Motion for Substituted Service in Philip Restivo vs Worldwide Ground Transportation Solutions, Inc. at el| Trellis.Law

On April 12, 2017 a Motion-Secondary was filed involving a dispute between and James Brown, for Breach of Contract/Warranty Unlimited(06) in the District Court of Santa Clara County.

Preview
CUMMING & ASSOCIATES, APLC
William R. Cumming (State Bar No. 200966)
ingandassociateslaw.com
3080 Bristol Street, Sixth Floor, Suite 630
Coste Mesa, CA 92626
Telephone: (714) 432-6494
Facsimile: (714) 202-3162

LAW OFFICES OF NANCY M. BATTEL
Nancy M. Battel (State Bar No. 126548)
nancy@battelaw.com
1101 Westwood Drive, Suite B
San Jose, CA 95125
Telephone: 408-723-2946
Facsimile: 408-266-7238
10
Attomeys for Defendants Worldwide Ground Transportation Solutions, Inc. and James Brown
il

SUPERIOR COURT OF THE STATE OF CALIFORNIA.
13
FOR THE COUNTY OF SANTA CLARA
14
15
PHILIP RESTIVO, Case No. 17CV308469
16
Plaintiff, Judge Christopher G. Rudy
17 Department 07
Vv.

18 [PROPOSED] JUDGMENT ON
WORLDWIDE GROUND DEFENDANT JAMES BROWN’S
19 TRANSPORTATION SOLUTIONS, INC.; MOTION FOR SUMMARY JUDGMENT
JAMES BROWN, an individual; and DOES 1
through 5, inclusive, Action Filed: April 12, 2017
Trial Date: March 11, 2019
21 Defendants,

27
28

[PROPOSED] JUDGMENT
On November 21, 2018, defendant James Brown (“Brown”), as an individual, filed a
motion for summary judgment to dismiss the breach of contract cause of action.
On February 26, 2019, the court filed its decision for the ruling on the motion for summary
judgment. Attached as Exhibit i is a copy of the court’s decision dated February 26, 2019. As to
Brown, the court granted the motion and dismissed Brown from the case. Brown is considered the
prevailing party relating to the case and can recover costs under Code of Civil Procedure § 1033.5.

Dated: » 2019
Honorable Christopher G. Rudy
Judge of the Superior Court

10
11
APPROVED AS TO FORM:
2
13
14 LAW OFFICES OF MICHAEL G. ACKERMAN

15
16
Dated: Mh 2 » 2019
17 ichael G. ‘kerman
ttomey for Plaintiff Phil Restivo
18
19
20
21
22

25
26
27
28

[PROPOSED] JUDGMENT
EXHIBIT 1
nAan

reer

FEB 2 6 2619
we
of the Court
fork of CACame cara
pest —__peruty

SUPERIOR COURT OF CALIFORNIA
COUNTY OF SANTA CLARA
10
PHILIP RESTIVO. Case No. 17CV308469
1
12 ORDER RE: MOTION FOR
Plaintiff,
SUMMARY JUDGMENT
13 vs.

14 DECISION ON SUBMITTED MATTER
WORLDWIDE GROUND
15 TRANSPORTATION SOLUTIONS, INC., et
16 al.,
17
Defendants.
18
19 The motion for summary judgment by defendants Worldwide Ground Transportation
20 Solutions, Inc. and James Brown came on for hearing before the Honorable Mary E. Arand on
21 February 5, 2019, at 9:00 a.m. in Department 9. The matter having been submitted, and the Court
22 not persuaded by arguments at the hearing, the Court finds and orders as follows
23 I Background
24 This lawsuit arises from a merger and acquisition transaction involving two limousine
25 companies
26 In May 2014, defendant Worldwide Ground Transportation Solutions, Inc.
27 (“Transportation Solutions”)—a limousine company operated by defendant James Brown
28 (“Brown”)—acquired a competing limousine company operated by plaintiff Philip Restivo

