Preview
MICHAEL SHEMTOUB — State Bar No.253948
BEVERLY LAW FIRM
Mailing Address:
4929 Wilshire Blvd., Suite 702
Los Angeles, CA 9001 0
Phone: 3 1 0-552-6959
Fax: 323-421—9397
E—mail: Michael
Attorney for Plaintiff,
DANNY BELL
RECEIVED
2/2/2021 2:59 PM
FRESNO COUNTY SUPERIOR COURT
By: Sam Garcia, Deputy
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 FOR THE COUNTY OF FRESNO
11
DANNY BELL, Case No.2 19CECG02045
UNLIMITED JURISDICTION
Plaintiff,
l3
vs.
14 STIPULATION TO TRANSFER VENUE:
JOHN BAKER, VFS CANADA INC, ISB (PROPOSED) ORDER
15 TRASNPORT LTD and DOES 1 TO 25,
Defendants.
16 Defendant
l7
18
19
Plaintiff DANNY BELL, and specially appearing defendant VFS Canada Inc., and their
undersigned attorneys of record agree and stipulate as follows:
20
l. On June 21, 2017, Plaintiff was involved in an automobile collision in I-5 N/B Golden State
21
Freeway
22
2. The proper venue isLos Angeles County Superior Court. Where the incident arose and based
23 0n information and belief is where the attorneys for Plaintiff and Defendant, the majon'ty of
24 Plaintiff medical treatment providers, and the expert witnesses are located in the vicinities.
25
3. California’s venue rule codified under Code of Civil procedure 395 (a), provides a preference
for a trial in the county of a defendant‘s residence or where the incident arose.
26
27
28
STIPULATION TO TRANSFER VENUE
4. Counsel have met and conferred and based 0n where the alleged incident occurred and the
attorneys for Plaintiff and Defendant, the Parties have stipulated to transfer this action to the
proper venue. In the Parties’ joint interest t0 informally resolve their venue disputes without
Court intervention, the Parties have agreed and stipulate as follows:
This matter should be transferred to Los Angeles County Superior Court.
This stipulation may be signed in counterparts and a facsimile 0r electronic signature shall be as
effective as an original signature.
IT IS SO STIPULATED.
10
DATE: September 1, 2020 BEVERLY LAW
11
12
13
%/Mé
14
By: MICHAEL SHEMTOUB, ESQ
Attorney for Plaintiff, Danny Bell
15
16
DATE: September 1, 2020
‘
17
18
By: PETER DUBRAWSKI, specially appearing for
19 Specially Appearing Defendant, VFS Canada Inc.
20 Badsed 0n the parties' stipulation and good cause appearing, the Court hereby ENTERS the following
0r ers:
21
1. It isordered that the matter of captioned above, Case No.: 19CECG02045, shall be transferred to
Los Angeles County Superior Court.
22
23
IT IS SO ORDERED
DATE: September 1, 2020
24
25
The Honorable
26 JUDGE OF THE SUPERIOR COURT
27
28
STIPULATION TO TRANSFER VENUE
[PROOF OF SERVICE
1013A(3) CCP Revised 5/1/88
STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
Iam employed in the County 0f Los Angeles, State of California. am over the age of 18 and not a party t0
the within action; my business address is:
BEVERLY LAW FIRM
Mailing Address:
4929 Wilshire B1vd., Suite 702
Los Angeles, CA 90010
On September 1, 2020, Iserved and executed at the above address the foregoing document described as
STIPULATION TO TRANSFER TO PROPER VENUE PURSUANT TO CCP §395
10
Peter Dubrawski
ll Haight Brown & Bonesteel LLP
555 South Flower Street, 45- floor
12 Los Angeles CA 90071
pdubrawski@hbblaw.com
13
Attorney for Defendant,
14 VFS Canada, Inc.
15
x BY MAIL
16
x I deposited such envelope in the mail at Los Angeles, California. The envelope was
17
mailed with postage thereon fully prepaid.
18 As follows: I am "readily familiar" with the firm's practice of collection and processing
correspondence for mailing. Under that practice itwould be deposited with U. S. postal
19 o‘n
service that same day with postage thereon fully prepaid at L08 Angeles, California in
20 the ordinary course of business. Iam aware that 0n motion 0f the party served, service is
presumed invalid if postal cancellation date or postage meter date ismore than one day
21
after date of deposit for mailing in affidavit.
22
BY PERSONAL SERVICE
23
24 I delivered such envelope by hand to the addressees at
25
26 BY FACSIMILE
27
28
STIPULATION TO TRANSFER VENUE
Iserved such document(s) by fax at See Service List t0 the fax number provided by each
of the parties inthis litigation at Los Angeles, California. I received a confirmation sheet
indicating said fax was transmitted completely.
X BY E-MAIL (ELECTRONIC TRANSMISSION)
#)_(_ ONLY BY ELECTRONIC TRANSMISSION. Only by e-mailing the document(s) to the persons at
the e-mail address(es). This is necessitated during the declared National Emergency, Local
Emergency and State 0f California emergency due to the Coronavirus (C0vid—19) pandemic
because this office will be working remotely, not able to send physical mail as usual, and is
therefore using only electronic mail. No electronic message 0r other indication that the
transmission was unsuccessful was received within a reasonable time after the transmission. We
will provide a physical copy, upon request only, when we return t0 the office at the conclusion of
10 the national emergency.
11
I declare under penalty 0f perj ury under the laws of the State 0f California that the above is true and
12 correct.
