On November 09, 2022 a
Order to Show Cause
was filed
involving a dispute between
Nouaux, Alexander Jacques,
and
Does 1 To 100,
Xxxxxx, Xxxxxx Xxxxx,
for PERSONAL INJURY/PROPERTY DAMAGE - VEHICLE RELATED
in the District Court of San Francisco County.
Preview
Lawrence D. Murray (SBN 77536)
MURRAY & ASSOCIATES
650 5'" Street, Suite 514
2 ELECTRONICALLY
San Francisco, CA 94107
3 Tel: (415) 673-0555 FILED
Superior Court of California,
County of San Francisco
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Attorney for Plaintiff 12/21/2023
ALEXANDER JACQUES NOUAUX Clerk of the Court
5 BY: WILLIAM TRUPEK
Deputy Clerk
6 SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
ALEXANDER JACQUES NOUAUX, Case No. CGC-22-602841
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RESPONSE TO ORDER TO SHOW CAUSE RE
Plaintiff, DISMISSAL
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vs. Date: January 23, 2024
Time: 10:30 a.m.
12 xxxxxx xxxxx xxxxxx, et al. Dept: 610
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Defendants. Complaint Filed: November 9, 2022
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I, Lawrence D. Murray, declare that:
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l. I am a duly licensed attorney in the State of California and as such am the attorney of record for
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plaintiff in this action. By virtue of my involvement in this case, I am familiar with the facts I
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testify to below. I have personal knowledge of the facts set forth herein, and if called to testify,
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would and could testify completely thereto.
2. This action was filed on November 9, 2022.
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3. I believe the parties have agreed to settle this matter.
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4. I have started drafting and intend to file a motion with this court for approval of the settlement and
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subsequent disbursements, which would extinguish any and all other lien claims so that it is a full
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and final disbursement settleing all liens.
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5. I am in the process of (1) obtaining the pertinent medical records and bills, (2) negotiating with
third party claimants, and (3) drafting the motion to be filed.
6. The difficulty is that there is a minimal policy for more than six figures in medical liens. I have
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been in repeated contct with each medical lien claimant and I believe that we may well have a
deal to settle this case and extinguish all liens.
Nouuux vs. xxxxxx; San Francisco County Superior Court No. CGC-22-602841 PAGE I
Response to Order to Show Cause
7. It is respectfully requested that this hearing be continued at least four months for adequate time
2 fior all settlement documents and the hearing on the Order to Show Cause Re Settlement of All
Liens.
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I declare under penalty of perjury that the foregoing is true an ect. This declaration was
executed in San Francisco, California on December 21, 2023.
trier /Ada
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Lawrence D. Murray
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Nouaux vs. xxxxxx; San Francisco County Superior Court No. CGC-22-602841 PAGE 2
Response to Order to Show Cause
I PROOF OF SERVICE
I am employed in the City and County of San Francisco, State of California. I am over the age of
18 and not a party to the within action. My business address is 650 5ra Street, Suite 514, San Francisco,
4 California 94107; (415) 673-0555. On this date, I served the following document(s): RESPONSE TO
ORDER TO SHOW CAUSE RE DISMISSAL on the interested parties in this action as follows:
Anthony F. Pinelli aninelli wnclaw.corn
Gina D. Huettel uhuettelRwnclaw.corn
Williams, Pinelli & Cullen Attorney for Defendant xxxxxx xxxxxx
1960 The Alameda, Suite 195 Tel: (408) 288-3686
San Jose, CA 95126 Fax: (408) 288-3860
10 City and County of San Francisco For Lien Claimant City and County of San Francisco
Delinquent Revenue Collection via email: wah-mehlew sfgov.org
ll City Hall Zuckerberg San Francisco General Hospital/San
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San Francisco, CA 94102 Francisco Fire Department Ambulance Account: 101880788
Current Lien Balance: $ 75,999.59
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Grant Mercantile Agency, Inc. Via US Mail and Email: gma@sti.net and
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P. O. Box 658 info@grantmercantile.corn
15 Oakhurst, CA 93644 King-American Ambulance Date of Loss: January 19, 2021
GMA Account No.: 3327199
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Mons Curtis
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Sr Recovery Specialist Phone: 844.709.6877 Fax: 800.842.8810
18 11000 Optum Circle E-mail:Mons.M.CurtisNOptum.corn
MD-102-0300 Injured Party: Alex Nouaux Date of Injury: 1/19/2021
19 Eden Praire, MN 55344 Group: INHERITANCE FUNDING COMPANY,
¹0000F9938 File ¹: 103320588
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[ ] [BY PERSONAL SERVICE] I caused such envelope(s) to be delivered by hand to the above
22 address(es).
