Preview
Whitney, Thompson & Jeffcoach LLP
Mandy L. Jeffcoach, #232313
mijeficoach@wtjlaw.com
8050 N. Palm Avenue, Suite 110
Fresno, California 93711 E-FILED
Telephone: (559) 753-2550 2/21/2020 2:36 PM
Facsimile: (559) 753-2560 Superior Court of California
County of Fresno
Attorneys for Defendants, City of Fresno and By: |. Herrera, Deputy
Steve Wallace
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF FRESNO, B. F. SISK COURTHOUSE
10
11 REZA MOHAMMADI AND FARHAN Case No. 16CECG01808
MOHAMMADI (Ist MVA) AND FARHAN
12 MOHAMMADI (2nd MVA), DECLARATION OF MANDY L.
JEFFCOACH RE STATUS OF
13 Plaintiffs, DISMISSAL
14 Vv, Case Status Review Hearing
Date: February 26, 2020
15 LARRY MATTSON (ist MVA), CITY OF Time: 3:30 p.m.
FRESNO AND STEVE WALLACE (2nd Dept.: 402
16 MVA), and Does 1 to 100, inclusive,
Assigned for All Purposes to:
17 Defendants. Hon. Kimberly A. Gaab
18 Action Filed: June 6, 2016
Trial Date: August 12, 2019
19
20 I, Mandy L. Jeffcoach, declare as follows:
21 1 Tam an attorney at law licensed to practice before all Courts of the State of California
22 and before this Court. I am a partner with the law firm of Whitney, Thompson & Jeffcoach LLP,
23 attorneys of record for Defendants, City of Fresno and Steve Wallace (hereafter collectively referred
24 to as the “City”).
25 2. If called as a witness, I would and could competently testify to all facts stated herein
26 from my personal knowledge except where stated upon information and belief and, as to these
27 matters, I am informed and believe them to be true.
28 3 This declaration is submitted to update the Court as to the status of the pending
115.4 05401173.000
DECLARATION OF MANDY L. JEFFCOACH RE STATUS OF DISMISSAL
appeal.
4 The appeal of the above-entitled matter, Fifth District Court of Appeal Case No.
F080055 is still pending. The briefing has not yet been completed.
5 In addition, on or about December 9, 2019, Defendant REZA MOHAMMADI, in
the related matter entitled The City of Fresno and Larry Matson vs. Reza Mohammadi, et al., Fresno
County Superior Court Case No. 19CECG03923, filed his Motion for Stay of Proceedings pending
resolution of the underlying appeal of the within case to the Fifth District Court of Appeal, Case No.
F080055.
6 It is respectfully requested that the Case Status Review Hearing be continued for 180
10 days to allow the appeal to move towards conclusion.
11 I declare under penalty of perjury under the laws of the State of California that the
12 foregoing is true and correct.
13 Executed this 21st day of February, 2020, at Fresno, California.
14
15 mi p00 Cone.
16
17 Mandy L. Jeffcoach
18
19
20
21
22
23
24
25
26
27
28
115.4 05401173.000 2
DECLARATION OF MANDY L. JEFFCOACH RE STATUS OF DISMISSAL
PROOF OF SERVICE
MOHAMMADL, et al. v. MATTSON, et al.
Fresno County Superior Court Case No. 16CECG01808
STATE OF CALIFORNIA, COUNTY OF FRESNO
At the time of service, I was over 18 years of age and not a party to this action. Iam
employed in the County of Fresno, State of California. My business address is 8050 N. Palm
Avenue, Suite 110, Fresno, CA 93711.
On February 21, 2020, I served true copies of the following document(s) described as
DECLARATION OF MANDY L. JEFFCOACH RE STATUS OF DISMISSAL on the
interested parties in this action as follows:
Jeremy M. Dobbins Sean T. O’Rourke, Esq.
P.O. Box 894 Petrie Leath Larrivee & O’Rourke, LLP
Fowler, CA 93625 6051 North Fresno Street, Suite 110
10 Telephone: (559) 306-6580 Fresno, CA 93710
E-mail: jeremy@jeremymdobbins.com Telephone: (559) 498-6522
11 E-mail: sorourke@pllolegal.com
Attorney for Plaintiffs
12 Attorney for Defendant Larry Matson
13 BY MAIL: I enclosed the document(s) in a sealed envelope or package addressed to the
persons at the addresses listed in the Service List and placed the envelope for collection and
14 mailing, following our ordinary business practices. I am readily familiar with the practice of
Whitney, Thompson & Jeffcoach LLP for collecting and processing correspondence for mailing.
1S On the same day that correspondence is placed for collection and mailing, it is deposited in the
ordinary course of business with the United States Postal Service, in a sealed envelope with
16 postage fully prepaid. I am a resident or employed in the county where the mailing occurred. The
envelope was placed in the mail at Fresno, California.
17
I declare under penalty of perjury under the laws of the State of California that the
18 foregoing is true and correct.
