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@ e :
FILED
25 BEC 1g P
(UONATHAN ALLAN KLEIN (SBN 162071)
THOMAS K. HOCKEL (SBN 172367)
MARK P. IEZZA (SBN 239813)
KELLY, HOCKEL & KLEIN P.C.
44 Montgomery Street, Suite 1500
San Francisco, CA 94104-4798
Tel.: (415) 951-0535
Fax: (415) 391-7808 1) WEBFR
Attorneys for Defendant
NEIL COOPER
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF CONTRA COSTA
PRESTON WRIGHT, J Case No.: C15-01555
2
Plaintiff, y
) DECLARATION OF MIKE ABEL IN
vs. SUPPORT OF MOTION TO QUASH
SERVICE OF SUMMONS
NEIL COOPER and DOES 1 TO 50, o-2-7h
inclusive, Date: 4.
) Time: aw my
Defendants. ) Location: Department 9
Hon. Judith S. Craddick
Accompanying: Documents:
1 Notice of Motion, Memorandum of
Points and Authorities;
Jy 2. Declaration of Thomas K. Hockel;
3. Declaration of Neil Cooper; and
p 4. Proposed Order. ,
I, Mike Abel, declare:
1. 1am an attorney at law duly licensed to practice by the State of Arizona. I am
submitting this declaration in support of defendant Neil Cooper’s (“Cooper”) motion to quash
service of summons. I have personal knowledge of the facts stated in this declaration and could
competently testify to those facts if called upon to do so.
‘DECLARATION OF MIKE ABEL IN SUPPORT OF MOTION TO QUASH SERVICE OF SUMMONS
Case No.: C15-01555
*%v
ur
2. Cooper initially retained me to assist him with the complaint he received in this
matter. | sent a letter of representation to counsel for plaintiff Preston Wright (“Wright”) on
September 22, 2015. I asked for an extension of time to respond to the complaint so the parties
could exchange information and explore a resolution of the dispute.
3. On October 5, 2015, Alice Freeman (“Freeman”) from Plaintiff's counsel's office
sent an email to me stipulating to an extension of time to respond to the complaint through
| November 15, 2015.
4, The parties exchanged some information, but it took longer than anticipated. As
such, I secured a further stipulation from Wright’s counsel to extend the time to respond through
December 1, 2015, which was confirmed in a letter from Wright’s counsel, dated November 9,
2015.
5. The parties continued to work toward a possible resolution, and Plaintiff's counsel
stipulated to a further extension for Cooper to answer or otherwise respond until January 1, 2015,
6. Ultimately, the parties’ efforts toward a resolution were unsuccessful, and | then
assisted Cooper in locating California counsel.
I declare under the penalty of perjury under the laws of the State of California that the
foregoing is iue and correct.
Dated: [ee] PIS
DECLARATION OF MIKE ABEL IN SUPPORT OF MOTION TO QUASH SERVICE OF SUMMONS
Cuse No; C15-01855oD me IN DH PB WN
PROOF OF SERVICE
Preston Wright v. Neil Cooper
Contra Costa County Superior Court Case No: C15-01555
I, EZRA M. DENMAN, declare:
I work in the City and County of San Francisco, State of Califomia. My business address
is 44 Montgomery Street, Suite 1500, San Francisco, California 94104. I am over the age of
18 years and not a party to the foregoing action.
On December 18, 20151 served the following Documents: DECLARATION OF MIKE ABEL
IN SUPPORT OF MOTION TO QUASH SERVICE OF SUMMONS, on the interested parties
in said action,
Jeffrey J. Rooney, Esq.
Brule & Rooney
319 Diablo Road, Suite 200
Danville, CA 94526
Attorney for Plaintiff
_X__—_ (by mail) by placing a true copy thereof enclosed in a sealed envelope in a designated area for
outgoing mail, addressed as set forth above. At Kelly, Hockel & Klein P.C., mail placed in that
designated area is given the correct amount of postage and is deposited that same day, in the
ordinary course of business, in a United States mailbox in the City of San Francisco, California.
_— _ (by personal delivery) by causing the document(s) listed above to be personally delivered
to the person(s) at the address(es) set forth above.
(by Federal Express) by depositing a true copy thereof in a sealed packet for overnight delivery,
with charges thereon fully prepaid, in a Federal Express collection box, at San Francisco,
California, and addressed as set forth above.
(by electronic transmission) by electronically mailing a true and correct copy through Kelly,
Hockel & Klein PC’s electronic mail system to the email address(es).
I declare under penalty of perjury and the laws of the United States that the foregoing is
true and correct and that this declaration was executed on December 18, 2015 at San Francisco,
California.
