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RA-010
ATTORNEY OR PARTY \MTHOUT ATTORNEY: STATE BAR NUMBER: 164116
NAME: Stacey Davis
FIRM NAME: Erskine Law Group, PC
STREET ADDREss 1592 N. Batavia St, Suite 1A
c1TY: Orange STATE: CA ZIP CODE: 92867
TELEPHONE NO. (949) 777-6032 FAX NO. (714) 844-9035
EMAIL ADDRESS: sdavis@erskinelaw.com
ATTORNEY FOR (name) GENERAL MOTORS LLC.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF MONTEREY
STREET ADDRESS 1200 Aguajito Road
MAILING ADDREss 1200 Aguajito Road
CITY AND z1P coDE: Monterey, CA 93940
BRANCH NAME: MONTEREY COURTHOUSE
PLAINTIFF/PETITIONER: CRISTOBAL FLETES ET AL.
DEFENDANT/RESPONDENT: GENERAL MOTORS LLC.
OTHER CASE NAME:
CASE NUMBER:
NOTICE OF REMOTE APPEARANCE
23CV000513
You must use this form to tell the court you intend to appear remotely in a civil case, unless the court's website describes an
online process for giving notice. You may also use it to give the required notice to all other parties in the case. (Do not use
this form in a juvenile dependency proceeding.)
Check the court's website for information about how to appear remotely, including the departments and types of cases or
proceedings that allow remote appearances and ways to appear remotely in their departments for such appearances.
See page 3 of this form for more information, including deadlines for giving notice and for opposing a remote appearance if
this notice is for an evidentiary hearing or trial.
A person appearing remotely should conduct themselves as though appearing in court in person.
1. The person who intends to appear remotely is (check and complete all that apply):
D Plaintiff/Petitioner (name):
D Attorney for Plaintiff/Petitioner (name):
D Defendant/Respondent (name) :
[K] Attorney for Defendant/Respondent (name): STACEY DAVIS ESQ.
D Other (name and role in case):
2. The person or persons in 1 intends to appear remotely (check one):
a. D Throughout the case.
b. [K] At the proceeding described below, including on any later dates if the proceeding is continued (describe) :
Type of proceeding: Motion to Compel
Set on (date): April 19, 2024 at (time): 8:30 am in (department): 15
Before (name of judicial officer, if known):
3. The person intends to appear by (check court's website for method that may be used):
[K] Videoconference D Audio only (including telephone)
4. D For evidentiary hearing or trial only (where testimony may be given): the party requests the following additional aspects of the
proceeding be conducted remotely(describe what the party wants to be done remotely and why; attach form MC-25 if more
space is needed):
Pa a1 ofl
Form Adopted for Mandatory Use Code of Civil Procedure, § 367. 75;
Judicial Council of California NOTICE OF REMOTE APPEARANCE Cal. Rules of Court, rule 3. 672
RA-01 O[New January 1, 2022] www.courls.ca.gov
RA-010
PLAINTIFF: CRISTOBAL FLETES ET AL. CASE NUMBER:
DEFENDANT: GENERAL MOTORS LLC. 23CV000513
5. [KJ I agree to keep the proceeding confidential to the same extent as would be required if I were appearing in person.
Date: April 18, 2024
Stacey Davis â–º
(TYPE OR PRINT NAME) (SIGNATURE)
Notice to Other Parties
Anyone intending to appear remotely must provide notice to all other parties by the deadlines stated in Cal. Rules of Court,
rule 3.672, and described on the next page. Notice may be provided orally, electronically, or by giving the other parties this
form in a way to ensure it is received by the applicable deadline. The party must tell the court this was done either by filing a
proof of service (this may be done on forms POS-040 or POS-050 for electronic service) or by completing and signing the
declaration below.
Declaration of Notice
I gave notice that I intend to appear remotely to the other parties or persons entitled to receive notice in this case as stated below.
Complete one item below for each person notice was given to, and enter one of the following options for "Method of notice" in c.
• Mail: By mailing them a copy of this form (write the mailing address in d.)
• Overnight delivery: By having a copy of this form delivered overnight (write the delivery address in d.)
