On November 18, 2015 a
Motion-Secondary
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
O _
O
\/\
JAMES ATTRIDGE SBN 124003
LAW OFFICE OF JAMES ATTRIDGE
270 Divisadero Street, #3
\/\
San Francisco, CA 941 17
415-552-3088
Jattridge@attridgelaw.com
Attorney for Defendant/Cross-Complainant
BJ Interstate Auto Transporters, Inc.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN MATEO UNLINIITED JURISDICTION
ANDY SABERI Case No.: CIV 536294
Plaintiff, DECLARATION OF BEVERLY LARSON
IN OPPOSITION TO MOTION FOR GOOI
vs. FAITH SETTLEMENT
LES STANFORD CHEVROLET CADILLAC,
INC, BI INTERSTATE AUTO DATE: January 7, 2019
TRANSPORTERS, INC, and BOGDAN TME: 9
vvvvvvvvvvvvvvvv
AM
DEDYK, dba SAFE AUTO TRANSPORT DEPT: 16-COURTROOM 7
17
HONORABLE RICHARD DuBOIS
18 Defendants g cw536294
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Declaration in Opposition
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INSERT DOCUMENT TITLE (e.g.,MOTION TO STRIKE)
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I,Beverly Larson declare and state:
1. I am the owner of defendant BJ Interstate Auto Transporters, Inc. Iknow the following of my
own personal knowledge and if called upon to do so could and would competently testify
thereto.
BJ Interstate is a licensed transportation broker specializing in arranging for the transportation
of automobiles in interstate commerce by licensed motor carriers like Bogdan Dedyk and his
\OOONO
ccmpany Safe Auto Transport, Inc. Prior to retaining the services of a motor carriepI verify its
licensure on the Federal Motor Carrier Administration website. That Website also contains
10
information pertaining to the carrier’s cargo insurance coverage. If a carrier’s insurance has
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lapsed for any reaggg, insurance companies are required by law to advise the FMCSA, which
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in tu~rn suspends the cérrief’s licensure. My cofipany fitilié-ed the servicés of Safe Auto
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.14.
Transport fof oVer a year prior to the matters referred to in the first amended complaint and at
15 no time was Safe Auto ever Uninsured‘of Suspended.
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At the time I formed the company Iwas advised by my licensing agent that brokers like BJ
18 Interstate were not required to carry cargo insurance because brokers are not lible for cargo
19 damage.
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In my 19 years in business I was only sued for cargo loss once. That was a small claims case
22 Which was dismissed by the Judge. When I received the plaintiff” s default I contacted a lawyer
23 who was the daughter of a client, Sands Chevrolet. She directed me to a transportation law
24 Phoenix named whb me to
specialist in Gary Doyle, in turn advised contact my lawyer in this
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casé, Mr. Attridge.
2.6
27 I normally earn a profit ofbetween $34,000.00 and $38,000.00 a year. There'iésirhply no
28 wayI ever could have paid a judgment of over $126,000.00 plus attorney fees. I do not carry
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INSERT DOCUMENT TITLE MOTION TO
(e.g., STRIKE)
cargo insurance on my business because I have been informed that I do not have to. I only
maintain a bond Which is required by the FMCSA to ensure that truckers get paid if brokers go
bankrupt or close shop Without paying freight charges.
6. When I first contacted Mr. Attridge he assured me that itwas common for these types of cases
to be brought by lawyers With littlebackground in transportation law and that normally once
Mr. Attridge called those laws to the plaintiff’ scounsel’s attention, the case would be
dismissed.
10 7. Had itnot been for MI. Attridge’s willingness to represent me despite my limited ability to
11 my business or declare bankruptcy.
pay, I believe that I may have been forced to close
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I declare under penalty of perjury under the laws of the States of Arizona and California that the
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14 above is true and correct. Executed at Sun City, Arizona November ,Zj ,
2018.