19 Executed on February 21, 2020, at Fresno, California.
20
21
22
23
24
25
26
27
28
115.4 05401173.000 3
DECLARATION OF MANDY L. JEFFCOACH RE STATUS OF DISMISSAL
Preview
Whitney, Thompson & Jeffcoach LLP Mandy L. Jeffcoach, #232313 mijeficoach@wtjlaw.com 8050 N. Palm Avenue, Suite 110 Fresno, California 93711 E-FILED Telephone: (559) 753-2550 2/21/2020 2:36 PM Facsimile: (559) 753-2560 Superior Court of California County of Fresno Attorneys for Defendants, City of Fresno and By: |. Herrera, Deputy Steve Wallace SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF FRESNO, B. F. SISK COURTHOUSE 10 11 REZA MOHAMMADI AND FARHAN Case No. 16CECG01808 MOHAMMADI (Ist MVA) AND FARHAN 12 MOHAMMADI (2nd MVA), DECLARATION OF MANDY L. JEFFCOACH RE STATUS OF 13 Plaintiffs, DISMISSAL 14 Vv, Case Status Review Hearing Date: February 26, 2020 15 LARRY MATTSON (ist MVA), CITY OF Time: 3:30 p.m. FRESNO AND STEVE WALLACE (2nd Dept.: 402 16 MVA), and Does 1 to 100, inclusive, Assigned for All Purposes to: 17 Defendants. Hon. Kimberly A. Gaab 18 Action Filed: June 6, 2016 Trial Date: August 12, 2019 19 20 I, Mandy L. Jeffcoach, declare as follows: 21 1 Tam an attorney at law licensed to practice before all Courts of the State of California 22 and before this Court. I am a partner with the law firm of Whitney, Thompson & Jeffcoach LLP, 23 attorneys of record for Defendants, City of Fresno and Steve Wallace (hereafter collectively referred 24 to as the “City”). 25 2. If called as a witness, I would and could competently testify to all facts stated herein 26 from my personal knowledge except where stated upon information and belief and, as to these 27 matters, I am informed and believe them to be true. 28 3 This declaration is submitted to update the Court as to the status of the pending 115.4 05401173.000 DECLARATION OF MANDY L. JEFFCOACH RE STATUS OF DISMISSAL appeal. 4 The appeal of the above-entitled matter, Fifth District Court of Appeal Case No. F080055 is still pending. The briefing has not yet been completed. 5 In addition, on or about December 9, 2019, Defendant REZA MOHAMMADI, in the related matter entitled The City of Fresno and Larry Matson vs. Reza Mohammadi, et al., Fresno County Superior Court Case No. 19CECG03923, filed his Motion for Stay of Proceedings pending resolution of the underlying appeal of the within case to the Fifth District Court of Appeal, Case No. F080055. 6 It is respectfully requested that the Case Status Review Hearing be continued for 180 10 days to allow the appeal to move towards conclusion. 11 I declare under penalty of perjury under the laws of the State of California that the 12 foregoing is true and correct. 13 Executed this 21st day of February, 2020, at Fresno, California. 14 15 mi p00 Cone. 16 17 Mandy L. Jeffcoach 18 19 20 21 22 23 24 25 26 27 28 115.4 05401173.000 2 DECLARATION OF MANDY L. JEFFCOACH RE STATUS OF DISMISSAL PROOF OF SERVICE MOHAMMADL, et al. v. MATTSON, et al. Fresno County Superior Court Case No. 16CECG01808 STATE OF CALIFORNIA, COUNTY OF FRESNO At the time of service, I was over 18 years of age and not a party to this action. Iam employed in the County of Fresno, State of California. My business address is 8050 N. Palm Avenue, Suite 110, Fresno, CA 93711. On February 21, 2020, I served true copies of the following document(s) described as DECLARATION OF MANDY L. JEFFCOACH RE STATUS OF DISMISSAL on the interested parties in this action as follows: Jeremy M. Dobbins Sean T. O’Rourke, Esq. P.O. Box 894 Petrie Leath Larrivee & O’Rourke, LLP Fowler, CA 93625 6051 North Fresno Street, Suite 110 10 Telephone: (559) 306-6580 Fresno, CA 93710 E-mail: jeremy@jeremymdobbins.com Telephone: (559) 498-6522 11 E-mail: sorourke@pllolegal.com Attorney for Plaintiffs 12 Attorney for Defendant Larry Matson 13 BY MAIL: I enclosed the document(s) in a sealed envelope or package addressed to the persons at the addresses listed in the Service List and placed the envelope for collection and 14 mailing, following our ordinary business practices. I am readily familiar with the practice of Whitney, Thompson & Jeffcoach LLP for collecting and processing correspondence for mailing. 1S On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service, in a sealed envelope with 16 postage fully prepaid. I am a resident or employed in the county where the mailing occurred. The envelope was placed in the mail at Fresno, California. 17 I declare under penalty of perjury under the laws of the State of California that the 18 foregoing is true and correct. 19 Executed on February 21, 2020, at Fresno, California. 20 21 22 23 24 25 26 27 28 115.4 05401173.000 3 DECLARATION OF MANDY L. JEFFCOACH RE STATUS OF DISMISSAL