Oo
EZRAM. DENMAN,
Proof of Service
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@ e : FILED 25 BEC 1g P (UONATHAN ALLAN KLEIN (SBN 162071) THOMAS K. HOCKEL (SBN 172367) MARK P. IEZZA (SBN 239813) KELLY, HOCKEL & KLEIN P.C. 44 Montgomery Street, Suite 1500 San Francisco, CA 94104-4798 Tel.: (415) 951-0535 Fax: (415) 391-7808 1) WEBFR Attorneys for Defendant NEIL COOPER SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF CONTRA COSTA PRESTON WRIGHT, J Case No.: C15-01555 2 Plaintiff, y ) DECLARATION OF MIKE ABEL IN vs. SUPPORT OF MOTION TO QUASH SERVICE OF SUMMONS NEIL COOPER and DOES 1 TO 50, o-2-7h inclusive, Date: 4. ) Time: aw my Defendants. ) Location: Department 9 Hon. Judith S. Craddick Accompanying: Documents: 1 Notice of Motion, Memorandum of Points and Authorities; Jy 2. Declaration of Thomas K. Hockel; 3. Declaration of Neil Cooper; and p 4. Proposed Order. , I, Mike Abel, declare: 1. 1am an attorney at law duly licensed to practice by the State of Arizona. I am submitting this declaration in support of defendant Neil Cooper’s (“Cooper”) motion to quash service of summons. I have personal knowledge of the facts stated in this declaration and could competently testify to those facts if called upon to do so. ‘DECLARATION OF MIKE ABEL IN SUPPORT OF MOTION TO QUASH SERVICE OF SUMMONS Case No.: C15-01555 *%v ur 2. Cooper initially retained me to assist him with the complaint he received in this matter. | sent a letter of representation to counsel for plaintiff Preston Wright (“Wright”) on September 22, 2015. I asked for an extension of time to respond to the complaint so the parties could exchange information and explore a resolution of the dispute. 3. On October 5, 2015, Alice Freeman (“Freeman”) from Plaintiff's counsel's office sent an email to me stipulating to an extension of time to respond to the complaint through | November 15, 2015. 4, The parties exchanged some information, but it took longer than anticipated. As such, I secured a further stipulation from Wright’s counsel to extend the time to respond through December 1, 2015, which was confirmed in a letter from Wright’s counsel, dated November 9, 2015. 5. The parties continued to work toward a possible resolution, and Plaintiff's counsel stipulated to a further extension for Cooper to answer or otherwise respond until January 1, 2015, 6. Ultimately, the parties’ efforts toward a resolution were unsuccessful, and | then assisted Cooper in locating California counsel. I declare under the penalty of perjury under the laws of the State of California that the foregoing is iue and correct. Dated: [ee] PIS DECLARATION OF MIKE ABEL IN SUPPORT OF MOTION TO QUASH SERVICE OF SUMMONS Cuse No; C15-01855oD me IN DH PB WN PROOF OF SERVICE Preston Wright v. Neil Cooper Contra Costa County Superior Court Case No: C15-01555 I, EZRA M. DENMAN, declare: I work in the City and County of San Francisco, State of Califomia. My business address is 44 Montgomery Street, Suite 1500, San Francisco, California 94104. I am over the age of 18 years and not a party to the foregoing action. On December 18, 20151 served the following Documents: DECLARATION OF MIKE ABEL IN SUPPORT OF MOTION TO QUASH SERVICE OF SUMMONS, on the interested parties in said action, Jeffrey J. Rooney, Esq. Brule & Rooney 319 Diablo Road, Suite 200 Danville, CA 94526 Attorney for Plaintiff _X__—_ (by mail) by placing a true copy thereof enclosed in a sealed envelope in a designated area for outgoing mail, addressed as set forth above. At Kelly, Hockel & Klein P.C., mail placed in that designated area is given the correct amount of postage and is deposited that same day, in the ordinary course of business, in a United States mailbox in the City of San Francisco, California. _— _ (by personal delivery) by causing the document(s) listed above to be personally delivered to the person(s) at the address(es) set forth above. (by Federal Express) by depositing a true copy thereof in a sealed packet for overnight delivery, with charges thereon fully prepaid, in a Federal Express collection box, at San Francisco, California, and addressed as set forth above. (by electronic transmission) by electronically mailing a true and correct copy through Kelly, Hockel & Klein PC’s electronic mail system to the email address(es). I declare under penalty of perjury and the laws of the United States that the foregoing is true and correct and that this declaration was executed on December 18, 2015 at San Francisco, California. Oo EZRAM. DENMAN, Proof of Service