• Electronic notice: By e-mail or text message (write the e-mail or phone number in d.)
• Phone: By telling them over the telephone or leaving them voice mail (write the phone number in d.), or
• In person: By giving them a copy of this form in person, or by telling them orally in person (write the address in d.)
1. D Plaintiff/Petitioner 2. D Attorney for:
a. Name: a. Name:
b. Date of notice: b. Date of notice:
c. Method of notice: c. Method of notice:
d. Address (mailing, in-person, or email) or phone number: d. Address (mailing, in-person, or email) or phone number:
3. [KJ Defendant/Respondent 4. D Attorney for:
a. Name: Stacey Davis a. Name:
b. Date of notice: April 18, 2024 b. Date of notice:
c. Method of notice: eservice c. Method of notice:
d. Address (mailing, in-person, or email) or phone number: d. Address (mailing, in-person, or email) phone number:
760-585-8253; sdavis@erskinelaw.com
5. D Other (specify): 6. D Attorney for:
a. Name: a. Name:
b. Date of notice: b. Date of notice:
c. Method of notice: c. Method of notice:
d. Address (mailing, in-person, or email) or phone number: d. Address (mailing, in-person, or email) phone number:
7. D Other (specify) : 7. D Other (specify):
a. Name: a. Name:
b. Date of notice: b. Date of notice:
c. Method of notice: c. Method of notice:
d. Address (mailing, in-person, or email) or phone number: d. Address (mailing, in-person, or email) or phone number:
D If more people were given notice, check here, attach form MC-025, titled as Attachment Notice, and add the information about
how and when notice was given to each person.
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Date: April 18, 2024 â–º ~ ,
1 :
Stacey Davis ~
(TYPE OR PRINT NAME) (SIGNATURE)
RA-01 0 [New January 1, 2022] NOTICE OF REMOTE APPEARANCE Paga 2 of 3
[page 3 need not be filed]
1
2 PROOF OF SERVICE
3 I am employed in the County of Orange and my business address is 1592 N Batavia Street,
Suite 1A, Orange, California 92867. I am over the age of 18 years and I am not a party to this
4 action. I am readily familiar with the practices of The Erskine Law Group for the collection
and processing of correspondence for mailing with the United States Postal Service. Such
5 correspondence is deposited with the United States Postal Service the same day in the ordinary course
of business.
6
On April 18, 2024, I served the foregoing document(s), bearing the title(s):
7
Defendant General Motors LLC NOTICE OF REMOTE APPEARANCE
8
on the interested parties in the action as follows:
9
[X] by placing [] the original [X] a true copy thereof enclosed in a sealed envelope addressed as
10 follows:
Law Offices of Ropbert B. Mobasseri, PC
11 7855 Ivanhoe Avenue, Suite 4001055 West 7th St, Suite 2140
Los Angeles, CA 93940
12 eservice@mobasserilaw.com
[] (BY MAIL SERVICE) I placed such envelopes for collection and to be mailed on this date
13 following ordinary business practices.
14 [] (BY PERSONAL SERVICE) I caused to be delivered such envelope by hand to the office of
the addressee.
15
[] (BY FACSIMILE) The document stated herein was transmitted by facsimile transmission and
16 the transmission was reported as complete and without error. A transmission report was properly
issued by the transmitting facsimile machine and a copy of said transmission report is attached to the
17 original proof of service indicating the time of transmission.
18
[] (BY NEXT DAY DELIVERY) I caused to be delivered such envelope by hand to the office of
the addressee.
19
[X] (BY E-MAIL) I served the above-mentioned document via electronic transmission per
agreement of the parties.
20
[X] (State) I declare under penalty of perjury under the laws of the State of California that the
21 foregoing is true and correct.
22 [] (Federal) I declare under penalty of perjury that I am employed by a member of the Bar of this
Court, at whose direction this service is made.
23
Executed on April 18, 2024, at Orange, CA.
