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THE BIERNAT LAW GROUP gPLKQ Cog@i
JAMES D. BIERNAT (SBN: 75839)
2 VICKY W. CHAN (SBN: 226923)
gpss g2 2013
1633 Bayshore Hwy, suite 133
Burlingame, CA 94010
4 Tel: (650) 689-5160
Fax: (650) 689-5587
5 -nitwit~'ttorneys
for Defendants
SOHYL MAHALLATI,individually and dba ARCH CONSTRUCTION,
7 [Erroneously sued herein as SAYL MAHALLATIand ARCH CONSTRUCTION]
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN MATEO
10
11
MONTGOMERY SANSOME, LP, LEONARD A. Case No.: CIV508839
NORDEMAN,
NOTICE OF ENTRY OF ORDER
13
Plaintiffs,
14 MOTION FOR JUDGMENT NOTWITHSTANDING
vs THE VERDICT
15
ARCH CONSTRUCTION, SAYL MAHALLATI, DATE: February 8, 2013
NASSER MAHALLATI,and DOES 1through TIME: 2:00 p.m.
17 100; DEPT: 10
JUDGE: Hon. Gerald J. Buchwald
18 Defendants.
19
TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:
20
21
PLEASE TAKE NOTICE of the court's entry of an Order on the MOTION FOR JUDGMENT
NOTWITHSTANDING THE VERDICT. A copy of the Order is attached hereto and made a part
hereof.
23
24 Dated: February 4, 2013 THE BIERNAT LAW GROUP
25
26 e,
IES D BIERNAT
27 I CYW. CHAN
HYL MAHALLATI,individually and dba ARCH
28
CONSTRUCTION
NOTICE OF ENTRY OF ORDER - JUDGMENT NOTWITHSTANDINGTHE VERDICT
MORI~I
1 THE BIERNAT LAWGRQU
JAMES D. BIERNAT (SB 859)
f 8 04 2033
VICKYW. CHAN (SBN 25)
H,p 155 ~csnc~D~QASED I'IILED
1655 Bayshore
Burllngame, CA $ 0. SAN MATEO u IUNIY
4 Tel: (650) 689-
FNc 587
FEB 1 5 2)l3
(650)
Cerk of the rl ar Gewt
Attorn r Defendants IIy Patrlce Del Nla
OEPNY CLII IK
SOHYL Tl, Indlvtdually and dba ARCH CONSTRUCTION,
usly sued herein as SAYL MAHALLATland ARCH CONSTRUCllON)
IN THE SUPERIOR COURT OF THE STATE OF CAUFORNIA
10 IN AND FOR THE COUNTY OF SAN MATEO
11
MONTGOMERYSANSOME, LP, LEONARD A. Case No.: CIV508859
NORDEMAN,
13 [PROPOSED) ORDER DENYING MOTION FOR
PlafntNs, JUDGMENT NOTWITHSTANDINGTHE
14
VERDICT
DATE: Februaryg,'201$
ARCH CONSTRUCTION, SAYL MAHALLATI, TIME: 2'.00 p.m.
NASSER MAHALLATI,and DOES 1through DEPT: 10
100; JUDGE: Hon. Gerald J. Buchwald
18
BY FAX
20 The motion of plalntlff for judgment ndlng the verdict came on regularly gaol
I
21 hearing before this Court on February p'013. The parties were represented as follows:
22 PlalntlflsMontgomery Sensome, LP and Leonard A. Nordeman were represented by Tracy N.
25 Tumlln; defendant SOHYL MAHALLATI lndlvldually and dba ARCH CONSTRUCllON was
24 represented by James D. Blernat of the Blernat Law Group.
25 Good cause appearing, IT IS ORDERED THATthe motion is DENIED.
26
21
A.;=====~
MDGE OF TIKSUPERIOR COURT
IPA ADEA OENvlNG MolloN Foa JUDBMENT NolvvtTNsrANOINGTHE VEADcr
PROOF OF SERVICE
2 I, Melissa M. Smith, declare:
3 I am over the age of 18 years and not a party to the within action; I am employed In the
4 County of San Mateo, State of California and my business address is 1633 Bayshore Hwy, Suite
133, Burllngame, California, 94010. On the date entered below, I served the following
documents;
P%OPOSEO) OROER OENYING NOTION FOR jUOGMENT NOTWITHSTANDINGTHE VEROICT
8
f) By Mall (C.C.P. 51013A 4 2015.5): I placed a true and correct copy of the foregol ng
9 document, address to the following party(les) listed below or on the Service Ust, ln a
sealed envelope, and following ordinary business practices, placing the envelope for
10
mailing and collection in The Biernat Law Group In the appropriate place for mall
collected for deposit with the United States Postal Service in the City of Burlingame,
California.
