Motion,Ex Parte: RUFUS ALEXANDER VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al

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Keith Reyen, Esq. (CSB 127420)
Bret R. Landess, Esq. (CSB 221105)

Angela Stinchfield, Esq. (CSB 244805) ELECTRONICALLY
OIUM REYEN & PRYOR FILED

i Superior Court of California,
220 Montgomery Street, Suite 910 County g San Fen i ma
San Francisco, CA 94104 NOV 30 204
Tel: (415) 392-8300 Clerk of the Cou
Fax: (415) 421-1254 BY: CHRISTLE ARRIO!

2 Deputy|Clerk
Attorneys for Defendant Fiat USA, Inc.
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO.
RUFUS ALEXANDER. Case No.: CGC-08-274719
Plaintiff, NOTICE OF NON-OPPOSITION TO
* DEFENDANT FIAT USA, INC.’S
vs - MOTION FOR AN ORDER TO IMPOSE
* TERMINATING SANCTIONS, OR IN

THE ALTERNATIVE, TO COMPEL

ASBESTOS DEFENDANTS (BP) c
As Reflected on Eakiits BC. G,H6,1,and | DISCOVERY RESPONSES; REQUEST

DOES 1-8500
Date: December 8, 2010

Time: 1:30 pum.
Defendants. Dept.: 220 P

Judge: Hon. Harold E, Kahn

Complaint Filed: July 1, 2008
Trial Date: Not Assigned

PLEASE TAKE NOTICE that Defendant Fiat USA, Inc.’s Motion For An Order To
Impose Terminating Sanctions, Or In The Alternative, To Compel Discovery Responses;
Request For Monetary Sanctions, was noticed for November 18, 2010, which was continued on
the Court’s own motion to December 8, 201 0. Pursuant to Code of Civ. Proc. §1005(b),
plaintiff's Opposition, if any, was to be filed with this Court and served on all parties on or
before November 4, 2016, nine court days before the hearing. Even taking into account the
Court’s November 16, 2010 continuance of defendant’s Motion to December 8, 2010, plaintiff's
Opposition was to be filed by November 23, 2010 at the latest.

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‘Notice of Non-Opposition Toe Defendant Fiat USA, Inc.'s Motion for an Order To Impose Terminating Sanctions, or in the
alternative, to Compel Discovery Responses; Request for Monetary Sanctions27

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Plaintiff Rufus Alexander has failed to respond to defendant Fiat USA, Inc.’s Motion,
and thus defendant Fiat USA, Inc. respectfully requests that the Court grant Fiat USA, Inc.’s
Motion For An Order To Impose Terminating Sanctions.

Respectfully submitted,s

OM REYEN & PRYOR

Dated: November 30, 2010 > -

Atigela Stinchfféld, Esq.
Attorneys for Defendant Fiat USA, Inc.

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Notice of Non-Oppasition To Defendant Fiat USA, Inc.'s Motion for an Order To Impose Terminating Sanctions, or in the
altemative, to Compel Discovery Responses; Request for Monetary SanctionsRufus Alexander v. Asbestos Defendants (Fiat USA, Inc.
San Francisco Superior Court Case No. CGC 08-274719

Tam a citizen of the United States. My business address is 220 Montgomery Street,
Suite 910, San Francisco, California 94104. Lam employed in the County of San Francisco
where this service occurs. I am over the age of 18 years and not a party to the within cause.
Tam readily familiar with my employer's normal business practice for collection and processing
of correspondence for mailing with the U.S. Postal Service and that practice is that
correspondence is deposited with the U.S. Postal Service the same day as the day of collection
in the ordinary course of business.

On November 30, 2010, following ordinary business practice, I served the foregoing
document(s) described as: on the interested parties in said action addressed as follows:

« Notice of Non-Oppesition to Defendant Fiat USA, Inc.’s Motion for an Order To
Impose Terminating Sanctions, or in The Alternative, To Compel Discovery
Responses; Request For Monetary Sanctions

Rufus Alexander, In Pro Per
170 Cashmere Street, Apt. D
San Francisco, CA 94124

(BY FACSIMILE) by transmitting via facsimile the document(s) listed above to
the facsimile number(s) set forth above, or as stated on the attached service list,
on this date before 5:00 p.m.

x (BY MAIL) by placing a true and correct copy of the document(s) listed above
enclosed in a sealed envelope(s) with postage thereon fully prepaid in the
United States Mail at San Francisco, California.

(BY PERSONAL SERVICE) by placing a tme and correct copy of the
document(s) listed above enclosed in a sealed envelope(s) and causing said
envelope(s) to be delivered by hand this date to the offices of the addressee(s).

(BY OVERNIGHT DELIVERY) by placing a true and correct copy of the
document(s) listed above enclosed in a sealed envelope(s) and causing said
envelope(s) to be delivered to an overnight delivery carrier with delivery fees
provided for, addressed to the person(s) on whom it is to be served.

I declare that I am employed in the office of a member of the bar of this Court at whose
direction the service was made. I declare under penalty of perjury under the laws of the State of
California that the foregoing is te and correct. Executed on November 30, 2010, at San Francisco,

California.

Wanda W. Burnett
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PR VICE
Rufus Alexander v. Asbestos Defendants (Fiat USA, Inc.
San Francisco Superior Court Case No, CGC 08-274719

I certify that I am over the age of 18 years and not a party to the above referenced action;
that my business address is 220 Montgomery Street, Suite 910, San Francisco, CA 94104; and
that on this date I served a true copy of the document(s) in the action of Rufus Alexander v.
Asbestos Defendants, San Francisco Superior Court Case No. CGC-08-274719, entitled:

e Notice of Non-Opposition te Defendant Fiat USA, Inc.’s Motion for an Order To
Impose Terminating Sanctions, or in The Alternative, To Compel Discovery
Responses; Request For Monetary Sanctions

Service was effectuated by forwarding the above-noted documents in the following manner:

xX Electronically on the recipients designated on the Transaction Receipt located on
the LexisNexis File & Serve website, pursuant to San Francisco Superior Court

General Order No. 158. Asbestos-Related Case.

I declare under penalty of perjury that the foregoing is true and correct and that this
declaration was executed on November 30, 2016, at San Francisco, California.

Warde 10 Bromaikt

‘anda W. Burnett

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Proof of Service