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WILLIAM A. BRUCE, ESQ. — SBN 91633
CLIFFORD & BROWN
A Professional Corporation.
Attorneys at Law
Bank of America Building
1430 Truxtun Avenue, Suite 900
Bakersfield, CA 93301-5230 [Filing fee exempt
Email: bbruce@clifford-brownlaw.com Gov. Code § 6103]
Tel: (661) 322-6023 Fax: (661) 322-3508
Attorneys for Defendant,
CITY OF BAKERSFIELD
SUPERIOR COURT OF CALIFORNIA, COUNTY OF KERN
METRO JUSTICE BUILDING
10 #ORK
11 RICHARD RAWLINGS, CASE NO. BCV-21-101873 TSC
Complaint filed: 8/13/2021
12 Plaintiff, Trial Date: 10/14/2024
13 DEFENDANT CITY OF BAKERFIELD’S
VS. NOTICE OF JOINDER AND JOINDER IN
14 DEFENDANT CALIFORNIA
DEPARTMENT OF TRANSPORTATION’S
15 CALIFORNIA DEPARTMENT OF MOTION FOR AN ORDER TO
TRANSPORTATION (CAL TRANS), a BIFURCATE TRIAL
16 California Government Entity;
CITY OF BAKERSFIELD, a California
17 Government Entity; and Date: March 13, 2024
COUNTY OF BAKERSFIELD, a California Time: 8:30 a.m.
18 Government Entity; and Dept.: 17
DOES 1 through 100, inclusive,
19
Defendants.
20
21 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
22 PLEASE TAKE NOTICE that Defendant CITY OF BAKERSFIELD, will and hereby does
23 join Defendant CALIFORNIA DEPARTMENT OF TRANSPORTATION’s Motion for an Order to
24 Bifurcate Trial.
25 DATED: March 11, 2024 CLIFFQRD & BROWN,
26 B
WILLIAM A. BRUCE, ESQ.
27
Attorneys for Defendant,
28 CITY OF BAKERSFIELD
1
DEFENDANT CITY OF BAKERFIELD’S NOTICE OF JOINDER AND JOINDER IN DEFENDANT CALIFORNIA
DEPARTMENT OF TRANSPORTATION’S MOTION FOR AN ORDER TO BIFURCATE TRIAL
PROOF OF SERVICE
STATE OF CALIFORNIA COUNTY OF KERN:
n years and not a party to
Lam a resident of the County aforesaid; I am over the age of eightee
, Suite 900, Bakersfield,
the within entitled action; my business address i s 1430 Truxtun Avenue
w.com
California, 93301. My electronic address is: tmjones@clifford-brownla
BAKERSFIELD’S
On March 11, 2024, I served the within DEFENDANT CITY OF
ORNIA DEPA RTMENT OF
NOTICE OF JOINDER AND JOINDER IN DEFENDANT CALIF
CATE TRIAL on the interested
TRANSPORTATION’S MOTION FOR AN ORDER TO BIFUR
parties in said action, as listed below:
[SEE ATTACHED MAILING LIST]
(XX) ONLY BY ELECTRONIC TRANSMISSION [CCP § 1010.6]. Only by e-mailing the
10 this office will not send
document(s) to the person(s) at the e-mail address(es) listed below,
electronic message or
11 physical mail as usual, and is therefore using only electronic mail. No
a reasonable time
other indication that the transmission was unsuccessful was received within
12 after the transmission.
facsimile
13 VIA FACSIMILE — [C.C.P. § 1013(e)]; - The telephone number of the sending
e machine(s)
machine was (661) 322-3508. The telephone(s) number of the receiving facsimil
14 by the machine . Pursuant to
is listed below. The Court, Rule 2004 and no error was reported
print a transmission record
15) California Rules of Court, Rule 2006(d), the machine was caused to
of the transmission, a copy of which is attached hereto.
16
ion and processing of
() BY MAIL I am readily familiar with the business’ practice for collect
Under that
17 correspondence and documents for mailing with the United States Postal Service.