13
/s/Martha Valencia
l4
Martha Valencia
15
16
17
18
l9
20
21
22
23
24
25
26
27
28
STIPULATION TO TRANSFER VENUE
Preview
MICHAEL SHEMTOUB — State Bar No.253948 BEVERLY LAW FIRM Mailing Address: 4929 Wilshire Blvd., Suite 702 Los Angeles, CA 9001 0 Phone: 3 1 0-552-6959 Fax: 323-421—9397 E—mail: Michael Attorney for Plaintiff, DANNY BELL RECEIVED 2/2/2021 2:59 PM FRESNO COUNTY SUPERIOR COURT By: Sam Garcia, Deputy SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 FOR THE COUNTY OF FRESNO 11 DANNY BELL, Case No.2 19CECG02045 UNLIMITED JURISDICTION Plaintiff, l3 vs. 14 STIPULATION TO TRANSFER VENUE: JOHN BAKER, VFS CANADA INC, ISB (PROPOSED) ORDER 15 TRASNPORT LTD and DOES 1 TO 25, Defendants. 16 Defendant l7 18 19 Plaintiff DANNY BELL, and specially appearing defendant VFS Canada Inc., and their undersigned attorneys of record agree and stipulate as follows: 20 l. On June 21, 2017, Plaintiff was involved in an automobile collision in I-5 N/B Golden State 21 Freeway 22 2. The proper venue isLos Angeles County Superior Court. Where the incident arose and based 23 0n information and belief is where the attorneys for Plaintiff and Defendant, the majon'ty of 24 Plaintiff medical treatment providers, and the expert witnesses are located in the vicinities. 25 3. California’s venue rule codified under Code of Civil procedure 395 (a), provides a preference for a trial in the county of a defendant‘s residence or where the incident arose. 26 27 28 STIPULATION TO TRANSFER VENUE 4. Counsel have met and conferred and based 0n where the alleged incident occurred and the attorneys for Plaintiff and Defendant, the Parties have stipulated to transfer this action to the proper venue. In the Parties’ joint interest t0 informally resolve their venue disputes without Court intervention, the Parties have agreed and stipulate as follows: This matter should be transferred to Los Angeles County Superior Court. This stipulation may be signed in counterparts and a facsimile 0r electronic signature shall be as effective as an original signature. IT IS SO STIPULATED. 10 DATE: September 1, 2020 BEVERLY LAW 11 12 13 %/Mé 14 By: MICHAEL SHEMTOUB, ESQ Attorney for Plaintiff, Danny Bell 15 16 DATE: September 1, 2020 ‘ 17 18 By: PETER DUBRAWSKI, specially appearing for 19 Specially Appearing Defendant, VFS Canada Inc. 20 Badsed 0n the parties' stipulation and good cause appearing, the Court hereby ENTERS the following 0r ers: 21 1. It isordered that the matter of captioned above, Case No.: 19CECG02045, shall be transferred to Los Angeles County Superior Court. 22 23 IT IS SO ORDERED DATE: September 1, 2020 24 25 The Honorable 26 JUDGE OF THE SUPERIOR COURT 27 28 STIPULATION TO TRANSFER VENUE [PROOF OF SERVICE 1013A(3) CCP Revised 5/1/88 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES Iam employed in the County 0f Los Angeles, State of California. am over the age of 18 and not a party t0 the within action; my business address is: BEVERLY LAW FIRM Mailing Address: 4929 Wilshire B1vd., Suite 702 Los Angeles, CA 90010 On September 1, 2020, Iserved and executed at the above address the foregoing document described as STIPULATION TO TRANSFER TO PROPER VENUE PURSUANT TO CCP §395 10 Peter Dubrawski ll Haight Brown & Bonesteel LLP 555 South Flower Street, 45- floor 12 Los Angeles CA 90071 pdubrawski@hbblaw.com 13 Attorney for Defendant, 14 VFS Canada, Inc. 15 x BY MAIL 16 x I deposited such envelope in the mail at Los Angeles, California. The envelope was 17 mailed with postage thereon fully prepaid. 18 As follows: I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. Under that practice itwould be deposited with U. S. postal 19 o‘n service that same day with postage thereon fully prepaid at L08 Angeles, California in 20 the ordinary course of business. Iam aware that 0n motion 0f the party served, service is presumed invalid if postal cancellation date or postage meter date ismore than one day 21 after date of deposit for mailing in affidavit. 22 BY PERSONAL SERVICE 23 24 I delivered such envelope by hand to the addressees at 25 26 BY FACSIMILE 27 28 STIPULATION TO TRANSFER VENUE Iserved such document(s) by fax at See Service List t0 the fax number provided by each of the parties inthis litigation at Los Angeles, California. I received a confirmation sheet indicating said fax was transmitted completely. X BY E-MAIL (ELECTRONIC TRANSMISSION) #)_(_ ONLY BY ELECTRONIC TRANSMISSION. Only by e-mailing the document(s) to the persons at the e-mail address(es). This is necessitated during the declared National Emergency, Local Emergency and State 0f California emergency due to the Coronavirus (C0vid—19) pandemic because this office will be working remotely, not able to send physical mail as usual, and is therefore using only electronic mail. No electronic message 0r other indication that the transmission was unsuccessful was received within a reasonable time after the transmission. We will provide a physical copy, upon request only, when we return t0 the office at the conclusion of 10 the national emergency. 11 I declare under penalty 0f perj ury under the laws of the State 0f California that the above is true and 12 correct. 13 /s/Martha Valencia l4 Martha Valencia 15 16 17 18 l9 20 21 22 23 24 25 26 27 28 STIPULATION TO TRANSFER VENUE