Motion-Secondary: ANDY SABERI VS LES STANFORD, ETAL

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             JAMES ATTRIDGE [Bar No. 124003)
             LAW OFFICE OF JAMES ATTRIDGE
             270 Divisadero Street, #3
             San Francisco, CA 94117
                                                                             FILED
             Telephone: (415) 552-3088                              SAN MATEO COUNTY
             Attorneys for Defendant                                            OCT.A1.0-2018
             BJ Interstate Auto Transporters, Inc.
                                                                                            Sup6rlor Court



                                SUPERIOR COURT OF THE STATE OF CALIFORNIA
                                          FOR THE COUNTY OF SAN MATEO
        10                                     UNLIMITED JURISDICTION
        11
        12   ANDY SABERI                                    CASE NO:             CIV 536294
        13                  Plaintiff,                     OPPOSITION TO MOTION IN LIMINE
                                                           NUMBER TWO TO EXCLUDE EVIDENCE
        14          VS.                                    THAT CARRIER WAS UNINSURED (SIC)
        15   LES STANFORD CHEVROLET
             CADILLAC, INC., et. al.                                                           d authorities
        16                                                       women       ndum of Points an



                                                                  IN iw
                                                                  4426575,
                            Defendants
        17

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        19          Defendant BJ Interstate Auto Transporters, Inc. is somewhat at a loss about how to
        20   respond to this motion, which it assumes to have been miss-captioned. BJ Interstate intends to
        21   introduce evidence that Bogdan Dedyk dba Safe Auto Transport was insured.
        22          The motion is comprised of two introductory pages of boilerplate in no way specific to the
        23   case, followed by a party admission that Mr. Saberi has no case against BJ Interstate, followed by
        24   a plea to exclude evidence on the grounds that there is too much of it. This is less'a motion in
        25   limine than it is a request for humane terms of surrender. Plaintiff Saberi fears post-trial motions
        26   for sanctions given that it is abundantly clear that its case is nothing beyond a shakedown and Mr.
        27   Saberi has spent three years casually lying in order to maintain it. If Mr. Saberi believes “there is
        28   no necessity for BJ to present evidence”   as to the only allegation against it, his obvious recourse is

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         to dismiss the case and face the music he is bound to face an’




                                                                      fe
                                                               James Attridge, Counsel for BJ Interstate



                                                        Proof of Service

         I James Attridge declare and state that I am counsel for record for defendant BJ Interstate Auto

         Transporters, Inc. and that I know the following of my own personal knowledge and if called upon
    10   to do so could and would competently testify thereto. On October 9, 2018 I placed this Opposition
    11   and the Declaration of James Attridge in Opposition in an overnight envelope addressed to
    12   James Dombroski

    13   P.O. Box 751027

    14   Petaluma, CA 94975

    15   And forwarded it by overnight courier. I also placed said documents in the United States mail
    16   addressed to:

    17   Michael LeVangie

    18   LeVangie Law Group
    19   2021 N Street

    20   Sacramento, CA 95811

    21
    22   I declare under penalty of perjury under the laws of the State of California that the above is true
    23   and correct. Executed October 9, 2018 at Littleton, Colorad
    24

    25

    26                                                          UV         James Attridge
    27

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