On November 18, 2015 a
Answer
was filed
involving a dispute between
Les Stanford Chevrolet Cadillac, Inc,
Saberi, Andy,
and
Bj Interstate Autotransporters, Inc,
Dedyk, Bogdan,
Les Stanford Chevrolet Cadillac, Inc,
for (06) Unlimited Breach of Contract/Warranty
in the District Court of San Mateo County.
Preview
PLD-Pl-003
ATTORNEY 0R PARTY WITHOUT ATTORNEY (NAME AND ADDRESS): TELEPHONE NO.: FOR COURT USE ONLY
James Attridge SBN 124003 415-552-3088
270 Divisadero Street # 3
San Francisco, CA 941 17
ATTORNEY FOR (NAME): E] Interstate Auto Transporters, Inc.
Insert name of court. judicial district or branch court, if any. and post office and street address:
.
FILEB ’
San Mateo County Superior Court SAN MATEO COUNT‘
400 County Government Center
Redwood City, CA 94063
law-2 .3 ZDIS
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Wk «:9 = - ' -
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PLAINTIFF:
Andy Sabieri
.. J87'7" “I
DEFENDANT:
Les Stanford Chevrolet Cadillac, Inc.
5%
‘3
Q _
ANSWER—Personal Injury, Property Damage, Wrongful Death
-
CASE NUMBER:
a:
E
I: COMPLAINT OF (name): Andy Sabieri
CROSS-COMPLAINT 0F (name):
536294
1. This pleading, including attachments and exhibits. consists of the following number of pages:
DEFENDANT OR CROSS-DEFENDANT (name):
2. Generally denies each allegation of the unverified complaint or cross-complaint.
§
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/§§§§§ i '
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3 a. DENIES each allegation of the following numbered paragraphs:
§
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a ”A”
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b. ADMITS each allegation of the following numbered paragraphs: I g
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c. I:I DENIES, ON INFORMATION AND BELIEF. each allegation of the following numbered paragraphs: l
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d. I: DENIES. BECAUSE OF LACK OF SUFFICIENT INFORMATION OR BELIEF TO ANSWER, each allegation
of the following numbered paragraphs:
e. :I ADMITS the following allegations and generally denies all other allegations:
Page 1 of 2
Form Approved for Optional Use
Judicial Council of California ANSWER—Personal Injury, Property Damage. Wrongful Death Code of CiVII Procedure. § 425.12
PLD-PI-OOS [Rcv. January 1. 2007]
www.courtinio.ca.gov
PLD-PI-003
SHORT TITLE: CASE NUMBER:
Sabieri v. Les Stanford 536294
ANSWER—Personal Injury, Property Damage, Wrongful Death
f. l:l DENIES the following allegations and admits all other allegations:
9. :1 Other (specify):
AFFIRMATIVELY ALLEGES AS A DEFENSE
4. The comparative fault of plaintiff or cross-complainant (name):
as follows:
1. Plaintiff fails to state a cause of action against this defendant for which relief can be granted.
2. As a freight broker, this defendant owed no duty of care to the plaintiff.
3. This defendant fulfilled its sole legal obligation by confirming that co-defendant Bogdan Dedyk
was licensed and insured.
4. This defendant's liability arises solely under federal law which prempts the fourth cause of action.
5. All damages suffered by defendant were proximately cause by the conduct of defendant Dedyk.
6. Plaintiff waived its right to recover for interstate cargo damage by failing to file a presuit claim.
5. l:l The expiration of the Statute of Limitations as follows:
6. i: Other (specify):
7. DEFENDANT OR CROSS - DEFENDANT PRAYS
For costs of suit and that plaintiff or cross—complainant take nothing.
Other (specify):
1. For attorneys fees as sanctions for frivolous litigation; and
2. For indemnity against cO-defendant Dedyk as outlined in the -c plaint.
/
James Attridge
I
/ u
(Type or pn'nt name) V (Signature of party or attorney)
PLD-Pl-003 [Rem January 1. 2007] ANSWER—Personal Injury, Property Damage, Wrongful Death "992°”
Proof of Service
I am employed in the County of San Francisco, State of California. am over the
1
age of eighteen and am not a party to this litigation. My business address is 270
Divisadero Street, #3 San Francisco, California. On this date I served this Answer to
Complaint to which this proof is appended upon:
James Dombroski
PO. Box 751027
Petaluma, CA 94975—1027
Tom Crowell
Toschi, Sidran, Collins & Doyle
5145 Johnson Drive
Pleasanton, CA 94588
Michael LeVangie
LeVangie law Group
2021 N Street
Sacramento, CA 95811
by placing a copy of said answer in an envelope with postage affixed thereto addressed to
him and placed it in the United States Mail at a mailbox in San Francisco, California. 1
am aware that on motion of the party served, service is presumed invalid if postal
cancellation date or postage meter date is more than one day after date of deposit for
mailing as stated in this proof of service.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct. Executed at San Francisco, Calif r , NoVember 20,2016.