By Express, Overnight Mall: I placed a true copy of the aforementioned document In
a sealed envelope provided by an overnight delivery carrier and addressed to the
14 persons at the addresses listed. I placed the envelope or package for collection and
overnight delivery at an oNce or a regularly utilized drop box of the overnight delivery
carrleI'.
16 Tracy N. Tumlin
331 Arguello Blvd
17
San Frandsco, CA 94118
(808) 345-7192
Leonard Nordeman Nontgomery
Sansome
Idedare under penalty of perjury in accordance with the laws of the State of California
that the foregoing Is true and correct, and that this document was executed at Burlingame,
California, on February 4, 2013.
24
25
26
27
28
II%0 oRDER DENYING MoTIoN FoR JUDGMENT N07wITHSTANDINGTNE VERDIcr
PROOF OF SERVICE
2 I,Melissa M. Smith, declare:
3 Iam over the age of 18 years and not a party to the within action; Iam employed in the
4 County of San Mateo, State of California and my business address is 1633 Bayshore Hwy, Suite
133, Burlingame, California, 94010. On the date entered below, I served the following
documents;
NOTICE OF ENTRY OF ORDER - MOTION FOR jUDGMENT NOTWITHSTANDINGTHE VERDICT
[X] By Mail [C.C.P. 5101$ A & 2015.5]: Iplaced a true and correct copy of the foregoing
document, address to the following party(ies) listed below or on the Service List,in a
sealed envelope, and following ordinary business practices, placing the envelope for
10
mailing and collection in The Biernat Law Group in the appropriate place for mail
collected for deposit with the United States Postal Service in the City of Burlingame,
California.
12
13
[] By Express, Overnight Mail: I placed a true copy of the aforementioned document in
'4
a sealed envelope provided by an overnight delivery carrier and addressed to the
persons at the addresses listed. Iplaced the envelope or package for collection and
overnight delivery at an office or a regularly utilized drop box of the overnight delivery
15 carrier.
Tracy N. Tumlin
331 Arguello Blvd
San Francisco, CA 94118
18 (808) 345-7192
Leonard Nordeman & Montgomery
Sansome
20 I declare under penalty of perjury in accordance with the laws of the State of California
that the foregoing is true and correct, and that this document was executed at Burlingame,
r~
California, on February 20, 2013.
23
24
25
26
27
~ %lilith
28
NOTICE OF ENTRY OF ORDER - JUDGMENT NOTWITHSTANDINGTHE VERDICT
Preview
THE BIERNAT LAW GROUP gPLKQ Cog@i JAMES D. BIERNAT (SBN: 75839) 2 VICKY W. CHAN (SBN: 226923) gpss g2 2013 1633 Bayshore Hwy, suite 133 Burlingame, CA 94010 4 Tel: (650) 689-5160 Fax: (650) 689-5587 5 -nitwit~'ttorneys for Defendants SOHYL MAHALLATI,individually and dba ARCH CONSTRUCTION, 7 [Erroneously sued herein as SAYL MAHALLATIand ARCH CONSTRUCTION] IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN MATEO 10 11 MONTGOMERY SANSOME, LP, LEONARD A. Case No.: CIV508839 NORDEMAN, NOTICE OF ENTRY OF ORDER 13 Plaintiffs, 14 MOTION FOR JUDGMENT NOTWITHSTANDING vs THE VERDICT 15 ARCH CONSTRUCTION, SAYL MAHALLATI, DATE: February 8, 2013 NASSER MAHALLATI,and DOES 1through TIME: 2:00 p.m. 17 100; DEPT: 10 JUDGE: Hon. Gerald J. Buchwald 18 Defendants. 19 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD: 20 21 PLEASE TAKE NOTICE of the court's entry of an Order on the MOTION FOR JUDGMENT NOTWITHSTANDING THE VERDICT. A copy of the Order is attached hereto and made a part hereof. 23 24 Dated: February 4, 2013 THE BIERNAT LAW GROUP 25 26 e, IES D BIERNAT 27 I CYW. CHAN HYL MAHALLATI,individually and dba ARCH 28 CONSTRUCTION NOTICE OF ENTRY OF ORDER - JUDGMENT NOTWITHSTANDINGTHE VERDICT MORI~I 1 THE BIERNAT LAWGRQU JAMES D. BIERNAT (SB 859) f 8 04 2033 VICKYW. CHAN (SBN 25) H,p 155 ~csnc~D~QASED I'IILED 1655 Bayshore Burllngame, CA $ 0. SAN MATEO u IUNIY 4 Tel: (650) 689- FNc 587 FEB 1 5 2)l3 (650) Cerk of the rl ar Gewt Attorn r Defendants IIy Patrlce Del Nla OEPNY CLII IK SOHYL Tl, Indlvtdually and dba ARCH CONSTRUCTION, usly sued herein as SAYL MAHALLATland ARCH CONSTRUCllON) IN THE SUPERIOR COURT OF THE STATE OF CAUFORNIA 10 IN AND FOR THE COUNTY OF SAN MATEO 11 MONTGOMERYSANSOME, LP, LEONARD