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CIV-110
ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR NO: FOR COURT USE ONLY
NAME: Michael H. Rosenstein (SBN 169091); Sepehr Daghighian (SBN 239349)
FIRM NAME: California Consumer Attorneys, P.C.
STREET ADDRESS: 10866 Wilshire Blvd, Suite 1200
CITY: Los Angeles STATE: CA ZIP CODE: 90024
TELEPHONE NO.: (310) 872-2600 FAX NO. : (310) 730-7377
E-MAIL ADDRESS: mhr@calattorneys.com; sd@calattorneys.com
ATTORNEY FOR (Name): Plaintiff, Francesca Murphy
SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Mateo
STREET ADDRESS: 800 North Humboldt St
MAILING ADDRESS: 800 North Humboldt St
CITY AND ZIP CODE: San Mateo, CA 94401
BRANCH NAME: Hall of Justice
Plaintiff/Petitioner: Francesca Murphy
Defendant/Respondent: Ford Motor Company
CASE NUMBER:
REQUEST FOR DISMISSAL 23-CIV-04031
A conformed copy will not be returned by the clerk unless a method of return is provided with the document.
This form may not be used for dismissal of a derivative action or a class action or of any party or cause of action in a class
action. (Cal. Rules of Court, rules 3.760 and 3.770.)
1. TO THE CLERK: Please dismiss this action as follows:
a. (1) With prejudice (2) Without prejudice
b. (1) Complaint (2) Petition
(3) Cross-complaint filed by (name): on (date):
(4) Cross-complaint filed by (name): on (date):
(5) Entire action of all parties and all causes of action
(6) Other (specify):*
2. (Complete in all cases except family law cases.)
The court did did not waive court fees and costs for a party in this case. (This information may be obtained from the
clerk. If court fees and costs were waived, the declaration on the back of this form must be completed).
Date: April 24, 2024
Sepehr Daghighian
(TYPE OR PRINT NAME OF ATTORNEY PARTY WITHOUT ATTORNEY) (SIGNATURE)
*If dismissal requested is of specified parties only of specified causes of action only, Attorney or party without attorney for:
or of specified cross-complaints only, so state and identify the parties, causes of Plaintiff/Petitioner Defendant/Respondent
action, or cross-complaints to be dismissed.
Cross Complainant
3. TO THE CLERK: Consent to the above dismissal is hereby given.**
Date:
(TYPE OR PRINT NAME OF ATTORNEY PARTY WITHOUT ATTORNEY) (SIGNATURE)
** If a cross-complaint – or Response (Family Law) seeking affirmative Attorney or party without attorney for:
relief – is on file, the attorney for cross-complainant (respondent) must sign
this consent if required by Code of Civil Procedure section 581 (i) or (j).
Plaintiff/Petitioner Defendant/Respondent
Cross Complainant
(To be completed by clerk)
4. Dismissal entered as requested on (date):
5 Dismissal entered on (date): as to only (name):
6. Dismissal not entered as requested for the following reasons (specify):
7. a. Attorney or party without attorney notified on (date):
b. Attorney or party without attorney not notified. Filing party failed to provide
a copy to be conformed means to return conformed copy
Date: Clerk, by , Deputy Page 1 of 2
Form Adopted for Mandatory Use Code of Civil Procedure, § 581 et seq.; Gov. Code,
Judicial Council of California REQUEST FOR DISMISSAL § 68637(c); Cal. Rules of Court, rule 3.1390
CIV-110 [Rev. Jan. 1, 2013] www.courts.ca.gov
CIV-110
CASE NUMBER:
Plaintiff/Petitioner: Francesca Murphy
23-CIV-04031
Defendant/Respondent: Ford Motor Company
COURT'S RECOVERY OF WAIVED COURT FEES AND COSTS
If a party whose court fees and costs were initially waived has recovered or will recover $10,000 or more in
value by way of settlement, compromise, arbitration award, mediation settlement, or other means, the
court has a statutory lien on that recovery. The court may refuse to dismiss the case until the lien is
satisfied. (Gov. Code, § 68637.)
Declaration Concerning Waived Court Fees
1. The court waived court fees and costs in this action for (name):
2. The person named in item 1 is (check one below):
a. not recovering anything of value by this action.
b. recovering less than $10,000 in value by this action.
c. recovering $10,000 or more in value by this action. (If item 2c is checked, item 3 must be completed.)
3. All court fees and court costs that were waived in this action have been paid to the court (check one): Yes No
I declare under penalty of perjury under the laws of the State of California that the information above is true and correct.