23 [BY EMAIL] I caused such document(s) to be served on the parties listed in this action via
[XX]
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email to the email addresses shown above.
25 [XX] [BY MAIL] I caused envelope(s) with postage thereon fully prepaid to be placed in the United
States mail at San Francisco, California, addressed as shown above.
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27 [ ] [BY E-SERVICE] I caused such document(s) to be served via e-service on the parties listed
above.
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[ ] [BY PERSONAL SERVICE BY FAX] I caused the above entitled document(s) to be
personally served on the above shown parties by facsimile transmission on the date shown below
Nousux vs. Sfer/e; San Francisco County Superior Court No. CGC-22-602841 PAGE 3
Response to Order to Show Cause
by confirming the fax phone number with the law office shown above then (a) transmitting it via
the fax machine within this office, and (b) receiving a receipt from the machine within this office
confirming all documents sent were in fact properly received.
3 I declare under penalty of perjury under the laws of the State of California that the above is true
4 and correct. Executed in San Francisco, California, on December 21, 2023.
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Nouaux vs. xxxxxx; San Francisco County Superior Court No. CGC-22-602841 PAGE 4
Response to Order to Show Cause
Document Filed Date
December 21, 2023
Case Filing Date
November 09, 2022
Category
PERSONAL INJURY/PROPERTY DAMAGE - VEHICLE RELATED
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Lawrence D. Murray (SBN 77536) MURRAY & ASSOCIATES 650 5'" Street, Suite 514 2 ELECTRONICALLY San Francisco, CA 94107 3 Tel: (415) 673-0555 FILED Superior Court of California, County of San Francisco 4 Attorney for Plaintiff 12/21/2023 ALEXANDER JACQUES NOUAUX Clerk of the Court 5 BY: WILLIAM TRUPEK Deputy Clerk 6 SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO ALEXANDER JACQUES NOUAUX, Case No. CGC-22-602841 9 RESPONSE TO ORDER TO SHOW CAUSE RE Plaintiff, DISMISSAL 10 vs. Date: January 23, 2024 Time: 10:30 a.m. 12 xxxxxx xxxxx xxxxxx, et al. Dept: 610 13 Defendants. Complaint Filed: November 9, 2022 14 I, Lawrence D. Murray, declare that: 16 l. I am a duly licensed attorney in the State of California and as such am the attorney of record for 17 plaintiff in this action. By virtue of my involvement in this case, I am familiar with the facts I 18 testify to below. I have personal knowledge of the facts set forth herein, and if called to testify, 19 would and could testify completely thereto. 2. This action was filed on November 9, 2022. 20 21 3. I believe the parties have agreed to settle this matter. 22 4. I have started drafting and intend to file a motion with this court for approval of the settlement and 23 subsequent disbursements, which would extinguish any and all other lien claims so that it is a full 24 and final disbursement settleing all liens. 25 5. I am in the process of (1) obtaining the pertinent medical records and bills, (2) negotiating with third party claimants, and (3) drafting the motion to be filed. 6. The difficulty is that there is a minimal policy for more than six figures in medical liens. I have 27 28 been in repeated contct with each medical lien claimant and I believe that we may well have a deal to settle this case and extinguish all liens. Nouuux vs. xxxxxx; San Francisco County Superior Court No. CGC-22-602841 PAGE I Response to Order to Show Cause 7. It is respectfully requested that this hearing be continued at least four months for adequate time 2 fior all settlement documents and the hearing on the Order to Show Cause Re Settlement of All Liens. 