1
ORDER RE: MOTION FOR SUMMARY JUDGMENT
(‘Restivo”). (Compl., {| 6-7.) They agreed Restivo would not compete with Transportation
Solutions for seven years following the sale and would, in exchange, receive limousine services
at a discounted rate. (Compl., {J 6-7.) Restivo claims Brown and Transportation Solutions
(collectively, “Defendants”) failed to provide him with discounted limousine services as
promised. (Compl., {| 7.) He alleges that because he could obtain up to $5,000 worth of. limousing
services each month, he suffered $5,000 in damages each month from September 17, 2015, and

will continue to suffer damages until 2021. (Compl, {J 7-8.)
Restivo asserts a single cause of action for breach ofcontract against Defendants.
Currently before the Court is Defendants’ motion for summary judgment! Restivo opposes the
10 motion and filed a request for judicial notice in support.” Defendants filed objections to Restivo’s
11 evidence in connection with their reply ..
12 I. Legal Standard

13 A defendant may move for summary judgment on the ground.an action has no merit.

14 (Code Civ. Proc., § 437c, subd. (a)( 1).) A defendant bears the initial burden of proving “a cause
15 of action has no merit [by] show[ing] that one or more elements of the cause of action, even if

16
17 ''In the alternative, Defendants move for summary adjudication of the claim for breach of contract and a claim for
declaratory relief. But Restivo does not plead a claim for declaratory relief. In his prayer for relief, he requests the
18 remedy of “a declaration from the Court that the covenant not to compete is now terminated and of no further force
and effect...” (Compl. at p. 3:15-16.) “[T]the prayer is no part of the statement of the cause of action.” (Foley v.
19 Foley (1963) 214 Cal.App.2d 802, 809.) Thus, here, the prayer for relief does not give rise to a claim for declaratory
relief. The existence and nature of a cause of action are determined by the facts pleaded in the body of the
20 complaint. (Tashakori v. Lakis (2011) 196 Cal.App.4th 1003, 1011-12.) In the body of the pleading, Restivo clearly
and uiéquivocally alleges a breach of contract occurred; he does not allege the existence of a dispute for which
21 declaratory relief is available. (See Code Civ. Proc., § 1060; see, ¢.g., Roberts v. Los Angeles County Bar Assn.
(2003) 105 Cal.App.4th 604, 618.) Accordingly, there is no claim for declaratory relief alleged. It follows that
22 Defendants need only address the sole cause of action actually asserted for the purpose of their motion for summary
judgment. (See generally Lopez v. Super. Ct. (1996) 45 Cal.App.4th 705, 713-14.) Additionally, because there is
23 only one cause of action pleaded, it is unnecessary to consider whether they are also entitled to summary
adjudication. The Court, thus, treats the motion solely as a motion for summary judgment.
24 ? Ina portion of Restivo’s opposition entitled “Standards on a Motion-for Summary Judgment,” he objects to the
authenticity of exhibits presented by Defendants consisting of di requests, his discovery responses,
25 correspondence between the parties’ counsel. (Opp. at pp. 3:24, 4:12-18,) Written objections to evidence at
summary judgment must be served and filed separately and must comport with the content and formatting
26 Tequirements set forth in rule 3.1354 of the California Rules of Court. Restivo’s objections do not comport with

27
these irements, and so the Court need not rule on them. (See Hodjat v. State Farm Mutual Automobile Insuranc
Co, (2012) 211 Cal.App.4th 1, 9; see also Serri v. Santa Clara University (2014) 226 Cal.App.4th 830, 852-57.)
4
3 Defendants’ written objections are directed to evidence that is not material to the disposition
of the motion.
28 Accordingly, the Court need not rule on their objections; these objections are preserved. (Code Civ. Proc., § 437c,
subd. (q).)

2
ORDER RE: MOTION FOR SUMMARY JUDGMENT
not separately pleaded, cannot be established, or that there is a complete defense to the cause of
action.” (Code Civ. Proc., § 437c, subd. (p)(2).) To carry this burden, the defendant must present
supporting evidence, such as “affidavits, declarations, admissions, answers to interrogatories,
depositions, and matters of which judicial notice shall ormay be taken.” (Code Civ. Proc.,
§ 4376, subd. (6)(1).)
“Once the defendant [ ] has met that burden, the burden shifis to the plaintiff [ ] to show

that a triable issue of one or more material facts exists as to the cause of action or a defense
thereto.” (Code Civ. Proc., § 4376, subd. (p)(2).) “The plaintiff[ ] shall not rely upon the
allegations or denials of its pleadings to show that a triable issue of material fact exists but,
10 instead, shall set forth the specific facts showing that a triable issue of material fact exists as to
11 the cause of action or a defense thereto.” (Code Civ. Proc., § 437c,. subd. (p)(2).)
12 Ultimately, “{t]he motion for summary judgment shall be granted if all the papers
13 submitted show that there is no triable issue as to any material fact and that the moving party is
14 entitled to a judgment as a matter of law.” (Code Civ. Proc., § 437c, subd. (c).)
15 Ti. Request for Judicial Notice