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%/:44—»
19 Beverly Larson
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INSERT DOCUIVIENT TITLE MOTION TO
(e.g., STRIKE)
Document Filed Date
December 21, 2018
Case Filing Date
November 18, 2015
Category
(06) Unlimited Breach of Contract/Warranty
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O _ O \/\ JAMES ATTRIDGE SBN 124003 LAW OFFICE OF JAMES ATTRIDGE 270 Divisadero Street, #3 \/\ San Francisco, CA 941 17 415-552-3088 Jattridge@attridgelaw.com Attorney for Defendant/Cross-Complainant BJ Interstate Auto Transporters, Inc. SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN MATEO UNLINIITED JURISDICTION ANDY SABERI Case No.: CIV 536294 Plaintiff, DECLARATION OF BEVERLY LARSON IN OPPOSITION TO MOTION FOR GOOI vs. FAITH SETTLEMENT LES STANFORD CHEVROLET CADILLAC, INC, BI INTERSTATE AUTO DATE: January 7, 2019 TRANSPORTERS, INC, and BOGDAN TME: 9 vvvvvvvvvvvvvvvv AM DEDYK, dba SAFE AUTO TRANSPORT DEPT: 16-COURTROOM 7 17 HONORABLE RICHARD DuBOIS 18 Defendants g cw536294 ' Declaration in Opposition 19 20 N\W“mm\|\\\||\\\|\|\\||\\|\\ 21 22 23 24 25 26 27 28 _ 1 _ INSERT DOCUMENT TITLE (e.g.,MOTION TO STRIKE) O v O I,Beverly Larson declare and state: 1. I am the owner of defendant BJ Interstate Auto Transporters, Inc. Iknow the following of my own personal knowledge and if called upon to do so could and would competently testify thereto. BJ Interstate is a licensed transportation broker specializing in arranging for the transportation of automobiles in interstate commerce by licensed motor carriers like Bogdan Dedyk and his \OOONO ccmpany Safe Auto Transport, Inc. Prior to retaining the services of a motor carriepI verify its licensure on the Federal Motor Carrier Administration website. That Website also contains 10 information pertaining to the carrier’s cargo insurance coverage. If a carrier’s insurance has 11 lapsed for any reaggg, insurance companies are required by law to advise the FMCSA, which 12 in tu~rn suspends the cérrief’s licensure. My cofipany fitilié-ed the servicés of Safe Auto 13 .14. Transport fof oVer a year prior to the matters referred to in the first amended complaint and at 15 no time was Safe Auto ever Uninsured‘of Suspended. 16 17 At the time I formed the company Iwas advised by my licensing agent that brokers like BJ 18 Interstate were not required to carry cargo insurance because brokers are not lible for cargo 19 damage. 20 21 In my 19 years in business I was only sued for cargo loss once. That was a small claims case 22 Which was dismissed by the Judge. When I received the plaintiff” s default I contacted a lawyer 23 who was the daughter of a client, Sands Chevrolet. She directed me to a transportation law 24 Phoenix named whb me to specialist in Gary Doyle, in turn advised contact my lawyer in this 25 ‘ ' '' casé, Mr. Attridge. 2.6 27 I normally earn a profit ofbetween $34,000.00 and $38,000.00 a year. There'iésirhply no 28 wayI ever could have paid a judgment of over $126,000.00 plus attorney fees. I do not carry -2- INSERT DOCUMENT TITLE MOTION TO (e.g., STRIKE) cargo insurance on my business because I have been informed that I do not have to. I only maintain a bond Which is required by the FMCSA to ensure that truckers get paid if brokers go bankrupt or close shop Without paying freight charges. 6. When I first contacted Mr. Attridge he assured me that itwas common for these types of cases to be brought by lawyers With littlebackground in transportation law and that normally once Mr. Attridge called those laws to the plaintiff’ scounsel’s attention, the case would be dismissed. 10 7. Had itnot been for MI. Attridge’s willingness to represent me despite my limited ability to 11 my business or declare bankruptcy. pay, I believe that I may have been forced to close 12 I declare under penalty of perjury under the laws of the States of Arizona and California that the 13 14 above is true and correct. Executed at Sun City, Arizona November ,Zj , 2018. 15 16 17 18 %/:44—» 19 Beverly Larson 20 21 22 23 24 25 26_ 27 28 -3- INSERT DOCUIVIENT TITLE MOTION TO (e.g., STRIKE)