4 I declare under penalty of perjury that the foregoing is true an ect. This declaration was executed in San Francisco, California on December 21, 2023. trier /Ada 7 Lawrence D. Murray 10 12 13 14 15 16 17 18 19 20 21 22 25 26 27 28 Nouaux vs. xxxxxx; San Francisco County Superior Court No. CGC-22-602841 PAGE 2 Response to Order to Show Cause I PROOF OF SERVICE I am employed in the City and County of San Francisco, State of California. I am over the age of 18 and not a party to the within action. My business address is 650 5ra Street, Suite 514, San Francisco, 4 California 94107; (415) 673-0555. On this date, I served the following document(s): RESPONSE TO ORDER TO SHOW CAUSE RE DISMISSAL on the interested parties in this action as follows: Anthony F. Pinelli aninelli wnclaw.corn Gina D. Huettel uhuettelRwnclaw.corn Williams, Pinelli & Cullen Attorney for Defendant xxxxxx xxxxxx 1960 The Alameda, Suite 195 Tel: (408) 288-3686 San Jose, CA 95126 Fax: (408) 288-3860 10 City and County of San Francisco For Lien Claimant City and County of San Francisco Delinquent Revenue Collection via email: wah-mehlew sfgov.org ll City Hall Zuckerberg San Francisco General Hospital/San 12 San Francisco, CA 94102 Francisco Fire Department Ambulance Account: 101880788 Current Lien Balance: $ 75,999.59 13 Grant Mercantile Agency, Inc. Via US Mail and Email: gma@sti.net and 14 P. O. Box 658 info@grantmercantile.corn 15 Oakhurst, CA 93644 King-American Ambulance Date of Loss: January 19, 2021 GMA Account No.: 3327199 16 Mons Curtis 17 Sr Recovery Specialist Phone: 844.709.6877 Fax: 800.842.8810 18 11000 Optum Circle E-mail:Mons.M.CurtisNOptum.corn MD-102-0300 Injured Party: Alex Nouaux Date of Injury: 1/19/2021 19 Eden Praire, MN 55344 Group: INHERITANCE FUNDING COMPANY, ¹0000F9938 File ¹: 103320588 20 21 [ ] [BY PERSONAL SERVICE] I caused such envelope(s) to be delivered by hand to the above 22 address(es). 23 [BY EMAIL] I caused such document(s) to be served on the parties listed in this action via [XX] 24 email to the email addresses shown above. 25 [XX] [BY MAIL] I caused envelope(s) with postage thereon fully prepaid to be placed in the United States mail at San Francisco, California, addressed as shown above. 26 27 [ ] [BY E-SERVICE] I caused such document(s) to be served via e-service on the parties listed above. 28 [ ] [BY PERSONAL SERVICE BY FAX] I caused the above entitled document(s) to be personally served on the above shown parties by facsimile transmission on the date shown below Nousux vs. Sfer/e; San Francisco County Superior Court No. CGC-22-602841 PAGE 3 Response to Order to Show Cause by confirming the fax phone number with the law office shown above then (a) transmitting it via the fax machine within this office, and (b) receiving a receipt from the machine within this office confirming all documents sent were in fact properly received. 3 I declare under penalty of perjury under the laws of the State of California that the above is true 4 and correct. Executed in San Francisco, California, on December 21, 2023. 10 12 13 14 15 16 17 18 19 20 21 23 24 25 26 27 28 Nouaux vs. xxxxxx; San Francisco County Superior Court No. CGC-22-602841 PAGE 4 Response to Order to Show Cause