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  • REGINA GLORIOSO-EMERSON, et al  vs.  CITY OF MILLBRAE, et al(23) Unlimited Other PI/PD/WD document preview
  • REGINA GLORIOSO-EMERSON, et al  vs.  CITY OF MILLBRAE, et al(23) Unlimited Other PI/PD/WD document preview
  • REGINA GLORIOSO-EMERSON, et al  vs.  CITY OF MILLBRAE, et al(23) Unlimited Other PI/PD/WD document preview
  • REGINA GLORIOSO-EMERSON, et al  vs.  CITY OF MILLBRAE, et al(23) Unlimited Other PI/PD/WD document preview
  • REGINA GLORIOSO-EMERSON, et al  vs.  CITY OF MILLBRAE, et al(23) Unlimited Other PI/PD/WD document preview
  • REGINA GLORIOSO-EMERSON, et al  vs.  CITY OF MILLBRAE, et al(23) Unlimited Other PI/PD/WD document preview
  • REGINA GLORIOSO-EMERSON, et al  vs.  CITY OF MILLBRAE, et al(23) Unlimited Other PI/PD/WD document preview
  • REGINA GLORIOSO-EMERSON, et al  vs.  CITY OF MILLBRAE, et al(23) Unlimited Other PI/PD/WD document preview
						
                                

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CIV-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): Robert J. Ounjian SBN: 210213 FOR COURT USE ONLY Carpenter & Zuckerman 8827 West Olympic Boulevard, Beverly Hills, CA 90211 TELEPHONENO.:3 1()-273-1230 FAX NO. (Optiona: 310-858-1063 Electronically E-MAIL ADDRESS (Optiona): robert(@cz..law ATTORNEY FOR (Name): Plaintiffs by|Superior Court of California, County of San Mateo SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN MATEO ON sTREET aDpress:400 County Center By| /s/ Nesha Gaines MAILING ADDRESS:400 County Center Deputy Clerk city AND ziP cone:Redwood City, 94063 BRANCH NAME:Southern Branch: Hall of Justice and Records PLAINTIFF/PETITIONER: REGINA GLORIOSO-EMERSON. ET AL. DEFENDANT/RESPONDENT: CITY OF MILLBRAE, ET AL. REQUEST FOR DISMISSAL case Numer: 22-CIV-05181 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 ina 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) [XJ Other (specify):* Plaintiffs’ Complaint as to Defendant County of San Mateo ONLY. 2. (Complete in all cases except family law cases.) The court [__]did [Xx] 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: February 23, 2023 Robert J, Ounjian > Rebut- Ounguan (TYPE OR PRINT NAME OF TroRNey [77] Pagry withour ATTORNEY) (SIGNATURE) “if dismissal requested is of specified parties only of specified causes of action Attorney or party without attorney for: only, of of specified cross-com) aints ‘only, so state and identify the parties, causes of action, or cross-comp| flaints to be dismissed. LX] Plaintiff/Petitioner Co Defendant/Respondent CC) Cross-Complainant 3. TO THE CLERK: Consent to the above dismissal is hereby given.** > Date: ('YPEOR PRINT NAMEOF [—] 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 ssign this consent if required by Code of Civil Procedure section 581 (i) ([_] Plaintiff/Petitioner (_) Defendant/Respondent or (). [] Cross-Complainant (To be completed by clerk) 2/23/2023 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): 7a. Co 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 /s/ Nesha Gaines Neal |. Taniguchi Date: 2/23/2023 : Clerk, by , Deputy Page 1 of 2 Form Adopted for Mandatory Use ‘Code of Civil Procedure, § 581 et seq. Judicial Council of California REQUEST FOR DISMISSAL Gov. Code, § 68637(c); Cal. Rules of Court, rule 3.1360, CIV-110 [Rev. Jan. 1, 2013] WestlawDoc &Form Buller: @*""-courts.ca.gov ClV-110 PLAINTIFF/PETITIONER: REGINA GLORIOSO-EMERSON. ET AL. CASE NUMBER: DEFENDANT/RESPONDENT: CITY OF MILLBRAE, ET AL. 22-CIV-05181 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 4 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 | declare under penalty of perjury under the laws of the State of California that the information above is true and correct. Date: > CTYPEOR PRINT NAME OF [—] ATTORNEY [—] PARTY MAKING DECLARATION) (SIGNATURE) CIV-110 [Rev. January 1, 2013], REQUEST FOR DISMISSAL Page 2 of 2 PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF LOS ANGELES Iam 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 8827 W. Olympic Blvd., Beverly Hills, CA 90211. On February 23, 2023, I served the foregoing document(s) described as REQUEST FOR DISMISSAL on all interested parties in this action as set forth on the attached service list as follows: oO BY MAIL: I placed a true copy of the above captioned documents for collection and processing for mailing, following this business’ usual practices, with which I am readily familiar. On the same day correspondence is placed for collection and mailing, it is 10 deposited in the ordinary course of business with the United States Postal Service. 11 BY OVERNIGHT MAIL: By sealing the envelope and placing it for collection and overnight delivery in a box regularly maintained by an overnight delivery service with 12 delivery fees paid or provided for in accordance with ordinary business practices. 13 BY PERSONAL SERVICE: I caused such envelope to be delivered by hand to 14 counsel for defendants. 15 BY ELECTRONIC TRANSFER/VIA FACSIMILE: I caused all of the pages of the above-entitled document(s) to be sent to the recipients noted above via electronic 16 transfer (FAX) at the respective telephone numbers indicated above. 17 BY ELECTRONIC SERVICE: Pursuant to Code of Civil Procedure § 18 1010.6(a)(2)(A)(i), 1010.6(a)(2)(A)(ii), and/or necessity resulting from the Safer at Home order/regulation issued by the City and County of Los Angeles effective March 19 20, 2020: from my email address angela@cz.law to the e-mail address(es) listed on the ATTACHED SERVICE LIST. 20 BY EMAIL OR ELECTRONIC TRANSMISSION: Pursuant to California Rules of 21 Court, Rule 2.251(b), I caused each such document to be converted to .pdf format and 22 sent from e-mail address xxxx(@cz.law to the person(s) on the electronic notification address listed in the service list. 23 STATE: I declare under penalty of perjury under the laws of the State of 24 California that the above is true and correct. 25 Executed on February 23, 2023 at Beverly Hills, California. 26 27 a Seven 28 Angela Sexton PROOF OF SERVICE SERVICE LIST Glorioso-Emerson, et al. v. City of Millbrae, et al. Case No.: 22-CIV-05181 Kevin E. Gilbert, Esq. kgilbert@ohhlegal.com JiEun Choi jechoi@ohhlegal.com ORBACH HUFF & HENDERSON LLP 6200 Stoneridge Mall Road, Suite 225 Pleasanton, CA 94588 Tele: (510) 999-7908 Fax: (510) 999-7918 Defendant, City of San Bruno 10 Lemuel L. Garcia, Esq. lem@lemgarcialaw.com 11 LEM GARCIA LAW, PC 12 1720 West Cameron Avenue, Suite 210 West Covina, CA 91790 13 Tele: (626) 337-1111 Fax: (626) 337-1112 14 15 TODD H. MASTER RIDLEY¢MASTER 16 1900 O’Farrell Street, Suite 280 6103 San Mateo, CA 94403 17 Telephone: (650) 365-7715 Facsimile: (650) 364-5297 tmaster@hrmrlaw.com 18 Attorneys for Defendant CITY OF MILLBRAE 19 Erin E. Holbrook 20 G. Michael Harrington Samuel C. Law 21 mike.harrington@dot.ca.gov California Department of Transportation — Legal Division 22 111 Grand Ave., Suite 11-100 23 Oakland, CA 94612-3717 Mail: P.O. Box 24323, Oakland, CA 94623 24 T: 510.433.9100 F: 510.433.9167 25 Attorneys for Defendant State of California acting by and through the Department of Transportation 26 27 28 PROOF OF SERVICE Kenneth D. Simoncini Eric Steinle kds@simoncini-law.com Simoncini & Associates 1694 The Alameda San Jose, CA 95126 T: 408.280.7711 F: 408.280.1330 Attorneys for Defendants, San Mateo Transit District and Peninsula Corridor Joint Powers Board Thomas Westphal San Mateo County/County Attorneys Office 400 County Ctr, #6 Redwood City, CA 94063 10 T: 650-363-4250 twestphal@smcgov.org 11 meoffey@smegov.org 12 gmaschio@smcgov.org Attorneys for Defendant, County of San Mateo 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE