Party Discovery: Ashley M Naghash vs. Board Of Trustees Of The California Stat...

• 
• 
• 
• 
• 
• 

						
                                
Preview
                                Law Offices O f

                  1
                                  Roger E . N a g k a s k
                                  Bar Numker: 181740
                                                                                             D/E^OORSED
                                   One Newport Place
                  2      19900 MacArthur Boulevard, Suite 1150
                             Irvine, Califomia 92612-8433
                                                                                             JUN 1 3 2016
                  3         TelepWe:         (949) 955-1000

                  4
                            Facsimile:        (949)852-9511                           By:.           A. MALONE
                                                                                                 DEPUTY CLERK

                  5 Attomeys for: Plaintiff, Ashley M. Naghash
                  6
                  7                       SUPERIOR COURT OF THE STATE OF CALIFORNIA
                  8                              IN AND FOR COUNTY OF SACRAMENTO
                  9
                  10
                        ASHLEY M. NAGHASH, ,                                 CASENO.: 34-2011-00113923
  o
  in              11
                                               Plaintiff,
J^          O
            O
                  12-
            O
•on B I                       vs.
Z ^   If)         13
      m                                                                      NOTICE OF MOTION AND MOTION TO
                  14 BOARD OF TRUSTEES OF THE                                STAY ACTION AND TOLL THE FIVE
            I-H

                        CALIFORNIA STATE UNIVERSITY, THE                     YEAR STATUTE TO BRING ACTION TO
                  15                                                         TRIAL PENDING APPEAL [CCP §§
                        STATE OF CALIFORNIA, THE                             583.320(a)(3), 583.340(b)]
o 41    V    V
                  16    CALIFORNIA STATE UNIVERSITY, THE
Et' ^   .9 75           CALIFORNIA STATE UNIVERSITY,
J3 8              17    SACRAMENTO, ALEXANDER
                        GONZALEZ, MICHAEL SPEROS, TERRY
                  18    JOSEPH RICHARDS Also Known As TERRY
                        RICHARDS, Also Known As TERRY J.                     Date:           July 8,2016
                  19                                                         Time:           2:00 p.m.
                        RICHARDS, APRIL PHILIPS, WIN CHEN,
                                                                             Dept.:          53
                  20    ADAM MENARD, ARIEL CAMPBELL, and
                        DOES 1 Through 100, Inclusive,
                  21
                  22
                  23                                                         Complaint Filed on November 14,2011
                                                Defendants.
                  24
                  25
                  26
                  27
                  28



                                                  AMN - MOTION To STAY ACTION PENDING APPEAL -   NOTICE   -1
               1           TO:     ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
              2
              3            NOTICE IS HEREBY GIVEN that on July 8,2016, at 2:00 p.m., or as soon thereafter as the
              4     matter may be heard, in Department 53 ofthis court, located at 800 9"' Street, Sacramento,
              5     Califomia 95814, Plaintiff, ASHLEY M. NAGHASH will move for an order to stay action pending
              6     the outcome of trial of this action as to the remaining defendants.
              7            The motion will be based on this notice of motion. Declaration of Roger E. Naghash,
              8     Memorandimi of Points and Authorities, served and filed with it, on the records, and file in this
              9     action, and pn any evidence that may be presented at the hearing of the motions.
              10
  o           11
                                                                               Law Offices Of Roger E. Naghash
         o    12-
         o
         o
              13
       rt-*   14
os     o ix         Dated this 7"* day of June 2016
              15                                                                  Roger E. Naghash, Esq.
O J           16                                                                  Attomey for Plaintiff
: s^                                                                              Ashley M. Naghash
J3 8          17
              18
              19
              20
              21
              22
              23
              24
              25
              26
              27
              28



                                               AMN - MOTION To   STAY ACTION PENDING APPEAL - NOTICE -   2
 1                                           PROOF OF SERVICE
              I, the imdersigned, certify and declare as follows:
2             I am employed in the County of Orange and my business address and telephone number are
3     19900 MacArthur Boulevard Suite 1150, Irvine, California 92612-8433, (949) 955-1000. I am
      over the age of 18 years. I am readily familiar with the practices of Law Offices Of Roger E.
4     Naghash for collection and processing of correspondence for mailing with the United States Postal
      Service. Such correspondence is deposited with the United States Postal Service the same day in
 5    the ordinary course of business.
6            On June 9,2016,1 served the following docimients, entitled:
7
             • Notice of Motion and Motion to Stay Action or Toll Five Year Statute to Bring
8              Action to Trial Pending Appeal [CCP §§ 583.320(a)(3), 583.340(b)];
             • Memorandum of points and authorities; and
9            • Declaration of Roger E. Naghash in support thereto - Naghash V. Board of
10             Trustees OfThe California State University, et aL,

11           on the interested parties in the action as follows:
12. [XX] By placing [XX] the original [ ] a tme copy thereof enclosed in a sealed envelope addressed
13       as follows:

14"      Terry Joseph Richards                        Alberto L. Gonzalez
         2715 Wildflower Drive                        Office of Attorney General of
15       Antioch, Califomia 94531                     State of California
                                                      13001" Street
16
                                                      Sacramento, California 95814
17
18
      [XX] By United States Postal Service, I placed such envelopes for collection and to be mailed
19         on this date following ordinary business practices.
20
      [ ]    By Personal Service, I caused to be delivered the document by hand to:.
21
      [ ]    By Facsimile, I caused to be transmitted to the following fax number:
22
      [ ]    By Overnight Express - Next Day Delivery, I placed such envelopes for collection and to
23           be delivered by the U.S. Express mail carrier on this date following ordinary business
24           practices

25            I declare under penalty of perjury of Federal Laws and laws of the State of Califomia, that
      the foregoing is tnje and correct and that this declaration was executed on June 9,2016, at Irvine,
26    Califomia.
27
28
                                                                   Roger E. Naghash, Esq.