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  • RUFUS ALEXANDER VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • RUFUS ALEXANDER VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • RUFUS ALEXANDER VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • RUFUS ALEXANDER VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • RUFUS ALEXANDER VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
  • RUFUS ALEXANDER VS. ASBESTOS DEFENDANTS (B/P)AS REFLECTED ON EXHIBITS et al ASBESTOS document preview
						
                                

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Keith Reyen, Esq. (CSB 127420) Bret R. Landess, Esq. (CSB 221105) ELECTRONICALLY OUMREYEN & PRYOR 220 Montgomery Street, Suite 910 FILED San Francisco, CA 94104 Seperer Court of Califojnia, Tel: (415) 392-8300 ounty of San Francispo Fax: (415) 421-1254 JUN 03 201 Clerk of the Cou Attorneys for Defendant Fiat USA, Inc. BY: JUDITH ae epuly clerk IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO RUFUS ALEXANDER Case No.: CGC-08-274719 oe DEFENDANT EIAT USA, INC’S Plaintiff, JOINDER IN CO-DEFENDANTS v8. MOTION TO DISMISS FOR DELAY IN ASBESTOS DEFENDANTS (BP) PROSECUTION As Reflected on Exhibits B, C,G,B,1; and | pate: June 7, 2011 DOES 1-8500 Time: 1:30 p.m. Dept. 220 Defendants. Judge: Hon. Harold E. Kahn Complaint Filed: July 1, 2008 Trial Date: Not Assigned TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that Defendant FIAT USA, INC. hereby join Defendants ARVINMERITOR, INC. AND MAREMONT CORPORATION in their Motions to Dismiss for| Delay in Prosecution set for hearing on June 7, 2011, at 1:30 p.m., in Department 220 of the above-entitled court, located at 400 McAllister Street, San Francisco, California. The moving Defendants seek an order dismissing the action for lack of prosecution pursuant to code of Civil Procedure Section 2023.030(4)(3).- Defendants FIAT USA, INC. incorporate by reference the moving papers filed by defendants ARVINMERITOR, INC. and MAREMONT CORPORATION in their entirety, Page 1 Defendant Fiat USA, Inc.’s Joinder In Co-Defendants Motion To Dismiss For Delay In Prosecutionincluding all exhibits and attachments thereto. The legal and factual arguments apply to defendant FIAT USA, INC. who have also been unable to depose plaintiff, Defendants also incorporate the moving papers and exhibits of any and all co-defendants’ joinder motions. PLEASE take further notice that should ARVINMERITOR, INC, and MAREMONT CORPORATION be dismissed from this case, or withdraw their moving papers, FIAT USA, INC. will continue with this motion. Respectfully submitted, OIUM REYEN & PRYOR ey a & Dated: June 2, 2011 Keith Reyen, Esq. Attomeys for Defendant Fiat USA, Inc. Page 2 Defendant Fiat USA, Inc.’s Joinder In Co-Defendants Motion To Dismiss For Delay In Prosecution: PROOF OF SERVICE Rufus Alexander v. Asbestos Defendants (Fiat USA, Ine. San Francisco Superior Court Case No. CGC 08-274719 I certify that [ 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 docurnent(s) in the action of Rufus Alexander v. Ashestos Defendants, San Francisco Superior Court Case No. CGC-08-274719, entitled: * Defendant Fiat USA, Inc.’s Joinder in Co-Defendants Motion to Dismiss For Delay in Prosecution 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 June 3, 2011, at San Francisco, California. Ma W. Burnett Page f Proof of Service