16 Restivo requests judicial notice of the Court’s previous orders on a demurrer and motion
17 to disqualify Defendants’ counsel. Although a court may take judicial notice of court records
18 (Evid. Code, § 452, subd. (d)), a matter must be relevant in order for a court to take judicial
19 notice of it (Poseidon Development, Inc. v. Woodland Lane Estates, LLC (2007) 152 Cal.App.4th
20 1106, 1117). The prior orders are not relevant to the issues before the Court. Thus, they are not
21 proper subjects of judicial notice. Restivo’s request for judicial notice is therefore DENIED.

22 Iv. Summary of Evidence
23 The undisputed evidence shows that Transportation Solutions and Le Grande Affaire
24 Limousine Service’, as buyer and seller respectively, executed an acquisition agreement in May
25 2014. (Sep. Stat., | 1; Compl., Ex. A.) Transportation Solutions agreed to purchase the assets of
26 Le Grande Affaire for $300,000. (Compl., Ex. A.) The agreement contained an integration clause|
27

28
* Although operating under this name, the business was registered as Restivo Enterprises, Inc.

3
ORDER RE: MOTION FOR SUMMARY JUDGMENT.
and prohibition on oral modifications. (Compl., Ex. A.) Restivo and Brown signed the written
agreement as representatives of their respective businesses. (Sep. Stat., {| 1-3; Compl., Ex. A;
Brown Decl., { 4.)
Several weeks later, Transportation Solutions and Le Grande Affaire executed a written
addendum to their acquisition agreement. (Compl., Ex. A) They agreed, among other things, that
Restivo would receive discounted limousine services as follows:
For the duration of the Covenant Not to Compete, Phillip [sic]
Restivo may use-vehicles of [Transportation Solutions] for a price
equal to.the cost of the chauffeur and fuel subject to reasonable
amount of use as agreed between [Transportation Solutions] and
[Restivo], to service [his] personal use, friends, trades, and family
10 ‘usage.
11
In exchange, Restivo agreed not to compete with Transportation Solutions within a 100-
12
mile radius for a period of seven years.> (Compl.; Ex. B.)
13
Subsequently, a dispute arose between Restivo and Defendants over whether the volume
14
of discount limousine services requested was a reasonable amount within the meaning of the
15
addendum. (Brown Deel., { 14; Restivo Decl., 4] 4-5.) The parties went to mediation to resolve
16
this dispute in September 2015. (Brown Decl., J 11.) They reached an agreement to amend the
17
disputed clause in the addendum (quoted above) by adding the following language:
18
Vehicle trade use is good for any day or any time with the
19 exception of Saturdays when 8 passenger or smaller is okay but
anything over 8 passenger must be booked within 24 hours or less
20 notification.
21
The value of trade will be no more than $5,000 per month to
include all classes of usage. The $5,000 is accumulated and carried
over monthly but disregarded every four months, no more than
23 $60,000 of value per year.
24
(Compl., Ex. C.)
25

26
27
28 >The no specifically states it “applies in an individual capacity to any person signing [it] on
bebalf
of [the seller].” (Compl., Ex. B.)

4
ORDER RE: MOTION FOR SUMMARY JUDGMENT
The mediated settlement agreement states “(t]he parties agree that this settlement is
intended to be binding and enforceable... .without the execution of any further documents.”
(Compl., Ex. C at p. 1.) But it also states the parties intended to draft a formal amendment in
conformity with their settlement agreement. (Compl., Ex. C at pp. 1-2.) According to Restivo, he
subsequently took a draft agreement to Brown for signature, but Brown refused to sign it and” _
stated he changed his mind about their settlement. (Restivo Decl., 6; see also Brown Ex. 14.)
Brown maintains that he continues to honor their agreement and that his attorney informed
Restivo and his counsel of this fact in writing on several occasions. (Brown Decl., 1 15; Brown.
Ex. 19.) Since Restivo commenced this action in April 2017, he has not requested limousine
10 services despite Brown’s assurances that he may continue to do so. (Brown Ex. 1, Restivo Dep.

