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Cc oOo ND KH PF WwW HY
mow NN RD De ee i i
BRRREBERBE SFB WARAEEOHREKS
LAW OFFICES OF
WALKUP, MELODIA, KELLY & SCHOENBERGER
‘A PROFESSIONAL CORPORATION
650 CALIFORNIA STREET, 26TH FLOOR ELECTRONICALLY
SAN FRANCISCO, CALIFORNIA 94108-2615 FILED
Np Serato, Superior Court of Catifornia,
KHALDOUN A. BAGHDADI (SB 190111) eA ona
kbaghdadi@walkuplawoffice.com 06/06/2017
ANDREW P. MCDEVITT (SB 271371) BY:DARLENE LUM
amdeveitt@walkuplawoffice.com Deputy Clerk
ATTORNEYS FOR PLAINTIFFS
GUSTAVO A. MEJIA
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
GUSTAVO A. MEJIA, Case No. CGC-15-548401
Plaintiffs, DECLARATION OF KHALDOUN A.
BAGHDADI IN RESPONSE TO ORDER
v. TO SHOW CAUSE RE: DISMISSAL
DAMODAR CHANDRADAS, AMARA. Hearing Date: June 13, 2017
IRIZARRY, and DOES ONE through SIXTY, Time: 10:30 am
inclusive, Department: 610
Defendants. Complaint Filed: October 13, 2015
Trial Date: none
I, Khaldoun A. Baghdadi, declare:
1. Jam an attorney at law, duly licensed to practice before all courts of the State of
California. I am an attorney in the law firm of Walkup, Melodia, Kelly & Schoenberger, counsel
for plaintiffs in the above-captioned matter. The following facts are within my personal
knowledge, and if called as a witness, I could and would testify confidently thereto. I submit this
Declaration in Response to Order to Show Cause Re: Dismissal.
2. The parties have reached a tentative settlement.
3. Though the parties have exchanged settlement documents, we have still not
finalized the amount of the lien claim (if any) by Medi-Cal and other insurance providers. We
accordingly respectfully request that the OSC be continued for 60 days to finalize the settlement
and file a dismissal.
DECLARATION OF KHALDOUN A. BAGHDADI IN RESPONSE TO ORDER TO SHOW CAUSE RE: DISMISSAL - CASE.
NO. CGC-15-548401I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct, except as to those matters stated on information and belief, and as to
those matters, I am informed and believe that they are true and correct. Signed this 6th day of
rac
June, 2017 at San Francisco, California.
OUN A. BAGHD,
LAW OFFICES OF
Watxur, MELODIA, Ket}
‘& SCHOENBERGER 2
moreso conroraron
or DECLARATION OF KHALDOUN A. BAGHDADI IN RESPONSE TO ORDER TO SHOW CAUSE RE: DISMISSAL - CASE
nas ere NO. CGC-15-548401Nw
3
PROOF OF SERVICE (CCP 1013a, 2015.5)
I am over the age of eighteen years and not a party to the within action; my business
address is and I am employed at Walkup, Melodia, Kelly & Schoenberger, 650 California Street,
San Francisco, California 94108.
On the date below I served the following document(s), the original of which was/were
produced on paper purchased as recycled, in accordance with Rules of Court §201(b):
DECLARATION OF KHALDOUN A. BAGHDADI IN RESPONSE TO ORDER TO
SHOW CAUSE RE: DISMISSAL
to:
Paul A. Bigley, Esq.
Jennifer L. Sommer, Esq.
Freeman Mathis & Gary, LLP
Mailing: 550 South Hope Street, 22"4 Floor
Los Angeles, CA 90071-2631
Office: 44 Montgomery Street, Suite 2080
San Francisco, CA 94104-6702
Phone: 415-627-9000
Fax: 213-615-7100
Email Address: pab@gilbertkelly.com: jsommer@gilbertkelly.com
Attorney For: Amara Irizarry
X_ BY ELECTRONIC SERVICE VIA FILE & SERVEXPRE
“~~ caused the above-entitled document(s) to be served through File & ServeXpress at
https://secure.fileandservexpress.com addressed to all parties appearing on the electronic
service list for the above-entitled case. The service transmission was reported as complete
and a copy of the File & ServeXpress Filing Receipt Page/Confirmation will be filed,
deposited, or maintained with the original document(s) in this office.
SS. Based ona court order, I
I declare under penalty of perjury that the foregoing is true and correct. Executed on June
6, 2017, at San Francisco, California.
