On November 18, 2015 a
Order to Show Cause
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
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JAMES ATTRIDGE [SBN NO. 124003]
ILED
LAW OFFICES OF JAMES ATTRIDGE
10821 West Dumbarton Place SAN MATEO COUNTY
Littleton, CO 80127
Telephone: (415) 846-4477 JUL 01 2019
ee
Email: jattridge@attridgelaw.com
Merion of Points and Authorities in Repl aI the Superior Court
‘Wun
Attorney for Defendant BJ Interstate AK
Auto Transporters, Inc.
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN MATEO
UNLIMITED JURISDICTION
10 ANDY SABERI, an individual
11 Plaintiff, Case No: CIV-536294
12 VS. RESPONSE TO ORDER TO SHOW CAUSE RE:
DISMISSAL OF ENTIRE ACTION
13 LES STANFORD CHEVROLET
CADILLAC, INC. et. al Date: July2, 2019
14 Time: 9 AM
Department 11
15 Defendants. Honorable Joh Grandsaert
16
17
18
On May 20, 2019 Judge Greenberg denied defendant BJ Interstate’s Motion for Sanctions on
19
procedural grounds only: that BJ Interstate had not complied with the 21-day cure rule before filing
20
the motion. BJ Interstate is therefore without prejudice to cure that defect and refile. Plaintiff has set
21
its own sanction motion for the day before this hearing. Should plaintiff's motion be denied, BJ
22
Interstate will set a date outside the 21-day period to have its motion reheard. It therefore requests a
23
sixty day continuance of this hearing.
24
Dated: June 25, 2019
25
26
27
James Attridge, Counsel for BJ Interstate
28
1
TRIAL BRIEF
\
a — — ~
ye?
ae’ We aoecat
4
Proof of Service
I am employed in the County of San Francisco, State of California. I am over the
age of eighteen and am counsel for defendant BJ Interstate Auto Transporters, Inc. My
business address is 270 Divisadero Street, #3 San Francisco, California, 94117 though
my mail is temporarily being forwarded to 10821 West Dumbarton Place, Littleton,
Colorado, 80127. On June 25, 2019 I placed a copy of the Response to Order to Show
Cause to which this proof of service is attached in a two-day overnight delivery envelope
addressed to:
James Dombroski
Law Office of James Dombroski
Post Office Bo 751027
Petaluma, CA 94975
I declare under penalty of perjury under the laws of the States of California and
Colorado that the foregoing is true and correct. Executed at Little 7 lorado, June 25,
2019
[ido|
James Attridge
Document Filed Date
July 01, 2019
Case Filing Date
November 18, 2015
Category
(06) Unlimited Breach of Contract/Warranty
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®¥ JAMES ATTRIDGE [SBN NO. 124003] ILED LAW OFFICES OF JAMES ATTRIDGE 10821 West Dumbarton Place SAN MATEO COUNTY Littleton, CO 80127 Telephone: (415) 846-4477 JUL 01 2019 ee Email: jattridge@attridgelaw.com Merion of Points and Authorities in Repl aI the Superior Court ‘Wun Attorney for Defendant BJ Interstate AK Auto Transporters, Inc. SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN MATEO UNLIMITED JURISDICTION 10 ANDY SABERI, an individual 11 Plaintiff, Case No: CIV-536294 12 VS. RESPONSE TO ORDER TO SHOW CAUSE RE: DISMISSAL OF ENTIRE ACTION 13 LES STANFORD CHEVROLET CADILLAC, INC. et. al Date: July2, 2019 14 Time: 9 AM Department 11 15 Defendants. Honorable Joh Grandsaert 16 17 18 On May 20, 2019 Judge Greenberg denied defendant BJ Interstate’s Motion for Sanctions on 19 procedural grounds only: that BJ Interstate had not complied with the 21-day cure rule before filing 20 the motion. BJ Interstate is therefore without prejudice to cure that defect and refile. Plaintiff has set 21 its own sanction motion for the day before this hearing. Should plaintiff's motion be denied, BJ 22 Interstate will set a date outside the 21-day period to have its motion reheard. It therefore requests a 23 sixty day continuance of this hearing. 24 Dated: June 25, 2019 25 26 27 James Attridge, Counsel for BJ Interstate 28 1 TRIAL BRIEF \ a — — ~ ye? ae’ We aoecat 4 Proof of Service I am employed in the County of San Francisco, State of California. I am over the age of eighteen and am counsel for defendant BJ Interstate Auto Transporters, Inc. My business address is 270 Divisadero Street, #3 San Francisco, California, 94117 though my mail is temporarily being forwarded to 10821 West Dumbarton Place, Littleton, Colorado, 80127. On June 25, 2019 I placed a copy of the Response to Order to Show Cause to which this proof of service is attached in a two-day overnight delivery envelope addressed to: James Dombroski Law Office of James Dombroski Post Office Bo 751027 Petaluma, CA 94975 I declare under penalty of perjury under the laws of the States of California and Colorado that the foregoing is true and correct. Executed at Little 7 lorado, June 25, 2019 [ido| James Attridge