Preview
FILED
1 Kenneth N. Greenfield, Esq. (State Bar No. 105721)
Alexandra N. Selfridge, Esq. (State Bar No. 247063)
2
LAiV OFFICES OF Glerk Ot Oe. uperlI)i GOurt
KENNETH N. GREENFIELD
16516 BERNARDO CENTER DRIVE, SUITE 210 By
DS K
SAiVDIEGO, CA 92128
(858) 675-0301
FAX (858) 67 5 —0319
5
Attorneys for Defendant, WAWANESA GENERAL INSURANCE COMPANY
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN MATEO
10 GEORGE MARDIKIAN, ) Lead Case No CIV 517132
) Consohdated with Case No CIV 526757
Plamtiff, )
) DECLARATIONOF ALKXANDRAN.
vs )
SELFRIDGE IN SUPPORT OF
13
DEFENDANT WAWANESA GENERAL
) INSURANCE COMPANY'S PROPOSED
WAWANESA GENERAL INSURANCE )
14
ORDER GRANTING DEFENDANT'S
COMPANY, a corporation, and DOES 1 ) MEMORANDUMOF COSTS ON
through 50, mclusive, ) APPEAL AND ENTERING COSTS ON
15
) JUDGMENT
16 Defendants )
) Filed Concurrentlv with
17 ) [Proposedj Order
)
18 Date I'iled October 3, 2012
)
Trial Date October 19, 2015
19 )
)
20
I, Alexandra N. Selfridge, declare as follows
23 1. I am an attorney duly licensed to practice before all of the courts of the State of
24 Cahfornia and am an associate with the Law Offices of Kenneth N Greenfield, attorneys of
25 record for Defendant Wawanesa General Insurance Company I have personal laxowledge of each
26 of the following facts and, if called as a witness, could and would testify competently hereto,
27 except as to those matters which are exphcitly set forth as based upon my mformation and behef
28 and, as to such matters, I am informed and believe that they are true and correct
1
DECLARATIONOF ALEXANDRAN. SELFRIDGE RE: COSTS ON APPEAL
1 2. This declaration is made in support of Defendant Wawanesa General Insurance
2 Company's Proposed Order Grantmg Defendant's Memorandum of Costs on Appeal and
3 Entering Costs on Judgment
4 3. Judgment was entered against Plamtiff Lilhan Mardikian on November 6, 2014
5 4 Plaintiff filed a Notice of Appeal on January 12, 2015
6 5. The Court of Appeal dismissed Ms Mardikian's appeal on March 4, 2015
7 6 My firm served Pro Per Plaintiff Lilhan Mardikian with its Memorandum of Costs
8 on Appeal in the amount of $ 419.70 by mail on May 7, 2015
9 7. Plaintiff Lillian Mardikian's Motion to Tax and/or Strike Costs was due to be filed
10 no later than May 27, 2015.
11 8 Plamtiff Lillian Mardikian did not challenge Defendant's Memorandum of Costs
12 on Appeal by way of a Motion to Tax and/or Strike Costs.
ai 13 I declare under penalty of perjury under the laws of the State of Cahforma that the
ee
inc
Q 7 ) ea 14 foregoing is true and correct and that this declaration was executed m the City of San Diego, State
ea
g
z
15 of Califonna on June oI 3, 2015
~Evq
0 ~ o oJ
r)Pw a
eu4 16
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ALEXANDRIA.~'hFRIDGE, Declarant
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DECLARATIONOF ALEXANDRAN. SELFRIDGE RE: COSTS ON APPEAL
George Mardikian Case No. CIV 517132
v. Wawanesa General Insurance Company et al. (Consolidated with CIV 526757)
2
3 SUPERIOR COURT OF THE STATE OF CALIFORNIA
4 COUNTY OF SAN MATEO
5 PROOF OF SERVICE
C.C.P $ 1013a, C.R.C. 2 300, et seq.
6
STATE OFi CALIFORNIA )
7
) ss.
COUNTY OF SAN DIEGO )
9
I am employed in the aforesaid County, State of California. I am over the age of 18 years and not
a party to the within action; my business address is16516 Bernardo Center Drive, Suite 210, San Diego,
10 Cahfornia 92128.
On June 29, 2015, I served the following document(s) described as.
12 [PROPOSED] ORDER GRANTING DEFENDANT WAWANESA GENERAL
INSURANCE COMPANY7S MEMORANDUMOF COSTS ON APPEAL
REGARDING PLAINTIFF LILLIANMARDIKIANAND ENTERING COSTS ON
14
JUDGMENT
DECLARATIONOF ALEXANDRAN. SKLFRIDGE IN SUPPORT OF DEFENDANT
WAWANESA GENERAL INSURANCE COMPANY'S PROPOSED ORDER
16 GRANTING DEFENDANT'S MEMORANDUMOF COSTS ON APPEAL AND
ENTERING COSTS ON JUDGMENT
17
on the interested parties in this action by:
18
19 [X] Placing the original X a true copy thereof, enclosed in a sealed envelope,
addressed as follows.