11 at p. 139:7-~25.) ‘
12 Vv. Merits of Motion

13 To establish a claim for breach of contract, a plaintiff must prove the existence ofa

14 contract, he or she performed or was excused from performing, defendant failed to perform, and
15 he or she suffered damages as a result. (Agam v. Gavra (2015) 236 Cal.App.4th 91, 104.)

16 Defendants argue Restivo’s claim lacks merit because he cannot establish the existence of a
17 contract with Brown and damages suffered as a result of abreach by Transportation Solutions.
18 A. Transportation Solutions

19 “Damages awarded to an injured party for breach of contract ‘seek to approximate the
20 agreed-upon performance.’ [Citation.]” (Lewis Jorge.Construction Management, Inc. v. Pomona

21 Unified School Dist, (2004) 34 Cal.4th 960, 967.) “In other words, the plaintiff isentitled to
22 damages that are equivalent to the benefit of the plaintiff's contractual bargain.” (Id. at pp. 967—
23 68.) “The injured party’s damages cannot, however, exceed what it would have received if the
24 contract had been fully performed on both sides.” (Id. at p. 968, citing Civ. Code, § 3358.)
25 As Transportation Solutions points out, the benefit Restivo bargained for was a discount
26 on limousine services. Consequently, the measure of his damages consists of the difference
27 between what he would have ordinarily had to pay for limousine services and the discounted
28

5
ORDER RE: MOTION FOR SUMMARY JUDGMENT
ptice he was entitled to pay Transportation Solutions under the parties’ agreement.° (See, ¢.g.,
KGM Harvesting Co. v. Fresh Network (1995) 36 Cal-App.4th 376, 382.) Contrary to what
Restivo alleges, he is not necessarily entitled to damages in the amount of the maximum value of,
services he conceivably could have requested each month, namely $5,000 per month.

With that clarification in mind, Transportation Solutions does not present evidence
establishing Restivo did not suffer any damages. Restivo did unequivocally concede that, since
he commenced this action in April 2017,he has not requested limousine services despite
wR
Brown’s assurance that he may continue to do so. (Brown Ex. 1, Restivo Dep. at p. 139:7-25. )°
Thus, the evidence shows Restivo has not suffered damages as a result of Transportation
10 Solutions refusing to furnish him vehicles from the time he commenced this action until he was
il deposed. But Restivo alleges Transportation Solutions first breached the agreement in Septemher|
12 2015
13 Transportation Solutions asserts Restivo has no evidence of unfulfilled requests for
14 limousine services from September 2015 until April 2017. A defendant moving for summary
1s judgment cannot carry its initial burden by simply pointing out the absence of evidence. (Aguilar
16 v. Atlantic Richfield Co. (2001) 25 Cal.4th 826,.854-55.) When moving for summary judgment,
17 “defendant may...conclusively negate an element of the plaintiffs cause of action [or] present
18 evidence that the plaintiff does not possess, and cannot reasonably obtain, needed evidence—as
19 through admissions by the plaintiff following extensive discovery to the effect that he has
20 discovered noting.” (Ibid.) - ~

21 Transportation Solutions does not present evidence conclusively negating the element of
22 damages. Additionally, the evidence does not show Restivo admitted he lacks and cannot
23 reasonably obtain needed evidence. Restivo did not admit in response to requests for admissions
24 that he lacks and cannot reasonably obtain evidence to support this element of his claim. (Brown
25
26
§ Restivo does not dispute this point in his opposition. Although not especially clear, to the extent he is asserting he
27 suffered damages as a result of being overcharged by Transportation Solutions, his assertion is not well-taken
because the specific breach alleged in the complaint is failure to provide services upon request (Compl., fj 7-8);
28 Restivo does not allege Transportation Solutions breached the agreement by overcharging him. (See generallyLaabs|
v. City of Victorville (2008) 163 Cal.App.4th 1242, 1253.)