24
25
26
Signed: _____________________
27 Tiffany Beuerlein
28
__________________________________________________________________________________________________
_ DEFENDANT GENERAL MOTORS LLC NOTICE OF REMOTE APPEARANCE
1
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RA-010 ATTORNEY OR PARTY \MTHOUT ATTORNEY: STATE BAR NUMBER: 164116 NAME: Stacey Davis FIRM NAME: Erskine Law Group, PC STREET ADDREss 1592 N. Batavia St, Suite 1A c1TY: Orange STATE: CA ZIP CODE: 92867 TELEPHONE NO. (949) 777-6032 FAX NO. (714) 844-9035 EMAIL ADDRESS: sdavis@erskinelaw.com ATTORNEY FOR (name) GENERAL MOTORS LLC. SUPERIOR COURT OF CALIFORNIA, COUNTY OF MONTEREY STREET ADDRESS 1200 Aguajito Road MAILING ADDREss 1200 Aguajito Road CITY AND z1P coDE: Monterey, CA 93940 BRANCH NAME: MONTEREY COURTHOUSE PLAINTIFF/PETITIONER: CRISTOBAL FLETES ET AL. DEFENDANT/RESPONDENT: GENERAL MOTORS LLC. OTHER CASE NAME: CASE NUMBER: NOTICE OF REMOTE APPEARANCE 23CV000513 You must use this form to tell the court you intend to appear remotely in a civil case, unless the court's website describes an online process for giving notice. You may also use it to give the required notice to all other parties in the case. (Do not use this form in a juvenile dependency proceeding.) Check the court's website for information about how to appear remotely, including the departments and types of cases or proceedings that allow remote appearances and ways to appear remotely in their departments for such appearances. See page 3 of this form for more information, including deadlines for giving notice and for opposing a remote appearance if this notice is for an evidentiary hearing or trial. A person appearing remotely should conduct themselves as though appearing in court in person. 1. The person who intends to appear remotely is (check and complete all that apply): D Plaintiff/Petitioner (name): D Attorney for Plaintiff/Petitioner (name): D Defendant/Respondent (name) : [K] Attorney for Defendant/Respondent (name): STACEY DAVIS ESQ. D Other (name and role in case): 2. The person or persons in 1 intends to appear remotely (check one): a. D Throughout the case. b. [K] At the proceeding described below, including on any later dates if the proceeding is continued (describe) : Type of proceeding: Motion to Compel Set on (date): April 19, 2024 at (time): 8:30 am in (department): 15 Before (name of judicial officer, if known): 3. The person intends to appear by (check court's website for method that may be used): [K] Videoconference D Audio only (including telephone) 4. D For evidentiary hearing or trial only (where testimony may be given): the party requests the following additional aspects of the proceeding be conducted remotely(describe what the party wants to be done remotely and why; attach form MC-25 if more space is needed): Pa a1 ofl Form Adopted for Mandatory Use Code of Civil Procedure, § 367. 75; Judicial Council of California NOTICE OF REMOTE APPEARANCE Cal. Rules of Court, rule 3. 672 RA-01 O[New January 1, 2022] www.courls.ca.gov RA-010 PLAINTIFF: CRISTOBAL FLETES ET AL. CASE NUMBER: DEFENDANT: GENERAL MOTORS LLC. 23CV000513 5. [KJ I agree to keep the proceeding confidential to the same extent as would be required if I were appearing in person. Date: April 18, 2024 Stacey Davis ► (TYPE OR PRINT NAME) (SIGNATURE) Notice to Other Parties Anyone intending to appear remotely must provide notice to all other parties by the deadlines stated in Cal. Rules of Court, rule 3.672, and described on the next page. Notice may be provided orally, electronically, or by giving the other parties this form in a way to ensure it is received by the applicable deadline. The party must tell the court this was done either by filing a proof of service (this may be done on forms POS-040 or POS-050 for electronic service) or by completing and signing the declaration below. Declaration of Notice I gave notice that I intend to appear remotely to the other parties or persons entitled to receive notice in this case as stated below. Complete one item below for each person notice was given to, and enter one of the following options for "Method of notice" in c. • Mail: By mailing them a copy of this form (write the mailing address in d.) • Overnight