On May 29, 2020 a
Party Discovery
was filed
involving a dispute between
Gomez, Ricardo,
and
Besheer, Nicholas Adam,
City Of Rialto A Government Entity,
City Of Rialto Police Department A Government Entity,
for Personal Injury Motor Vehicle Unlimited
in the District Court of San Bernardino County.
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Michael Karns, Esq. (SBN 232256)
t‘:
William Karns, Esq. (SBN 238599)
Timothy Mitchell, Esq. (SBN 234130)
w
Karns & Karns, LLP F LE
l
SUPERIOR COURT OF
800 West 6th Street, Suite 800 CALIFO
CSOAJNTY OF SAN BERNARDIS'OWA
Los Angeles, CA 90017 N BERNARDINO
DISTRICT
Tel: (310) 623—9032
\DOOflQUI-PWNH
Fax: (310) 623-9033 JUN 01 2022
Email: tim@kamsandkams.com
BY:
Attorneys for Plaintiff RICARDO GOMEZ Cesar R. Lep’i,
Deputy
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO
RICARDO GOMEZ, an Individual; Case No.: CIVDSZOO9827
Assigned to Hon. Thomas Garza
Plaintiff,
Dept: 827
VS.
PROOF OF SERVICE
1. OPPOSITION TO REPLY TO
CITY OF RIALTO POLICE DEPARTMENT, MOTION FOR
a Government Entity; CITY OF RIALTO, a
RECONSIDERATION
Government entity; NICHOLAS ADAM 2. DECLARATION OF TIMOTHY P.
NNNNNNNNNt—lt—tr—Ar—r—ny—th—nr—Ar—dt—I
BESHEER, an Individual; and DOES 1
MITCHELL
through 50, Inclusive;
3. DECLARATION OF LEAH STEIN
Defendants
4. DECLARATION OF MICAHEL
WQQMAWNHOOWQCthl-HNHO
BARKER
Complaint Filed: May 20, 2020
Trial Date: May 23, 2022
‘
PC“ ~
1
PROOF OF SERVICE
PROOF 0F SERVICE
STATE OF CALIFORNIA, COUNTY 0F LOS ANGELES
I am an employee in the County of Los Angeles, State of California. I am over the age of 18 and
party to the within action. My business address is 800 West 6‘h Street, Los Angeles, CA
1918:)?
7.
1, 2022, I served the foregoing document, described as: REPLY T0 OPPOSITION
On June
TO MOTION FOR RECONSIDERATION; DECLARATION OF TIMOTHY P.
MITCHELL, ESQ.; DECLARATION 0F LEAH STEIN; DECLARATION 0F
MICHAEL BARKER on all interested parties in this action by placing a true copy thereof in a
sealed envelope, addressed as follows:
SEE ATTACHED SERVICE LIST
10 D (BY PERSONAL SERVICE) I caused such envelope t0 be delivered by hand t0 the
attorney at the offices of the addressee.
11
E] (BY OVERNIGHT DELIVERY) I caused a true copy thereof to be enclosed in a
12 sealed envelope With delivery fees provided for, and to be deposited in the box regularly
maintained by Federal Express in Los Angeles, CA.
l3
l4 g (BY ELECTRONIC MAIL) Based 0n a court order or an agreement with opposing
counsel to accept service of documents electronically, I caused the documents to be sent
to the persons at the e—mail address(es) listed on the above service list. I did not receive,
15
within a reasonable time after the transmission, any electronic message 0r other
16 indication that the transmission was unsuccessful.
l7 D (BY FACSIMILE) I sent such document Via facsimile mail to the number(s) noted
above. The transmission was reported as complete and without error, and the
l8 transmitting facsimile machine properly issued the transmission report.
l9 D (BY MAIL) Asfonows:
20 Iplaced such envelope, with postage thereon prepaid, in the United States mail at Los
Angeles, California. I am “readily familiar” with the firm’s practice of collecting and
21 processing correspondence for mailing. Under that practice, it would be deposited with
the U.S. Postal Service on that same day, with postage thereon fully prepaid, at Los
22
Angeles, California, in the ordinary course of business. I am aware that, on motion of the
party served, service is presumed invalid if the postal cancellation or postage meter date
23
is more than one day after the date of deposit for mailing in this affidavit.
24
K4 (STATE) I declare, under penalty of perjury under the laws of the State of California,
25 that the above is true and correct.