6
ORDER RE: MOTION FOR SUMMARY JUDGMENT
Ex. 17.) Although his deposition testimony lacks clarity and specificity, he did testify that he
kept notes about his requests for services and purchased services from another limousine
company; he did, however, have some difficulty recalling any specific instance. (Brown Ex. 1, :
Restivo Dep. at pp. 99-100, 182.) The evidence is equivocal at best. For these reasons,
Transportation Solutions does not carry its initial burden by either conclusively negating the
element of damages or showing Restivo admittedly lacks and cannot obtain evidence of the

damages he suffered, ~~ _ + —~ ae - ~ =
B. Brown

Brown argues Restivo’s breach of contract claim lacks merit because he cannot establish
10 the existence of an agreement with him as an individual. It is undisputed that the parties to the
11 acquisition agreement, inclusive of the addendum, were.Transportation Solutions and Le Grande
12 Affaire; Brown was not ‘a party to this agreement.” (Sep. Stat., ff 1-3; Compl., Ex. A; Brown

13 Decl., 4; Brown Ex. 17.)

14 Nevertheless, Restivo maintains that Brown is a party to the agreement because he signed
15 the mediated settlement agreement.* “Directors and officers are not personally liable on contracts
16 signed by them for and on behalf of the corporation unless they purport to bind themselves

17 individually.” (United States Liability Insurance Co. v. Haidinger-Hayes, Inc. (1970) 1 Cal.3d
18 586, 595.) Thus, Brown is not personally bound by an agreement simply because his signature
19 appears on the agreement. Furthermore, there is no basis for concluding he signedthe agreement

20 in his individual capacity: An agreement necessarilycan only be modifiedbythe parties to-that- | ~
21 agreement. (Riverside Rancho Corp. v. ‘Cowan (1948) 88 Cal.App.2d 197, 208.) Restivo does not]
22 dispute that Brown is not a party to the acquisition agreement inclusive of the addendum. Thus,
Brown necessarily cannot have individually agreed to modify the agreement between
24
25 7 The Court notes the issue of whether Restivo was a third-party beneficiary is an entirely separate issue. (See
generally Spinks v. Equity Residential Briarwood Apartments (2009) 171 Cal.App.4th 1004, 1024-25.)
26 8 The Court did determine ai the pleading stage that Restivo adequately stated a claim against Brown because his
signature appeared on the mediated settlement agreement. A demurrer, unlike a motion for summary judgment, test:
27 the legal sufficiency of the pleading and not the parties’ evidence. (Nguyen v. Western Digital Corp. (2014) 229
Cal.App.4th 1522, 1536-37.) And so, the Court’s previous determination that a claim had been stated against Bro
28 does not preclude a determination as to whether he is actually a party to the agreement at issue based on the
undisputed evidence and arguments presented at this juncture.

7
ORDER RE: MOTION.FOR SUMMARY JUDGMENT
Transportation Solutions and Le Grande Affaire, which agreement contains the clause regarding
discounted limousine services that has purportedly been breachéd. Restivo presents no reasoned
explanation supported by legal authority to support a contrary conclusion.’ Instead, he rests on
conjecture and speculation that does not address this fundamental principle of contract law
For these reasons, Brown demonstrates Restivo cannot establish Brown personally agreed|
to provide discounted limousine services. Restivo fails to raise a triable issue of material fact in
opposition. Thus, the breach of contract claim lacks merit to the extent it isasserted against
ee Se eee a we -
Brown.
Cc. Conclusion
10 Based on the foregoing, Defendants’ motion for summary judgment is GRANTED IN
11 PART and DENIED IN PART. The motion is granted to the extent it is brought by Brown
12 because he demonstrates Restivo cannot establish an essential element of his breach of contract
13 claim as asserted against him. The motion is denied to the extent it is brought by Transportation
14 Solutions because it does not carry its initial burden of demonstrating Restivo’s claim lacks merit
15 as asserted against it in particular.
16
Mary E. Arand
17 Date: February Ho 2019
18 MARY E, ARAND
Judge of the Superior Court
19
—~ ane ee
20 ee —-

23
24
25
26
27
28 ° Restivo cites Carlesimo v. Schwebel (1948) 87 Cal.App.2d 482, which is wholly inapposite because, here, both
Parties were aware of the respective entities they represented.

8
ORDER RE: MOTION FOR SUMMARY JUDGMENT
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SANTA CLARA
DOWNTOWN COURTHOUSE
191 NORTH FirsT STREET
Lig ‘SAN José, CALIFORNIA 95113
CIVIL DIVISION

William Reid Cumming
3080 Bristol St Ste 630
Costa Mesa CA 92626

RE: ‘Philip Restivo vs. Worldwide Ground Transportation Solutions, Inc. atel
Case Number: 17CV308469

PROOF OF SERVICE
ORDER RE: MOTION FOR SUMMARY JUDGMENT (DECISION ON SUBMITTED MATTER) was delivered to
the parties listed below the above entitled case as set forth in the sworn declaration below.

