On August 16, 2021 a
Party Discovery
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
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CASE ATTACHMENT COVER PAGE (ENDORSED)
ELECTRONICALLY
SUPERIOR COURT 0F 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
: . sb—court org
.
on Dec 30, 2022
ATTACHMENTNAME; Motion: Notice of Defendant Kal Freight lnc.'s and Pro
CLERK OF THE SUPERIOR COURT
Tec Inc's Motion lo Withdraw and Amend Responses to Deputy Clem.- Jordyn Drake
CASE NAME: Abdifatah Moh‘amed Abdi vs. Kal Freight Inc, Pro Tec lnc., and CASE NUMBER:
Kader Ismail Kalif
CIVSB2123823
Please log on to www.TurboCourt.com regularly for updates
Please staple this to your original attachment
'unaooqlnyfiduq
/Iuoa
\J \r
Stephen B. Heath -
237622
sheath@heathandvuen.com
Steven W. Yuen - 230768
syuenGIDheathandx/uencom
Matthew J. Kracht - 249076
mkrachtébheathandvuen.com
Mario E. Hermosillo - 330725
mhemosillo@heathandvuen.com
HEATH & YUEN, APC
268 Bush Street, #3006
San Francisco, CA 94104
Tel: (415) 622-7004
Fax: (415) 373-3957
\OOO\)O\
Attorneys for Defendants
KAL FREIGHT INC, PRO TEC INC., AND KADER
ISMAIL KALIF
10
SUPERIOR COURT OF THE STATE OF CALIFORNIA
11
COUNTY OF SAN BERNARDINO
12
ABDIFATAH MOHAMED ABDI, Case No.2 CIVSB2123823
13
14
Plaintiffs, NOTICE OF DEFENDANT KAL FREIGHT
INC.’S AND PRO TEC INC’S MOTION T0
15
v.
WITHDRAW AND AMEND RESPONSES TO
REQUEST FOR ADMISSIONS
KAL FREIGHT, INC., A CORPORATION; PRO
16 TEC, INC., A CORPORATION; KADER Date: February 15, 2023
ISMAIL KALIF, INDIVIDUALLY; AND DOES Time: 8:30 a.m.
17 1-20, INCLUSIVE, Judge: Hon. Khymberli S. Apaloo
Dept: 825
18 Defendants. File Date: August 16, 2021
Trial Date: November 6, 2023
19
20
21 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
22 NOTICE IS HEREBY GIVEN that on the above date and time or as soon thereafter as the
23 matter may be heard in department 825 0f this court, located at 247 W. 3rd
Street, San Bernardino,
24 California 92415, defendants Kal Freight Inc. and Pro Tec Inc. moving
is to withdraw and amend
25 responses to request for admissions. The motion is made on the grounds of mistake, inadvertence,
26 and/or excusable neglect. The motion based on
is this notice, the memorandum of points and
27 authorities, the declaration of Mario E. Hennosillo, the files and records in this action, and any further
28 evidence and argument that the court may receive at or before the hearing.
-1-
NOTICE OF DEFENDANT KAL FREIGHT INC.’S AND PRO TEC INC’S MOTION TO WITHDRAW AND
AMEND
RESPONSES TO REQUEST FOR ADMISSIONS
Document Filed Date
December 30, 2022
Case Filing Date
August 16, 2021
Category
Auto PI/PD/WD Unlimited
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\y CASE ATTACHMENT COVER PAGE (ENDORSED) ELECTRONICALLY SUPERIOR COURT 0F 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 : . sb—court org . on Dec 30, 2022 ATTACHMENTNAME; Motion: Notice of Defendant Kal Freight lnc.'s and Pro CLERK OF THE SUPERIOR COURT Tec Inc's Motion lo Withdraw and Amend Responses to Deputy Clem.- Jordyn Drake CASE NAME: Abdifatah Moh‘amed Abdi vs. Kal Freight Inc, Pro Tec lnc., and CASE NUMBER: Kader Ismail Kalif CIVSB2123823 Please log on to www.TurboCourt.com regularly for updates Please staple this to your original attachment 'unaooqlnyfiduq /Iuoa \J \r Stephen B. Heath - 237622 sheath@heathandvuen.com Steven W. Yuen - 230768 syuenGIDheathandx/uencom Matthew J. Kracht - 249076 mkrachtébheathandvuen.com Mario E. Hermosillo - 330725 mhemosillo@heathandvuen.com HEATH & YUEN, APC 268 Bush Street, #3006 San Francisco, CA 94104 Tel: (415) 622-7004 Fax: (415) 373-3957 \OOO\)O\ Attorneys for Defendants KAL FREIGHT INC, PRO TEC INC., AND KADER ISMAIL KALIF 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA 11 COUNTY OF SAN BERNARDINO 12 ABDIFATAH MOHAMED ABDI, Case No.2 CIVSB2123823 13 14 Plaintiffs, NOTICE OF DEFENDANT KAL FREIGHT INC.’S AND PRO TEC INC’S MOTION T0 15 v. WITHDRAW AND AMEND RESPONSES TO REQUEST FOR ADMISSIONS KAL FREIGHT, INC., A CORPORATION; PRO 16 TEC, INC., A CORPORATION; KADER Date: February 15, 2023 ISMAIL KALIF, INDIVIDUALLY; AND DOES Time: 8:30 a.m. 17 1-20, INCLUSIVE, Judge: Hon. Khymberli S. Apaloo Dept: 825 18 Defendants. File Date: August 16, 2021 Trial Date: November 6, 2023 19 20 21 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 22 NOTICE IS HEREBY GIVEN that on the above date and time or as soon thereafter as the 23 matter may be heard in department 825 0f this court, located at 247 W. 3rd Street, San Bernardino, 24 California 92415, defendants Kal Freight Inc. and Pro Tec Inc. moving is to withdraw and amend 25 responses to request for admissions. The motion is made on the grounds of mistake, inadvertence, 26 and/or excusable neglect. The motion based on is this notice, the memorandum of points and 27 authorities, the declaration of Mario E. Hennosillo, the files and records in this action, and any further 28 evidence and argument that the court may receive at or before the hearing. -1- NOTICE OF DEFENDANT KAL FREIGHT INC.’S AND PRO TEC INC’S MOTION TO WITHDRAW AND AMEND RESPONSES TO REQUEST FOR ADMISSIONS