A. Case No.: CIV508859 NORDEMAN, 13 [PROPOSED) ORDER DENYING MOTION FOR PlafntNs, JUDGMENT NOTWITHSTANDINGTHE 14 VERDICT DATE: Februaryg,'201$ ARCH CONSTRUCTION, SAYL MAHALLATI, TIME: 2'.00 p.m. NASSER MAHALLATI,and DOES 1through DEPT: 10 100; JUDGE: Hon. Gerald J. Buchwald 18 BY FAX 20 The motion of plalntlff for judgment ndlng the verdict came on regularly gaol I 21 hearing before this Court on February p'013. The parties were represented as follows: 22 PlalntlflsMontgomery Sensome, LP and Leonard A. Nordeman were represented by Tracy N. 25 Tumlln; defendant SOHYL MAHALLATI lndlvldually and dba ARCH CONSTRUCllON was 24 represented by James D. Blernat of the Blernat Law Group. 25 Good cause appearing, IT IS ORDERED THATthe motion is DENIED. 26 21 A.;=====~ MDGE OF TIKSUPERIOR COURT IPA ADEA OENvlNG MolloN Foa JUDBMENT NolvvtTNsrANOINGTHE VEADcr PROOF OF SERVICE 2 I, Melissa M. Smith, declare: 3 I am over the age of 18 years and not a party to the within action; I am employed In the 4 County of San Mateo, State of California and my business address is 1633 Bayshore Hwy, Suite 133, Burllngame, California, 94010. On the date entered below, I served the following documents; P%OPOSEO) OROER OENYING NOTION FOR jUOGMENT NOTWITHSTANDINGTHE VEROICT 8 f) By Mall (C.C.P. 51013A 4 2015.5): I placed a true and correct copy of the foregol ng 9 document, address to the following party(les) listed below or on the Service Ust, ln a sealed envelope, and following ordinary business practices, placing the envelope for 10 mailing and collection in The Biernat Law Group In the appropriate place for mall collected for deposit with the United States Postal Service in the City of Burlingame, California. By Express, Overnight Mall: I placed a true copy of the aforementioned document In a sealed envelope provided by an overnight delivery carrier and addressed to the 14 persons at the addresses listed. I placed the envelope or package for collection and overnight delivery at an oNce or a regularly utilized drop box of the overnight delivery carrleI'. 16 Tracy N. Tumlin 331 Arguello Blvd 17 San Frandsco, CA 94118 (808) 345-7192 Leonard Nordeman Nontgomery Sansome Idedare under penalty of perjury in accordance with the laws of the State of California that the foregoing Is true and correct, and that this document was executed at Burlingame, California, on February 4, 2013. 24 25 26 27 28 II%0 oRDER DENYING MoTIoN FoR JUDGMENT N07wITHSTANDINGTNE VERDIcr PROOF OF SERVICE 2 I,Melissa M. Smith, declare: 3 Iam over the age of 18 years and not a party to the within action; Iam employed in the 4 County of San Mateo, State of California and my business address is 1633 Bayshore Hwy, Suite 133, Burlingame, California, 94010. On the date entered below, I served the following documents; NOTICE OF ENTRY OF ORDER - MOTION FOR jUDGMENT NOTWITHSTANDINGTHE VERDICT [X] By Mail [C.C.P. 5101$ A & 2015.5]: Iplaced a true and correct copy of the foregoing document, address to the following party(ies) listed below or on the Service List,in a sealed envelope, and following ordinary business practices, placing the envelope for 10 mailing and collection in The Biernat Law Group in the appropriate place for mail collected for deposit with the United States Postal Service in the City of Burlingame, California. 12 13 [] By Express, Overnight Mail: I placed a true copy of the aforementioned document in '4 a sealed envelope provided by an overnight delivery carrier and addressed to the persons at the addresses listed. Iplaced the envelope or package for collection and overnight delivery at an office or a regularly utilized drop box of the overnight delivery 15 carrier. Tracy N. Tumlin 331 Arguello Blvd San Francisco, CA 94118 18 (808) 345-7192 Leonard Nordeman & Montgomery Sansome 20 I declare under penalty of perjury in accordance with the laws of the State of California that the foregoing is true and correct, and that this document was executed at Burlingame, r~ California, on February 20, 2013. 23 24 25 26 27 ~ %lilith 28 NOTICE OF ENTRY OF ORDER - JUDGMENT NOTWITHSTANDINGTHE VERDICT