[ ] Facsimile transmission as stated below.
21 Counsel for Plaintiff. Georae Mardikian Plaintiff in Pro Per
Montie S. Day, Esq. Lillian Mardikian
22 Day Law Offices 2349 Shannon Dr.
1235 Casa'Palermo Circle South San Francisco, CA 94080
23 Henderson', Nevada 89011-3144 T: (415) 756-6550
T: (208) 280-3766
24 F: (800) 219-2901
msdavesa@aoL corn
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Proof o1service
'BY, MAIL. I am "readily familiar" with the firm's practice of collection and processing
correspondence for mailing Under that practice, it would be deposited with the United States
Postal Service on that same day, with postage thereon fully prepaid at San Diego, California in
the ordinary course of busmess. I am aware that on motion of the party served, service is
presumed invahd ifpostal cancellation date or postage meter date is more than one day after date
of deposit for mailing an affidavit.
5 [] BY FEDERAL EXPRESS
such documents in San Diego,
OVERNIGHT DELIVERY.On the
California, in a box or other
date stated above, I deposited
like facihty regularly maintamed by
FEDERAL EXPRESS for receipt of overnight deliveries, or delivered to an authorized courier or
driver authorized by the express service carrier to receive documents, in a sealed envelope or
package designated by said carrier for dehvery, with dehvery fees paid or provided for, addressed
to the person on whom it is to be served at the office address as last given by that person on any
document filed in the cause and served on the party making service.
9
10 [] BY PERSONAL SERVICE: I caused such envelope to be dehvered by hand to the addressee
11 [] BY FACSIMILE TRANSMISSION.
29011and directed to Montie S. Day, Esq.
From
The
Fax No
facsimile
(858)
machme
675-0319
I used
to Fax
comphed
No. (800) 219-
with Rule
12
2 301, and no error was reported by the machine, I caused the machine to print a record of the
13 transmission, a copy of which is attached to this declaration.
14 [] BY E-MAIL to msdavesa@aol.corn (Courtesy Copy Only).
[x] STATE: I declare under penalty of perjury under the laws of the State of Cahfornia
16 that the above is true and correct
17 Executed', on June 29, 2015, at San Diego, California
19
~Ch@rrero
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Proof of Service
Preview
FILED 1 Kenneth N. Greenfield, Esq. (State Bar No. 105721) Alexandra N. Selfridge, Esq. (State Bar No. 247063) 2 LAiV OFFICES OF Glerk Ot Oe. uperlI)i GOurt KENNETH N. GREENFIELD 16516 BERNARDO CENTER DRIVE, SUITE 210 By DS K SAiVDIEGO, CA 92128 (858) 675-0301 FAX (858) 67 5 —0319 5 Attorneys for Defendant, WAWANESA GENERAL INSURANCE COMPANY SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN MATEO 10 GEORGE MARDIKIAN, ) Lead Case No CIV 517132 ) Consohdated with Case No CIV 526757 Plamtiff, ) ) DECLARATIONOF ALKXANDRAN. vs ) SELFRIDGE IN SUPPORT OF 13 DEFENDANT WAWANESA GENERAL ) INSURANCE COMPANY'S PROPOSED WAWANESA GENERAL INSURANCE ) 14 ORDER GRANTING DEFENDANT'S COMPANY, a corporation, and DOES 1 ) MEMORANDUMOF COSTS ON through 50, mclusive, ) APPEAL AND ENTERING COSTS ON 15 ) JUDGMENT 16 Defendants ) ) Filed Concurrentlv with 17 ) [Proposedj Order ) 18 Date I'iled October 3, 2012 ) Trial Date October 19, 2015 19 ) ) 20 I, Alexandra N. Selfridge, declare as follows 23 1. I am an attorney duly licensed to practice before all of the courts of the State of 24 Cahfornia and am an associate with the Law Offices of Kenneth N Greenfield, attorneys of 25 record for Defendant Wawanesa General Insurance Company I have personal laxowledge of each 26 of the following facts and, if called as a witness, could and would testify competently hereto, 27 except as to those matters which are exphcitly set forth as based upon my mformation and behef 28 and, as to such matters, I am informed and believe that they are true and correct 1 DECLARATIONOF ALEXANDRAN. SELFRIDGE RE: COSTS ON APPEAL 1 2. This declaration is made in support of Defendant Wawanesa General Insurance 2 Company's Proposed Order Grantmg Defendant's Memorandum of Costs on Appeal and 3 Entering Costs on Judgment 4 3. Judgment was entered against Plamtiff Lilhan Mardikian on November 6, 2014 5 4 Plaintiff filed a Notice of Appeal on January 12, 2015 6 5. The Court of Appeal dismissed Ms Mardikian's appeal on March 4, 2015 7 6 My firm served Pro Per Plaintiff Lilhan Mardikian with its Memorandum of Costs 8 on Appeal in the amount of $ 419.70 by mail on May 7, 2015 9 7. Plaintiff Lillian Mardikian's Motion to Tax and/or Strike Costs was due to be filed 10 no later than May 27, 2015. 