LILYCONNORS
PROOF OF SERVICE: DECLARATION OF KHALDOUN A. BAGHDADI IN RESPONSE TO ORDER TO SHOW CAUSE
RE: DISMISSAL ~ CASE NO. CGC-15-548401
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Cc oOo ND KH PF WwW HY mow NN RD De ee i i BRRREBERBE SFB WARAEEOHREKS LAW OFFICES OF WALKUP, MELODIA, KELLY & SCHOENBERGER ‘A PROFESSIONAL CORPORATION 650 CALIFORNIA STREET, 26TH FLOOR ELECTRONICALLY SAN FRANCISCO, CALIFORNIA 94108-2615 FILED Np Serato, Superior Court of Catifornia, KHALDOUN A. BAGHDADI (SB 190111) eA ona kbaghdadi@walkuplawoffice.com 06/06/2017 ANDREW P. MCDEVITT (SB 271371) BY:DARLENE LUM amdeveitt@walkuplawoffice.com Deputy Clerk ATTORNEYS FOR PLAINTIFFS GUSTAVO A. MEJIA IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO GUSTAVO A. MEJIA, Case No. CGC-15-548401 Plaintiffs, DECLARATION OF KHALDOUN A. BAGHDADI IN RESPONSE TO ORDER v. TO SHOW CAUSE RE: DISMISSAL DAMODAR CHANDRADAS, AMARA. Hearing Date: June 13, 2017 IRIZARRY, and DOES ONE through SIXTY, Time: 10:30 am inclusive, Department: 610 Defendants. Complaint Filed: October 13, 2015 Trial Date: none I, Khaldoun A. Baghdadi, declare: 1. Jam an attorney at law, duly licensed to practice before all courts of the State of California. I am an attorney in the law firm of Walkup, Melodia, Kelly & Schoenberger, counsel for plaintiffs in the above-captioned matter. The following facts are within my personal knowledge, and if called as a witness, I could and would testify confidently thereto. I submit this Declaration in Response to Order to Show Cause Re: Dismissal. 2. The parties have reached a tentative settlement. 3. Though the parties have exchanged settlement documents, we have still not finalized the amount of the lien claim (if any) by Medi-Cal and other insurance providers. We accordingly respectfully request that the OSC be continued for 60 days to finalize the settlement and file a dismissal. DECLARATION OF KHALDOUN A. BAGHDADI IN RESPONSE TO ORDER TO SHOW CAUSE RE: DISMISSAL - CASE. NO. CGC-15-548401I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, except as to those matters stated on information and belief, and as to those matters, I am informed and believe that they are true and correct. Signed this 6th day of rac June, 2017 at San Francisco, California. OUN A. BAGHD, LAW OFFICES OF Watxur, MELODIA, Ket} ‘& SCHOENBERGER 2 moreso conroraron or DECLARATION OF KHALDOUN A. BAGHDADI IN RESPONSE TO ORDER TO SHOW CAUSE RE: DISMISSAL - CASE nas ere NO. CGC-15-548401Nw 3 PROOF OF SERVICE (CCP 1013a, 2015.5) I am over the age of eighteen years and not a party to the within action; my business address is and I am employed at Walkup, Melodia, Kelly & Schoenberger, 650 California Street, San Francisco, California 94108. On the date below I served the following document(s), the original of which was/were produced on paper purchased as recycled, in accordance with Rules of Court §201(b): DECLARATION OF KHALDOUN A. BAGHDADI IN RESPONSE TO ORDER TO SHOW CAUSE RE: DISMISSAL to: Paul A. Bigley, Esq. Jennifer L. Sommer, Esq. Freeman Mathis & Gary, LLP Mailing: 550 South Hope Street, 22"4 Floor Los Angeles, CA 90071-2631 Office: 44 Montgomery Street, Suite 2080 San Francisco, CA 94104-6702 Phone: 415-627-9000 Fax: 213-615-7100 Email Address: pab@gilbertkelly.com: jsommer@gilbertkelly.com Attorney For: Amara Irizarry X_ BY ELECTRONIC SERVICE VIA FILE & SERVEXPRE “~~ caused the above-entitled document(s) to be served through File & ServeXpress at https://secure.fileandservexpress.com addressed to all parties appearing on the electronic service list for the above-entitled case. The service transmission was reported as complete and a copy of the File & ServeXpress Filing Receipt Page/Confirmation will be filed, deposited, or maintained with the original document(s) in this office. SS. Based ona court order, I I declare under penalty of perjury that the foregoing is true and correct. Executed on June 6, 2017, at San Francisco, California. LILYCONNORS PROOF OF SERVICE: DECLARATION OF KHALDOUN A. BAGHDADI IN RESPONSE TO ORDER TO SHOW CAUSE RE: DISMISSAL ~ CASE NO. CGC-15-548401