Date:
(TYPE OR PRINT NAME OF ATTORNEY PARTY MAKING DECLARATION) (SIGNATURE)
CIV-110 [Rev. January 1, 2013] REQUEST FOR DISMISSAL Page 2 of 2
1 PROOF OF SERVICE
[CCP, 1013a (3) CRE Rule 2006]
2
3 I am employed in the County of Los Angeles, State of California. I am over the age of 18
and not a party to the within action. My business address is 10866 Wilshire Blvd, Suite 1200, Los
4 Angeles, CA 90024.
5 On April 24, 2024, I served the foregoing document described as:
6 REQUEST FOR DISMISSAL
7
That document was served on parties herein in this proceeding by placing true copies of the
8 original in enclosed, sealed envelope(s) addressed as follows:
9 SEE ATTACHED SERVICE LIST
10
[] (BY MAIL) I am “readily familiar” with the practices of CALIFORNIA CONSUMER
11 ATTORNEYS, P.C., in collecting and processing correspondence and documents for mailing.
Under that practice, documents for mailing would be deposited with the US Postal Service on that
12 same day this affidavit is signed with postage fully prepaid at Los Angeles, California in the ordinary
course of business. I am aware that on motion of the party served, service is presumed invalid if the
13 postal cancellation date is more than 1-day after the day of deposit for mailing the affidavit. [CCP
§ 1013]
14
[] (BY OVERNIGHT MAIL) I am “readily familiar” with the practices of the CALIFORNIA
15 CONSUMER ATTORNEYS, P.C., for collection and processing of documents for mailing via
16 overnight delivery. I caused such document(s) to be placed in a sealed envelope designated by the
overnight service carrier, addressed to the person(s) on whom it is to be served pursuant to the
17 attached service list, and deposited said envelope in a box or other facility regularly maintained by
the overnight service carrier with delivery fees paid or provided for. [CCP § 1013(c)]
18
[X] (BY ELECTRONIC MAIL) I caused the document(s) to be transmitted by electronic mail to
19 the e-mail addresses for each party indicated on the attached service list.
20 [] (BY PERSONAL DELIVERY) I caused to be delivered such envelope by hand to the addressee
at the address indicated on the attached service list.
21
22 I declare under penalty of perjury under the laws of the State of California that the foregoing
is true and correct.
23
Executed on April 24, 2024.
24
___________________
25 Crystal Rivas
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PROOF OF SERVICE
SERVICE LIST
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2 Brian C. Vanderhoof Counsel for Defendant
Jonathan Won
3 LEWIS BRISBOIS BISGAARD & SMITH LLP
45 Fremont Street, Suite 3000
4 San Francisco, CA 94105
Brian.Vanderhoof@lewisbrisbois.com
5 Jonathan.Won@lewisbrisbois.com
lbfcaservice@lewisbrisbois.com
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PROOF OF SERVICE
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CIV-110 ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR NO: FOR COURT USE ONLY NAME: Michael H. Rosenstein (SBN 169091); Sepehr Daghighian (SBN 239349) FIRM NAME: California Consumer Attorneys, P.C. STREET ADDRESS: 10866 Wilshire Blvd, Suite 1200 CITY: Los Angeles STATE: CA ZIP CODE: 90024 TELEPHONE NO.: (310) 872-2600 FAX NO. : (310) 730-7377 E-MAIL ADDRESS: mhr@calattorneys.com; sd@calattorneys.com ATTORNEY FOR (Name): Plaintiff, Francesca Murphy SUPERIOR COURT OF CALIFORNIA, COUNTY OF San Mateo STREET ADDRESS: 800 North Humboldt St MAILING ADDRESS: 800 North Humboldt St CITY AND ZIP CODE: San Mateo, CA 94401 BRANCH NAME: Hall of Justice Plaintiff/Petitioner: Francesca Murphy Defendant/Respondent: Ford Motor Company CASE NUMBER: REQUEST FOR DISMISSAL 23-CIV-04031 A conformed copy will not be returned by the clerk unless a method of return is provided with the document. This form may not be used for dismissal of a derivative action or a class action or of any party or cause of action in a class action. (Cal. Rules of Court, rules 3.760 and 3.770.) 1. TO THE CLERK: Please dismiss this action as follows: a. (1) With prejudice (2) Without prejudice b. (1) Complaint (2) Petition (3) Cross-complaint filed by (name): on (date): (4) Cross-complaint filed by (name): on (date): (5) Entire action of all parties and all causes of action (6) Other (specify):* 2. (Complete in all cases except family law cases.) The court did did not waive court fees and costs for a party in this case. (This information may be obtained from the clerk. If court fees and costs were waived, the declaration on the back of this form must be completed). Date: April 24, 2024 Sepehr Daghighian (TYPE OR PRINT NAME OF ATTORNEY PARTY WITHOUT ATTORNEY) (SIGNATURE) *If dismissal requested is of specified parties only of specified causes of action only, Attorney or party without attorney for: or of specified cross-complaints only, so state and identify the parties, causes of Plaintiff/Petitioner Defendant/Respondent action, or cross-complaints to be dismissed. Cross Complainant 3. TO THE CLERK: Consent to the above dismissal is hereby given.** Date: (TYPE OR PRINT NAME OF ATTORNEY PARTY WITHOUT ATTORNEY) (SIGNATURE) ** If a cross-complaint – or Response (Family Law) seeking affirmative Attorney or party without attorney for: relief – is on file, the attorney for cross-complainant (respondent) must sign this consent if required by Code of Civil Procedure section 581 (i) or (j). Plaintiff/Petitioner Defendant/Respondent Cross Complainant (To be completed by clerk) 4. Dismissal entered as requested on (date): 5 Dismissal entered on (date): as to only (name): 6. Dismissal not entered as requested for the following reasons (specify): 7. a. Attorney or party without attorney notified on (date): b. Attorney or party without attorney not notified. Filing party failed to provide a copy to be conformed means to return conformed copy Date: Clerk, by , Deputy Page 1 of 2 Form Adopted for Mandatory Use Code of Civil Procedure, § 581 et seq.; Gov. Code, Judicial Council of California REQUEST FOR DISMISSAL § 68637(c); Cal. Rules of Court, rule 3.1390 CIV-110 [Rev. Jan. 1, 2013] www.courts.ca.gov CIV-110 CASE NUMBER: Plaintiff/Petitioner: Francesca Murphy 23-CIV-04031 Defendant/Respondent: Ford Motor Company COURT'S RECOVERY OF WAIVED COURT FEES AND COSTS If a party whose court fees and costs were initially waived has recovered or will recover $10,000 or more in value by way of settlement, compromise, arbitration award, mediation settlement, or other means, the court has a statutory lien on that recovery. The court may refuse to dismiss the case until the lien is satisfied. (Gov. Code, § 68637.) Declaration Concerning Waived Court Fees 1. The court waived court fees and costs in this action for (name): 2. The person named in item 1 is (check one below): a. not recovering anything of value by this action. b. recovering less than $10,000 in value by this action. c. recovering $10,000 or more in value by this action. (If item 2c is checked, item 3 must be completed.) 3. All court fees and court costs that were waived in this action have been paid to the court (check one): Yes No I declare under penalty of perjury under the laws of the State of California that the information above is true and correct. Date: (TYPE OR PRINT NAME OF ATTORNEY PARTY MAKING DECLARATION) (SIGNATURE) CIV-110 [Rev. January 1, 2013] REQUEST FOR DISMISSAL Page 2 of 2 1 PROOF OF SERVICE [CCP, 1013a (3) CRE Rule 2006] 2 3 I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action. My business address is 10866 Wilshire Blvd, Suite 1200, Los 4 Angeles, CA 90024. 5 On April 24, 2024, I served the foregoing document described as: 6 REQUEST FOR DISMISSAL 7 That document was served on parties herein in this proceeding by placing true copies of the 8 original in enclosed, sealed envelope(s) addressed as follows: 9 SEE ATTACHED SERVICE LIST 10 [] (BY MAIL) I am “readily familiar” with the practices of CALIFORNIA CONSUMER 11 ATTORNEYS, P.C., in collecting and processing correspondence and documents for mailing. Under that practice, documents for mailing would be deposited with the US Postal Service on that 12 same day this affidavit is signed with postage fully prepaid at Los Angeles, California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if the 13 postal cancellation date is more than 1-day after the day of deposit for mailing the affidavit. [CCP § 1013] 14 [] (BY OVERNIGHT MAIL) I am “readily familiar” with the practices of the CALIFORNIA 15 CONSUMER ATTORNEYS, P.C., for collection and processing of documents for mailing via 16 overnight delivery. I caused such document(s) to be placed in a sealed envelope designated by the overnight service carrier, addressed to the person(s) on whom it is to be served pursuant to the 17 attached service list, and deposited said envelope in a box or other facility regularly maintained by the overnight service carrier with delivery fees paid or provided for. [CCP § 1013(c)] 18 [X] (BY ELECTRONIC MAIL) I caused the document(s) to be transmitted by electronic mail to 19 the e-mail addresses for each party indicated on the attached service list. 20 [] (BY PERSONAL DELIVERY) I caused to be delivered such envelope by hand to the addressee at the address indicated on the attached service list. 21 22 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 23 Executed on April 24, 2024. 24 ___________________ 25 Crystal Rivas 26 27 28 -1- PROOF OF SERVICE SERVICE LIST 1 2 Brian C. Vanderhoof Counsel for Defendant Jonathan Won 3 LEWIS BRISBOIS BISGAARD & SMITH LLP 45 Fremont Street, Suite 3000 4 San Francisco, CA 94105 Brian.Vanderhoof@lewisbrisbois.com 5 Jonathan.Won@lewisbrisbois.com lbfcaservice@lewisbrisbois.com 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -2- PROOF OF SERVICE