V "James Attridge
N310 AmcElO
Na
mag muadns am go x1919
9102 3 Z AON
A. 1.3!5'30’3 03.53MB NVS
Document Filed Date
November 23, 2016
Case Filing Date
November 18, 2015
Category
(06) Unlimited Breach of Contract/Warranty
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Preview
PLD-Pl-003 ATTORNEY 0R PARTY WITHOUT ATTORNEY (NAME AND ADDRESS): TELEPHONE NO.: FOR COURT USE ONLY James Attridge SBN 124003 415-552-3088 270 Divisadero Street # 3 San Francisco, CA 941 17 ATTORNEY FOR (NAME): E] Interstate Auto Transporters, Inc. Insert name of court. judicial district or branch court, if any. and post office and street address: . FILEB ’ San Mateo County Superior Court SAN MATEO COUNT‘ 400 County Government Center Redwood City, CA 94063 law-2 .3 ZDIS .’ Wk «:9 = - ' - I PLAINTIFF: Andy Sabieri .. J87'7" “I DEFENDANT: Les Stanford Chevrolet Cadillac, Inc. 5% ‘3 Q _ ANSWER—Personal Injury, Property Damage, Wrongful Death - CASE NUMBER: a: E I: COMPLAINT OF (name): Andy Sabieri CROSS-COMPLAINT 0F (name): 536294 1. This pleading, including attachments and exhibits. consists of the following number of pages: DEFENDANT OR CROSS-DEFENDANT (name): 2. Generally denies each allegation of the unverified complaint or cross-complaint. § \ /§§§§§ i ' I:I M 3 a. DENIES each allegation of the following numbered paragraphs: § § S / I é’ a ”A” “ I: § I § I I s a § b. ADMITS each allegation of the following numbered paragraphs: I g I 3‘ I I’ -' S 5 3' @— c. I:I DENIES, ON INFORMATION AND BELIEF. each allegation of the following numbered paragraphs: l I d. I: DENIES. BECAUSE OF LACK OF SUFFICIENT INFORMATION OR BELIEF TO ANSWER, each allegation of the following numbered paragraphs: e. :I ADMITS the following allegations and generally denies all other allegations: Page 1 of 2 Form Approved for Optional Use Judicial Council of California ANSWER—Personal Injury, Property Damage. Wrongful Death Code of CiVII Procedure. § 425.12 PLD-PI-OOS [Rcv. January 1. 2007] www.courtinio.ca.gov PLD-PI-003 SHORT TITLE: CASE NUMBER: Sabieri v. Les Stanford 536294 ANSWER—Personal Injury, Property Damage, Wrongful Death f. l:l DENIES the following allegations and admits all other allegations: 9. :1 Other (specify): AFFIRMATIVELY ALLEGES AS A DEFENSE 4. The comparative fault of plaintiff or cross-complainant (name): as follows: 1. Plaintiff fails to state a cause of action against this defendant for which relief can be granted. 2. As a freight broker, this defendant owed no duty of care to the plaintiff. 3. This defendant fulfilled its sole legal obligation by confirming that co-defendant Bogdan Dedyk was licensed and insured. 4. This defendant's liability arises solely under federal law which prempts the fourth cause of action. 5. All damages suffered by defendant were proximately cause by the conduct of defendant Dedyk. 6. Plaintiff waived its right to recover for interstate cargo damage by failing to file a presuit claim. 5. l:l The expiration of the Statute of Limitations as follows: 6. i: Other (specify): 7. DEFENDANT OR CROSS - DEFENDANT PRAYS For costs of suit and that plaintiff or cross—complainant take nothing. Other (specify): 1. For attorneys fees as sanctions for frivolous litigation; and 2. For indemnity against cO-defendant Dedyk as outlined in the -c plaint. / James Attridge I / u (Type or pn'nt name) V (Signature of party or attorney) PLD-Pl-003 [Rem January 1. 2007] ANSWER—Personal Injury, Property Damage, Wrongful Death "992°” Proof of Service I am employed in the County of San Francisco, State of California. am over the 1 age of eighteen and am not a party to this litigation. My business address is 270 Divisadero Street, #3 San Francisco, California. On this date I served this Answer to Complaint to which this proof is appended upon: James Dombroski PO. Box 751027 Petaluma, CA 94975—1027 Tom Crowell Toschi, Sidran, Collins & Doyle 5145 Johnson Drive Pleasanton, CA 94588 Michael LeVangie LeVangie law Group 2021 N Street Sacramento, CA 95811 by placing a copy of said answer in an envelope with postage affixed thereto addressed to him and placed it in the United States Mail at a mailbox in San Francisco, California. 1 am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing as stated in this proof of service. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed at San Francisco, Calif r , NoVember 20,2016. V "James Attridge N310 AmcElO Na mag muadns am go x1919 9102 3 Z AON A. 1.3!5'30’3 03.53MB NVS