U: nited States Postal
practice, the correspondence and documents would be deposited with the
18 y course of business at
Service that same day, with postage thereon fully prepaid, in the ordinar
19 Bakersfield, California.
20 (XX) BY PERSONAL SERVICE was served by messenger service and delivered by hand to the
offices of the addressee.
21
ia, that the foregoing
22 I declare, under penalty of perjury under the laws of the State of Californ
is true and correct.
23
Executed on March 11, 2024, at Bakersfield, California.
24
LLIN. M. Lyon ZA
25 ~ 7TYREANA M. JONES
26
27
28
MAILING LIST
Richard Rawlings v. California Department of Transportation (Cal Trans), et al.
Superior Court of California, County of Kern, Case No. BCV-21-101873 TSC
Gabriel Sepulveda-Sanchez, Esq. Attorneys for Plaintiff,
Sepulveda Sanchez Law, PC Richard Rawlings
811 Traction Avenue, Suite 2A
Los Angeles, CA 90013
Email: Gabriel@sepulvedalawgroup.com
saundra@sepulvedalawgroup.com
vanessa@sepulvedalawgroup.com
(213) 426-1051
(213) 426-1052 (fax)
10 Kevin W. O’Hara, Esq. Attorney for Plaintiff,
O’Hara Law APC Richard Rawlings
ll
1730 W Cameron Ave, Ste. 200,
12 West Covina, CA 91790;
Email: kevin@oharalawapce.com
13 ashley@oharalawapc.com
Tel/Fax: 310-525-5882
14
15 Attorneys for Defendant,
Erin E. Holbrook, Esq.
16 Alan M. Steinberg, Esq. California Department of
Paul R. Brown, Esq. Transportation
17 Nikolette Y. Clavel, Esq.
1120 “N” Street (MS 57), P.O. Box 1438
18 Sacramento, CA 95812-1438
19 Email: nikolette.clavel@dot.ca.go
Brandon.Ball \dot.ca.go
20 Angela.Hamdan@dot.ca.gov
edward. batista@dot.ca.gov
21 obert. vaghini@dot.ca.go’
CaltransHQService@dot.ca.gov.
22
23 (916) 654-2630
(916) 654-6128 (fax)
24
25
26
27
28
Preview
WILLIAM A. BRUCE, ESQ. — SBN 91633 CLIFFORD & BROWN A Professional Corporation. Attorneys at Law Bank of America Building 1430 Truxtun Avenue, Suite 900 Bakersfield, CA 93301-5230 [Filing fee exempt Email: bbruce@clifford-brownlaw.com Gov. Code § 6103] Tel: (661) 322-6023 Fax: (661) 322-3508 Attorneys for Defendant, CITY OF BAKERSFIELD SUPERIOR COURT OF CALIFORNIA, COUNTY OF KERN METRO JUSTICE BUILDING 10 #ORK 11 RICHARD RAWLINGS, CASE NO. BCV-21-101873 TSC Complaint filed: 8/13/2021 12 Plaintiff, Trial Date: 10/14/2024 13 DEFENDANT CITY OF BAKERFIELD’S VS. NOTICE OF JOINDER AND JOINDER IN 14 DEFENDANT CALIFORNIA DEPARTMENT OF TRANSPORTATION’S 15 CALIFORNIA DEPARTMENT OF MOTION FOR AN ORDER TO TRANSPORTATION (CAL TRANS), a BIFURCATE TRIAL 16 California Government Entity; CITY OF BAKERSFIELD, a California 17 Government Entity; and Date: March 13, 2024 COUNTY OF BAKERSFIELD, a California Time: 8:30 a.m. 18 Government Entity; and Dept.: 17 DOES 1 through 100, inclusive, 19 Defendants. 20 21 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 22 PLEASE TAKE NOTICE that Defendant CITY OF BAKERSFIELD, will and hereby does 23 join Defendant CALIFORNIA DEPARTMENT OF TRANSPORTATION’s Motion for an Order to 24 Bifurcate Trial. 