Fua Cruz, Ida Christina, Sanchez, Joel Enrique Andino, and Da Silva, Alan, Does 1 To 10, Does 1 To 20, Does 1 To 50, Inclusive, Gillespie, James, Martinez, Pamela, Mellegard, Hal, Miller, Caroline, Miller, Carolyn, Olsen, Nick, Reimers, Steven, Sanchez, Joel, Sanchez, Joel Enrique Andino, San Francisco Independent Taxi Association, San Francisco Independent Taxi Association, A, Silva, Alan, Taxi Equipment Leasing Llc, Taxi Equipment Leasing Llc, A Limited Liability, Taxi Property Company, Inc., Wiener, Richard, Wolley, Llc, Yellow Cab Cooperative, Inc., Yellow Cab Coopoerative, Inc A Corporation, for civil in the District Court of San Francisco County.
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D. Douglas Shureen, SBN 124613 ELECTRONICALLY Donald T. McMillan, SBN 134366 McMILLAN & SHUREEN LP sopehr iL ED anta Rosa Avenue, Fi joor omnia, Santa Rosa, CA 95404-4952 County of San Francisco (on 525-5400 APR 08 2014 707) 576-7955 (Fax) Clerk of the Court BY: EDNALEEN JAVIER Attorneys for Defendant/Cross-Complainant Deputy Clerk JOEL ENRIQUE ANDINO SANCHE; SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO IDA CRISTINA CRUZ FUA, CASE No. CGC-11-515542 (Lead Case) Consolidated with Case Nos. Plaintiff, CGC-12-519794 and CGC-13-529705 vs. DEFENDANT AND CROSS- COMPLAINANT JOEL ENRIQUE JOEL ENRIQUE ANDINO SANCHEZ, an ANDINO SANCHEZ’S NOTICE OF individual, et al., MOTION AND MOTION FOR LEAVE TO FILE CROSS-COMPLAINT Defendants. JOEL ENRIQUE ANDINO SANCHEZ, Date: 05/09/14 (reservation 040714-03) Time: 9:30 a.m. Cross-Complainant, ) Dept.:302 dudge: Hon. Ernest H. Goldsmith TAXI EQUIPMENT LEASING, LLC; SAN FRANCISCO INDEPENDENT TAXI Action filed: 10/31/11 ASSOCIATION; YELLOW CAB Trial: 09/22/14 COOPERATIVE, ING.; ALAN DA SILVA; TAXI PROPERTY COMPANY, INC.; WOLLEY, LLC; JAMES GILLESPIE; DMITRI ERENKOV; HAL MELLEGARD; NICK OLSEN; PAMELA MARTINEZ; RICHARD WIENER; STEVEN REIMERS; and ROES 1-50, Cross-Defendants. fit ttt itl Ht] ttl 4 DEFENDANT AND CROSS-COMPLAINANT JOEL ENRIQUE ANDINO SANCHEZ’S NOTICE OF MOTION AND MOTION FOR LEAVE TO FILE CROSS-COMPLAINT0 Oe RW Dw BF WY DN eke BRR RR BSF SS SFU RGAETHS SS TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that on May 9, 2014 at 9:30 a.m. or as soon thereafter as the matter can be heard, in Department 302 of this Court located at 400 McAllister Street, San Francisco, California, 94102, Defendant and Cross-Complainant JOEL ENRIQUE ANDINO SANCHEZ (hereinafter “SANCHEZ’) will move, and hereby does move, for leave to file a Cross-Complaint pursuant to sections 428.10 and 428.50 of the California Code of Civil Procedure. Defendant and Cross-Complainant’s. motion for leave to file Cross-Complaint is based on the grounds that under the authority of C.C.P. §428.10 (b) the proposed cross- complaint “(1) arises out of the same transaction, occurrence, or series of transactions or occurrences as the cause brought against Sanchez and (2) asserts a claim, right or interest in the property or controversy which is the subject of the cause brought against (Sanchez).” Sanchez submits that this Court should grant leave to file Sanchez’s Cross- Complaint in the interest of justice. The motion is based on this Notice of Motion, the Memorandum of Points and Authorities, and the Declaration of Donald T. McMillan, filed and served concurrently with this Notice, together with the Amended Complaint filed by Plaintiff in this action. The Motion may additionally be based upon materials in the court file, and such further oral and/or documentary evidence as the Court may consider in its discretion at the hearing on this motion. DATED: April_ 7, 2014 Attorneys for Defendant and Cross- Complainant JOEL ENRIQUE ANDINO SANCHEZ 2 “DEFENDANT AND CROSS-COMPLAINANT JOEL ENRIQUE ANDINO SANCHEZ’S NOTICE OF MOTION AND MOTION FOR LEAVE TO FILE CROSS-COMPLAINT