11 8 Plamtiff Lillian Mardikian did not challenge Defendant's Memorandum of Costs 12 on Appeal by way of a Motion to Tax and/or Strike Costs. ai 13 I declare under penalty of perjury under the laws of the State of Cahforma that the ee inc Q 7 ) ea 14 foregoing is true and correct and that this declaration was executed m the City of San Diego, State ea g z 15 of Califonna on June oI 3, 2015 ~Evq 0 ~ o oJ r)Pw a eu4 16 17 18 ALEXANDRIA.~'hFRIDGE, Declarant 19 20 22 23 24 25 26 27 28 2 DECLARATIONOF ALEXANDRAN. SELFRIDGE RE: COSTS ON APPEAL George Mardikian Case No. CIV 517132 v. Wawanesa General Insurance Company et al. (Consolidated with CIV 526757) 2 3 SUPERIOR COURT OF THE STATE OF CALIFORNIA 4 COUNTY OF SAN MATEO 5 PROOF OF SERVICE C.C.P $ 1013a, C.R.C. 2 300, et seq. 6 STATE OFi CALIFORNIA ) 7 ) ss. COUNTY OF SAN DIEGO ) 9 I am employed in the aforesaid County, State of California. I am over the age of 18 years and not a party to the within action; my business address is16516 Bernardo Center Drive, Suite 210, San Diego, 10 Cahfornia 92128. On June 29, 2015, I served the following document(s) described as. 12 [PROPOSED] ORDER GRANTING DEFENDANT WAWANESA GENERAL INSURANCE COMPANY7S MEMORANDUMOF COSTS ON APPEAL REGARDING PLAINTIFF LILLIANMARDIKIANAND ENTERING COSTS ON 14 JUDGMENT DECLARATIONOF ALEXANDRAN. SKLFRIDGE IN SUPPORT OF DEFENDANT WAWANESA GENERAL INSURANCE COMPANY'S PROPOSED ORDER 16 GRANTING DEFENDANT'S MEMORANDUMOF COSTS ON APPEAL AND ENTERING COSTS ON JUDGMENT 17 on the interested parties in this action by: 18 19 [X] Placing the original X a true copy thereof, enclosed in a sealed envelope, addressed as follows. [ ] Facsimile transmission as stated below. 21 Counsel for Plaintiff. Georae Mardikian Plaintiff in Pro Per Montie S. Day, Esq. Lillian Mardikian 22 Day Law Offices 2349 Shannon Dr. 1235 Casa'Palermo Circle South San Francisco, CA 94080 23 Henderson', Nevada 89011-3144 T: (415) 756-6550 T: (208) 280-3766 24 F: (800) 219-2901 msdavesa@aoL corn 25 26 27 Proof o1service 'BY, MAIL. I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing Under that practice, it would be deposited with the United States Postal Service on that same day, with postage thereon fully prepaid at San Diego, California in the ordinary course of busmess. I am aware that on motion of the party served, service is presumed invahd ifpostal cancellation date or postage meter date is more than one day after date of deposit for mailing an affidavit. 5 [] BY FEDERAL EXPRESS such documents in San Diego, OVERNIGHT DELIVERY.On the California, in a box or other date stated above, I deposited like facihty regularly maintamed by FEDERAL EXPRESS for receipt of overnight deliveries, or delivered to an authorized courier or driver authorized by the express service carrier to receive documents, in a sealed envelope or package designated by said carrier for dehvery, with dehvery fees paid or provided for, addressed to the person on whom it is to be served at the office address as last given by that person on any document filed in the cause and served on the party making service. 9 10 [] BY PERSONAL SERVICE: I caused such envelope to be dehvered by hand to the addressee 11 [] BY FACSIMILE TRANSMISSION. 29011and directed to Montie S. Day, Esq. From The Fax No facsimile (858) machme 675-0319 I used to Fax comphed No. (800) 219- with Rule 12 2 301, and no error was reported by the machine, I caused the machine to print a record of the 13 transmission, a copy of which is attached to this declaration. 14 [] BY E-MAIL to msdavesa@aol.corn (Courtesy Copy Only). [x] STATE: I declare under penalty of perjury under the laws of the State of Cahfornia 16 that the above is true and correct 17 Executed', on June 29, 2015, at San Diego, California 19 ~Ch@rrero 20 21 22 23 24 25 26 27 Proof of Service