25 DATED: March 11, 2024 CLIFFQRD & BROWN, 26 B WILLIAM A. BRUCE, ESQ. 27 Attorneys for Defendant, 28 CITY OF BAKERSFIELD 1 DEFENDANT CITY OF BAKERFIELD’S NOTICE OF JOINDER AND JOINDER IN DEFENDANT CALIFORNIA DEPARTMENT OF TRANSPORTATION’S MOTION FOR AN ORDER TO BIFURCATE TRIAL PROOF OF SERVICE STATE OF CALIFORNIA COUNTY OF KERN: n years and not a party to Lam a resident of the County aforesaid; I am over the age of eightee , Suite 900, Bakersfield, the within entitled action; my business address i s 1430 Truxtun Avenue w.com California, 93301. My electronic address is: tmjones@clifford-brownla BAKERSFIELD’S On March 11, 2024, I served the within DEFENDANT CITY OF ORNIA DEPA RTMENT OF NOTICE OF JOINDER AND JOINDER IN DEFENDANT CALIF CATE TRIAL on the interested TRANSPORTATION’S MOTION FOR AN ORDER TO BIFUR parties in said action, as listed below: [SEE ATTACHED MAILING LIST] (XX) ONLY BY ELECTRONIC TRANSMISSION [CCP § 1010.6]. Only by e-mailing the 10 this office will not send document(s) to the person(s) at the e-mail address(es) listed below, electronic message or 11 physical mail as usual, and is therefore using only electronic mail. No a reasonable time other indication that the transmission was unsuccessful was received within 12 after the transmission. facsimile 13 VIA FACSIMILE — [C.C.P. § 1013(e)]; - The telephone number of the sending e machine(s) machine was (661) 322-3508. The telephone(s) number of the receiving facsimil 14 by the machine . Pursuant to is listed below. The Court, Rule 2004 and no error was reported print a transmission record 15) California Rules of Court, Rule 2006(d), the machine was caused to of the transmission, a copy of which is attached hereto. 16 ion and processing of () BY MAIL I am readily familiar with the business’ practice for collect Under that 17 correspondence and documents for mailing with the United States Postal Service. U: nited States Postal practice, the correspondence and documents would be deposited with the 18 y course of business at Service that same day, with postage thereon fully prepaid, in the ordinar 19 Bakersfield, California. 20 (XX) BY PERSONAL SERVICE was served by messenger service and delivered by hand to the offices of the addressee. 21 ia, that the foregoing 22 I declare, under penalty of perjury under the laws of the State of Californ is true and correct. 23 Executed on March 11, 2024, at Bakersfield, California. 24 LLIN. M. Lyon ZA 25 ~ 7TYREANA M. JONES 26 27 28 MAILING LIST Richard Rawlings v. California Department of Transportation (Cal Trans), et al. Superior Court of California, County of Kern, Case No. BCV-21-101873 TSC Gabriel Sepulveda-Sanchez, Esq. Attorneys for Plaintiff, Sepulveda Sanchez Law, PC Richard Rawlings 811 Traction Avenue, Suite 2A Los Angeles, CA 90013 Email: Gabriel@sepulvedalawgroup.com saundra@sepulvedalawgroup.com vanessa@sepulvedalawgroup.com (213) 426-1051 (213) 426-1052 (fax) 10 Kevin W. O’Hara, Esq. Attorney for Plaintiff, O’Hara Law APC Richard Rawlings ll 1730 W Cameron Ave, Ste. 200, 12 West Covina, CA 91790; Email: kevin@oharalawapce.com 13 ashley@oharalawapc.com Tel/Fax: 310-525-5882 14 15 Attorneys for Defendant, Erin E. Holbrook, Esq. 16 Alan M. Steinberg, Esq. California Department of Paul R. Brown, Esq. Transportation 17 Nikolette Y. Clavel, Esq. 1120 “N” Street (MS 57), P.O. Box 1438 18 Sacramento, CA 95812-1438 19 Email: nikolette.clavel@dot.ca.go Brandon.Ball \dot.ca.go 20 Angela.Hamdan@dot.ca.gov edward. batista@dot.ca.gov 21 obert. vaghini@dot.ca.go’ CaltransHQService@dot.ca.gov. 22 23 (916) 654-2630 (916) 654-6128 (fax) 24 25 26 27 28