Motion-Secondary: COMMONWEALTH LAND TITLE INSURANCE COMPANY VS. FEDEX OFFICE AND PRINT SERVICES, INC et al (PROVIDE ACCESS)

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                                148678

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FIDELITY NATIONAL LAW GROUP
HOWARD P. BRODY (SBN 65307)
915 Wilshire Boulevard, Suite 2100

Los Angeles, California 90017
Telephone: (213) 438-4414

Facsimile: (213) 438-4417

Email: howard.brody@fnf.com

Attomeys for Plaintiff,
COMMONWEALTH LAND TITLE
INSURANCE COMPANY

ELECTRONICALLY

FILED

Superior Court of California,
County of San Francisco

06/02/2017
Clerk of the Court
BY:RONNIE OTERO
Deputy Clerk

SUPERIOR COURT FOR THE STATE OF CALIFORNIA

FOR THE COUNTY OF SAN FRANCISCO

COMMONWEALTH LAND TITLE
INSURANCE COMPANY,

Plaintiffs,
ve.

FEDEX OFFICE AND PRINT SERVICES,
INC.; WINSTON LUM; KAUSHAL
NIROULA; JAY CHANDRAKANT SHAH;
ELVIA PALOMINO; MORAD AFRAIMI;
MELVIN LEE EMERICH; MARTINI &
CHNOOGLE; GRACHELLE LANGUBAN;
MERCHANTS BONDING COMPANY, and
DOES 1-25, inclusive,

Defendants.

Mt

Mt

Mt

CASE NO. CGC-10-503332
(Consolidated for all purposes with CGC-11-
512102)

DECLARATION OF HOWARD P. BRODY
IN SUPPORT OF PLAINTIFF
COMMONWEALTH LAND TITLE
INSURANCE COMPANY ’S MOTION IN
LIMINE NO. 4 TO PRECLUDE ANY
REFERENCE TO SETTLEMENT
DISCUSSIONS, SETTLEMENT
AGREEMENTS, AND SETTLEMENT
PROPOSALS

Trial Date: © June 12, 2017
Time: 9:30 a.m.
Dept.: 206

1

PLAINTIFF COMMONWEALTH LAND TITLE INSURANCE COMPANY'S MOTION IN LIMINE NO. 4 TO PRECLUDE ANY T
REFERENCE TO SETTLEMENT DISCUSSIONS, SETTLEMENT AGREEMENTS, AND SETTLEMENT PROPOSALS148678,

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DECLARATION OF HOWARD P. BRODY

I, Howard P. Brody, declare under penalty of perjury of the laws of the State of California
that the following statements are true, correct, and based on personal knowledge:

1. lam an attorney admitted in the State of California. | am a member in good
standing of the California State Bar Association, and my California State Bar Number is 65307. I
represent Plaintiff Commonwealth Land Title Insurance Company in this action. I know the facts
stated herein to be true based upon my own personal knowledge and experience, | am over the
age of 18 and otherwise of sound capacity to deliver testimony if called upon to testify in this
action,

2. My concern in filing this motion is based upon the fact that a number of the party
defendants have little or no understanding of civil practice and procedure and furthermore, are
convicted felons who have already shown a disregard for the rule of law.

I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct to the best of my knowledge and experience.

Executed on June 1, 2017 at Los Angeles, California.

Howard P. Brody

ENT PROPOS

TON IN LIMINE NO. 4 TO PRECLU
z ND SE NPROOF OF SERVICE

STATE OF CALIFORNIA, COUNTY OF LOS ANGELES

Tam employed in the County of Los Angeles, State of California. | am over the age of
eighteen years and nota party to t hin entitled action; my business address is 915 Wilshire |
Blvd., Suite 2100, Los Angeles. California 90017. |

On June 2, 2017, I served the foregoing document(s) described as:

PLAINTIFF
IN LIMINE NO,4 TO PREC
DISCUSSIONS, SETTLEMENT ¢
MEMORANDUM OF POINTS AND Al THORITI as
BRODY IN SUPPORT THEREOF

COMMONWEALTH LAND TITLE INSURANCE COMPANY’S MOTION
UDE ANY REFERENCE TO SETTLEMENT

: DECLARATION OF HOWARD P,

on the interested parties in said action:

[X] By placing the original and/or a true copy thereof enclosed in a sealed envelope
addressed as follows:

SEE ATTACHED SERVICE LIST |

| (BY MAIL) I deposited such envelope in an internal collection basket. The envelope was |
mailed with postage thereon fully prepaid trom Los Angeles, California. T am readily familiar
with the firm's practice of collection and proe gs corr for mailing. It is deposited
with the U.S. Postal Service on that y : of business. Tam aware that |
on motion of party served, service is presumed invalid ifa postal cancellation date or post

meter date is more than one day afier date of deposit for mailing in affidavit.

] (BY PERSON
offices of the addres:

L SERVICE) | caused such envelope to be delivered by hand to the

X] (BY GSO OVERNIGHT) | delivered to an authorized driver authorized by GSO
(GOLDE N STATE ERNIGHT) to receive documents, in an envelope or package designated |
JVERNIGHT) with deli paid or provided for, addressed to |
the person on who served, at the office address as last given by that person on any
document filed in the cause and served on the party making service: or at that party’s place of
residence,

FACSIMILE) | faxed such document from Los Angeles, California to the fae: mile
shown on the attached service list. The sending facsimile machine numbe:
The transmission was reported as complete and without error and the transmi:
was properly issued by the transmitting facsimile machine.

-438- |

jon report

Xj PE). [ declare under the penalty of perjury under the laws of the State of California. |
that the foregoing i is true and correct. |
i

Executed on June 2, 2017, at Los Angeles, Calify |

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PROOF OF SERVICE1
SERVICE LIST
2 Commonwealth Land Title Insurance Com; v. FedEx Office and Print Services Inc., et al.
Superior Court of California, County of San Francisco
3 Case No. CGC-10-503332
4 Attorney for Shirley Hwang In Pro Per Defendant
5 Morgan Lopez, Esq. Jay C. Shah
Glynn & Finley, LLP A03101, Rm No. 6-123
6 One Walnut Creek Center California Medical facility
100 Pringle Avenue, Suite 500 P.O. Box 2000
7 Walnut Creek, CA 94596 Vacaville, CA 95696
Fax: (925) 945-1975
8 mi GI inley.com
9
10 Attorney for Elvia Palomino In Pro Per Defendant
Craig J. Bassett, Esq. Winston Lum
11 25 W First Street 25 Forest Side Ave.
Morgan Hill CA 95037 San Francisco, CA 94127
12 chassett@garlic.com
13
14
Attorney Pro Se In Pro Per Defendant
15 Melvin L. Emerich Kaushal Niroula
B10-337 ANIS518 :
16 4546 El Camino Real Mule Creek State Prison
Los Altos, CA 94022 P.O. Box 409099
17 _ Tone, CA 95640
milemeric! o.com
18
19 In Pro Per Defendant
20 Morad Afraimi
912 Edgecliff Drive
21 Reno, NV 89523
22
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24
25
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27
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DOCUMENT PREPARED
(ON RECYCLED PareR

PROOF OF SERVICE