If you, a party represented by you, or a witness to be called on behalf of that party need an accommodation under the American with
Disabilities Act, please contact the Court Administrator's office at (408) 882-2700, or use the Court’s TDD line (408) 882-2690 or the
Voice/TDD California Relay Service (800) 735-2922.

DECLARATION OF SERVICE BY MAIL: | declare that | served this notice by enclosing a true copy in a sealed envelope, addressed to
each person whose name is shown below, and by depositing the envelope with postage fully prepaid, inthe United States Mail at San Jose,
CA on February 26, 2019. CLERK OF THE COURT, by Catherine Pham, Deputy.

cc: Michael G Ackerman 2391 The Alameda Ste 100 Santa Clara CA 95050
Nancy M Battel 1101 Westwood Dr Ste B San Jose CA 95125

(CW-9027 REV 12/08/16 PROOF OF SERVICE
1 PROOF OF SERVICE
2 I, Laurie St. Claire, declare that my business address is 3080 Bristol Street, Suite 630,
Costa Mesa, CA 92626. I am over the age of eighteen years and not a party to this action. On
3 || the date set forth below, I served the foregoing document(s) described as:
4 [PROPOSED] JUDGMENT ON DEFENDANT JAMES BROWN’S MOTION FOR
SUMMARY JUDGMENT
5
6 {on the person(s) in this action listed in the attached Service List.

7
Oo BY FIRST CLASS MAIL: I am employed in the County of Orange County
8 where the mailing occurred. I enclosed the document(s) identified above in a
sealed envelope or package addressed to the person(s) listed above, with postage
9 fully paid. I placed the envelope or package for collection and mailing, following
our ordinary business practice. I am readily familiar with this firm’s practice for
10 collecting and processing correspondence for mailing. On the same day that
correspondence is placed for collection and mailing, it is deposited in the ordinary
11 course of business with the United States Postal Service.

12 BY PERSONAL SERVICE: I caused the document(s) identified above to be
delivered to the person(s) listed on the attached Service List via personal service.
13
BY OVERNIGHT DELIVERY: I enclosed the document(s) identified above in a
14 sealed envelope or package addressed to the person(s) listed above, in an
envelope or package designated by the overnight delivery carrier with delivery
15 fees paid or provided for. I placed the envelope or package for collection and
overnight delivery at an office or a regularly utilized drop box of the overnight
16 delivery carrier, or by delivering to a courier or driver authorized by the overnight
delivery carrier to receive documents.
17 XI BY ONE LEGAL E-SERVICE: I served the document(s) identified above by
18 delivering a copy to One Legal for electronic service on the person(s) listed on the
attached Service List.
19
BY ELECTRONIC MAIL: Based on a court order or an agreement of the parties
20 to accept service by electronic mail, I caused the document(s) identified above to
be transmitted electronically to the person(s) at the e-mail address(es) listed
21 above. I did not receive, within a reasonable time after the transmission, any
electronic message or other indication that the transmission was unsuccessful.
22
I declare under penalty of perjury under the laws of the United States and the State of
23 California that the foregoing is true and correct.

Executed on April 12, 2019, at Costa Mesa, California.

25
/s/ Laurie St. Claire
26 Laurie St. Claire
27

28
1

PROOF OF SERVICE
SERVICE LIST

Michael G. Ackerman, Esq.
mga@mgackermanlaw.com
Law Offices of Michael G. Ackerman
2391 The Alameda, Suite 100
Santa Clara, CA 95050
Telephone: 408-261-5800
Facsimile: 408-261-5900
Counsel for Plaintiff Philip Restivo

Nancy M. Battel
nancy@battelaw.com
Law Offices of Nancy M. Battel
1101 Westwood Drive, Suite B
San Jose, CA 95125
10 Telephone: 408-723-2946
Facsimile: 408-266-7238
il Co-counsel for Worldwide Ground Transportation Solutions, Inc. and James Brown

13
14

15
16

21
22

28
2

PROOF OF SERVICE

Case Info

Judge

Sunil R. Kulkarni Track Judge’s New Case

Case No.

(Subscribe to View)

Document Filed Date

April 12, 2019

Case Filing Date

April 12, 2017

County

Parties

For full print and download access, please subscribe at https://www.trellis.law/.

Motion-Secondary: Philip Restivo vs Worldwide Ground Transportation Solutions, Inc. at el

Preview

Case Info

Parties