On August 16, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Abdi, Abdifatah Mohamed,
and
Does 1-20,
Kal Freight, Inc.,
Kalif, Kader Ismail,
Pro Tec, Inc.,
for Auto PI/PD/WD Unlimited
in the District Court of San Bernardino County.
Preview
CASE ATTACHMENT COVER PAGE (ENDORSED)
ELECTRONICALLY
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO FILED
STREET ADDREss;247 West Third Street
MAILING ADDRESS: BY SUPERIOR COURT
CITY AND z|p CODE; San Bernardino, CA 92415 OF CALIFORNIA, COUNTY OF
BRANCH NAME:San Bernardino Justice Center San Bernardino
WEBSITE:http //www.
z sb-court. org on Nov 30, 2021
CLERK OF THE SUPERIOR COURT
ATTACHMENTNAME; Declaration: Declaration in support of motion to strike
Deputy Clerk: Justin Manassee
CASE NAME: ABDIFATAH MOHAMED ABDI vs. KAL FREIGHT, INC CASE NUMBER:
CIVSB2123823
Please log on to www.TurboCourt.com regularly for updates
Please staple this to your original attachment
q
'unoaoqlm/fidu
/uma
\v \r
Stephen B. Heath - 237622
sheath@heathandyuen.com
Steven W. Yuen - 230768
svuen@heathandvuen.com
Matthew J. Kracht - 249076
mkracht@heathandyuen.com
UI-bWN
HEATH & YUEN, APC
268 Bush Street, #3006
San Francisco, CA 94104
Tel: (415) 622-7004
Fax: (415) 373-3957
Attorneys for Defendant
KAL FREIGHT INC, PRO TEC INC, and KADER
\OWQQ
ISMAIL KALIF
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 COUNTY OF SAN BERNARDINO
11 ABDIFATAH MOHAMED ABDI, Case No.2 CIV SB 2123823
individually
12 DECLARATION OF MATTHEW J.
Plaintiff, KRACHT IN SUPPORT OF KAL FREIGHT
13 INC, PRO TEC INC AND KADER ISMAIL
v. KALIF’S MOTION TO STRIKE
14
KAL FREIGHT, INC., a corporation; PRO TEC, Date: January 6, 2022
15 INC., a corporation; KADER
ISMAIL KALIF, Time: 9:00 a.m.
individually; DOES 1 TO 20, Judge: Hon. Khymberli S. Apaloo
16 Dept: S25
Defendants.
17 File Date: August 16, 2021
Trial Date: Not Set
18
19 I, Matthew J. Kracht, declare that:
20 1. I am an attorney duly licensed to practice in all courts of the State 0f California, and am
21 a Junior Partner with the law firm of Heath & Yuen, APC, attorneys 0f record for defendants Kal
22 Freight Inc, Pro Tec Inc and Kader Ismail Kalif. I have personal knowledge of the information set
23 forth herein below, unless noted as based on information and belief, all of which is true and correct 0f
24 my own personal knowledge, and if called upon to testify, I could and would competently testify
25 thereto.
26 2. Attached to the exhibit index as Exhibit A is a true and correct copy of plaintiff’s
27 Complaint.
28 3. Plaintiffs counsel and myself completed a telephone conference on November 17,
_ 1 -
DECLARATION OF MATTHEW KRACHT IN SUPPORT 0F DEFENDANTS’ MOTION T0 STRIKE
J.
Document Filed Date
November 30, 2021
Case Filing Date
August 16, 2021
Category
Auto PI/PD/WD Unlimited
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
CASE ATTACHMENT COVER PAGE (ENDORSED) ELECTRONICALLY SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO FILED STREET ADDREss;247 West Third Street MAILING ADDRESS: BY SUPERIOR COURT CITY AND z|p CODE; San Bernardino, CA 92415 OF CALIFORNIA, COUNTY OF BRANCH NAME:San Bernardino Justice Center San Bernardino WEBSITE:http //www. z sb-court. org on Nov 30, 2021 CLERK OF THE SUPERIOR COURT ATTACHMENTNAME; Declaration: Declaration in support of motion to strike Deputy Clerk: Justin Manassee CASE NAME: ABDIFATAH MOHAMED ABDI vs. KAL FREIGHT, INC CASE NUMBER: CIVSB2123823 Please log on to www.TurboCourt.com regularly for updates Please staple this to your original attachment q 'unoaoqlm/fidu /uma \v \r Stephen B. Heath - 237622 sheath@heathandyuen.com Steven W. Yuen - 230768 svuen@heathandvuen.com Matthew J. Kracht - 249076 mkracht@heathandyuen.com UI-bWN HEATH & YUEN, APC 268 Bush Street, #3006 San Francisco, CA 94104 Tel: (415) 622-7004 Fax: (415) 373-3957 Attorneys for Defendant KAL FREIGHT INC, PRO TEC INC, and KADER \OWQQ ISMAIL KALIF SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF SAN BERNARDINO 11 ABDIFATAH MOHAMED ABDI, Case No.2 CIV SB 2123823 individually 12 DECLARATION OF MATTHEW J. Plaintiff, KRACHT IN SUPPORT OF KAL FREIGHT 13 INC, PRO TEC INC AND KADER ISMAIL v. KALIF’S MOTION TO STRIKE 14 KAL FREIGHT, INC., a corporation; PRO TEC, Date: January 6, 2022 15 INC., a corporation; KADER ISMAIL KALIF, Time: 9:00 a.m. individually; DOES 1 TO 20, Judge: Hon. Khymberli S. Apaloo 16 Dept: S25 Defendants. 17 File Date: August 16, 2021 Trial Date: Not Set 18 19 I, Matthew J. Kracht, declare that: 20 1. I am an attorney duly licensed to practice in all courts of the State 0f California, and am 21 a Junior Partner with the law firm of Heath & Yuen, APC, attorneys 0f record for defendants Kal 22 Freight Inc, Pro Tec Inc and Kader Ismail Kalif. I have personal knowledge of the information set 23 forth herein below, unless noted as based on information and belief, all of which is true and correct 0f 24 my own personal knowledge, and if called upon to testify, I could and would competently testify 25 thereto. 26 2. Attached to the exhibit index as Exhibit A is a true and correct copy of plaintiff’s 27 Complaint. 28 3. Plaintiffs counsel and myself completed a telephone conference on November 17, _ 1 - DECLARATION OF MATTHEW KRACHT IN SUPPORT 0F DEFENDANTS’ MOTION T0 STRIKE J.