Memorandum: Points and Authorities - Memorandum of Points & Authorities

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                          Michael G. Ackerman, Esq. (SBN 64997)

LAW OFFICES OF MICHAEL G. ACKERMAN
2391 The Alameda, Suite 100

Santa Clara, CA 95050

Telephone: (408) 261-5800

Facsimile: (408) 261-5900

Email: mga@mgackermanlaw.com

Attorneys for Plaintiff,
PHIL RESTIVO

SUPERIOR COURT FOR THE STATE OF CALIFORNIA

COUNTY OF SANTA CLARA
PHILIP RESTIVO, } Case No.: 17CV308469
Plaintiff, )
) MEMORANDUM OF POINTS AND
vs. ) AUTHORITIES TO AMEND
2 COMPLAINT
WORLDWIDE GROUND )
TRANSPORTATION SOLUTIONS, INC.; )
JAMES BROWN, an individual; and DOES )
1 through 5, inclusive. ;
Defendants. )
)
INTRODUCTION:

Plaintiff filed a complaint containing one cause of action for breach of contract, referring

specifically to the mediated settlement agreement attached as Exhibit “C” to the complaint. Plaintiff

alleges in paragraph 7 of the complaint that Defendants breached the agreement by failing to provide

discount limousine services as promised. Defendants filed a motion for summary judgment. In the

tentative ruling on t…