26 Executed on June 1, 2022, at Los Angeles, Californigf
27
Léafl‘smr)
28
PROOF OF SERVICE
Document Filed Date
June 01, 2022
Case Filing Date
May 29, 2020
Category
Personal Injury Motor Vehicle Unlimited
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Michael Karns, Esq. (SBN 232256) t‘: William Karns, Esq. (SBN 238599) Timothy Mitchell, Esq. (SBN 234130) w Karns & Karns, LLP F LE l SUPERIOR COURT OF 800 West 6th Street, Suite 800 CALIFO CSOAJNTY OF SAN BERNARDIS'OWA Los Angeles, CA 90017 N BERNARDINO DISTRICT Tel: (310) 623—9032 \DOOflQUI-PWNH Fax: (310) 623-9033 JUN 01 2022 Email: tim@kamsandkams.com BY: Attorneys for Plaintiff RICARDO GOMEZ Cesar R. Lep’i, Deputy SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO RICARDO GOMEZ, an Individual; Case No.: CIVDSZOO9827 Assigned to Hon. Thomas Garza Plaintiff, Dept: 827 VS. PROOF OF SERVICE 1. OPPOSITION TO REPLY TO CITY OF RIALTO POLICE DEPARTMENT, MOTION FOR a Government Entity; CITY OF RIALTO, a RECONSIDERATION Government entity; NICHOLAS ADAM 2. DECLARATION OF TIMOTHY P. NNNNNNNNNt—lt—tr—Ar—r—ny—th—nr—Ar—dt—I BESHEER, an Individual; and DOES 1 MITCHELL through 50, Inclusive; 3. DECLARATION OF LEAH STEIN Defendants 4. DECLARATION OF MICAHEL WQQMAWNHOOWQCthl-HNHO BARKER Complaint Filed: May 20, 2020 Trial Date: May 23, 2022 ‘ PC“ ~ 1 PROOF OF SERVICE PROOF 0F SERVICE STATE OF CALIFORNIA, COUNTY 0F LOS ANGELES I am an employee in the County of Los Angeles, State of California. I am over the age of 18 and party to the within action. My business address is 800 West 6‘h Street, Los Angeles, CA 1918:)? 7. 1, 2022, I served the foregoing document, described as: REPLY T0 OPPOSITION On June TO MOTION FOR RECONSIDERATION; DECLARATION OF TIMOTHY P. MITCHELL, ESQ.; DECLARATION 0F LEAH STEIN; DECLARATION 0F MICHAEL BARKER on all interested parties in this action by placing a true copy thereof in a sealed envelope, addressed as follows: SEE ATTACHED SERVICE LIST 10 D (BY PERSONAL SERVICE) I caused such envelope t0 be delivered by hand t0 the attorney at the offices of the addressee. 11 E] (BY OVERNIGHT DELIVERY) I caused a true copy thereof to be enclosed in a 12 sealed envelope With delivery fees provided for, and to be deposited in the box regularly maintained by Federal Express in Los Angeles, CA. l3 l4 g (BY ELECTRONIC MAIL) Based 0n a court order or an agreement with opposing counsel to accept service of documents electronically, I caused the documents to be sent to the persons at the e—mail address(es) listed on the above service list. I did not receive, 15 within a reasonable time after the transmission, any electronic message 0r other 16 indication that the transmission was unsuccessful. l7 D (BY FACSIMILE) I sent such document Via facsimile mail to the number(s) noted above. The transmission was reported as complete and without error, and the l8 transmitting facsimile machine properly issued the transmission report. l9 D (BY MAIL) Asfonows: 20 Iplaced such envelope, with postage thereon prepaid, in the United States mail at Los Angeles, California. I am “readily familiar” with the firm’s practice of collecting and 21 processing correspondence for mailing. Under that practice, it would be deposited with the U.S. Postal Service on that same day, with postage thereon fully prepaid, at Los 22 Angeles, California, in the ordinary course of business. I am aware that, on motion of the party served, service is presumed invalid if the postal cancellation or postage meter date 23 is more than one day after the date of deposit for mailing in this affidavit. 24 K4 (STATE) I declare, under penalty of perjury under the laws of the State of California, 25 that the above is true and correct. 26 Executed on June 1, 2022, at Los Angeles, Californigf 27 Léafl‘smr) 28 PROOF OF SERVICE