delivery: By having a copy of this form delivered overnight (write the delivery address in d.) • Electronic notice: By e-mail or text message (write the e-mail or phone number in d.) • Phone: By telling them over the telephone or leaving them voice mail (write the phone number in d.), or • In person: By giving them a copy of this form in person, or by telling them orally in person (write the address in d.) 1. D Plaintiff/Petitioner 2. D Attorney for: a. Name: a. Name: b. Date of notice: b. Date of notice: c. Method of notice: c. Method of notice: d. Address (mailing, in-person, or email) or phone number: d. Address (mailing, in-person, or email) or phone number: 3. [KJ Defendant/Respondent 4. D Attorney for: a. Name: Stacey Davis a. Name: b. Date of notice: April 18, 2024 b. Date of notice: c. Method of notice: eservice c. Method of notice: d. Address (mailing, in-person, or email) or phone number: d. Address (mailing, in-person, or email) phone number: 760-585-8253; sdavis@erskinelaw.com 5. D Other (specify): 6. D Attorney for: a. Name: a. Name: b. Date of notice: b. Date of notice: c. Method of notice: c. Method of notice: d. Address (mailing, in-person, or email) or phone number: d. Address (mailing, in-person, or email) phone number: 7. D Other (specify) : 7. D Other (specify): a. Name: a. Name: b. Date of notice: b. Date of notice: c. Method of notice: c. Method of notice: d. Address (mailing, in-person, or email) or phone number: d. Address (mailing, in-person, or email) or phone number: D If more people were given notice, check here, attach form MC-025, titled as Attachment Notice, and add the information about how and when notice was given to each person. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Date: April 18, 2024 ► ~ , 1 : Stacey Davis ~ (TYPE OR PRINT NAME) (SIGNATURE) RA-01 0 [New January 1, 2022] NOTICE OF REMOTE APPEARANCE Paga 2 of 3 [page 3 need not be filed] 1 2 PROOF OF SERVICE 3 I am employed in the County of Orange and my business address is 1592 N Batavia Street, Suite 1A, Orange, California 92867. I am over the age of 18 years and I am not a party to this 4 action. I am readily familiar with the practices of The Erskine Law Group for the collection and processing of correspondence for mailing with the United States Postal Service. Such 5 correspondence is deposited with the United States Postal Service the same day in the ordinary course of business. 6 On April 18, 2024, I served the foregoing document(s), bearing the title(s): 7 Defendant General Motors LLC NOTICE OF REMOTE APPEARANCE 8 on the interested parties in the action as follows: 9 [X] by placing [] the original [X] a true copy thereof enclosed in a sealed envelope addressed as 10 follows: Law Offices of Ropbert B. Mobasseri, PC 11 7855 Ivanhoe Avenue, Suite 4001055 West 7th St, Suite 2140 Los Angeles, CA 93940 12 eservice@mobasserilaw.com [] (BY MAIL SERVICE) I placed such envelopes for collection and to be mailed on this date 13 following ordinary business practices. 14 [] (BY PERSONAL SERVICE) I caused to be delivered such envelope by hand to the office of the addressee. 15 [] (BY FACSIMILE) The document stated herein was transmitted by facsimile transmission and 16 the transmission was reported as complete and without error. A transmission report was properly issued by the transmitting facsimile machine and a copy of said transmission report is attached to the 17 original proof of service indicating the time of transmission. 18 [] (BY NEXT DAY DELIVERY) I caused to be delivered such envelope by hand to the office of the addressee. 19 [X] (BY E-MAIL) I served the above-mentioned document via electronic transmission per agreement of the parties. 20 [X] (State) I declare under penalty of perjury under the laws of the State of California that the 21 foregoing is true and correct. 22 [] (Federal) I declare under penalty of perjury that I am employed by a member of the Bar of this Court, at whose direction this service is made. 23 Executed on April 18, 2024, at Orange, CA. 24 25 26 Signed: _____________________ 27 Tiffany Beuerlein 28 __________________________________________________________________________________________________ _ DEFENDANT GENERAL MOTORS LLC NOTICE OF REMOTE APPEARANCE 1