Preview
Jeremy M. Dobbins, Esq. (SBN 320648)
Law ffice of Jeremy M. Dol ins E-FILED
1225 E. Divisadero, hird Floor
Fresno, California 93721 9/13/2021 8:00 AM
Telephone No.: (559) 306-6580 Superior Court of California
Facsimile No.: (559) 316-4070 County of Fresno
Email: jeremy@jeremydobbins.com By: C. York, Deputy
Attomey for Plaintiff, REZA MOHAMMADI
SUPERIOR COURT OF CALIFORNIA
COUNTY OF FRESNO
10
11 REZA MOHAMMADI and FARHAN Case Number: 16C ECG01808
MOHAMMADI [1% MVA]; REZA
12 MOHAMMAD! [2 MVA]; PLAINTIFF’S REQUEST FOR J UDICIAL
NOTICE
13 Plaintiffs,
14 Vv. Action Filed: June 6, 2016
Trial Date: September 13, 2021
15 LARRY MATTSON [1% MVA]; CITY OF
FRESNO and STEVE WALLACE [2"¢
16 MVA\] and DOES 1 through 100, inclusive.
17
Defendants.
18 TO THE HONORABLE COURT:
19
PLAINTIFF REZA MOHAMMADLI, under the provisions of Evidence Code §§451, 452,
20
and 453 requests that the court take judicial notice of the following:
21
22 (1) The plaintiffs third amended complaint filed in the Superior Court of California,
23 County of Fresno, in this action as the only operative pleading in this action. A true
24
and correct copy of the third amended complaint is attached as Exhibit A.
25
(2) The Docket in this case, printed on September 3, 2021, a true and correct copy of
26
27 which is attached as Exhibit B.
28 Relevant rules regarding Cross Complaints in California are as follows:
1
PLAINTIFF’S REQUEST FOR JUDICIAL NOTICE
CCP 428.10: A party against whom a cause of action has been
asserted in a complaint or cross-complaint may file a cross-
complaint setting forth either or both of the following:
(a) Any cause of action he has against any of the parties who filed
the complaint or cross-complaint against him....
(b) Any cause of action he has against a person alleged to be liable
thereon, whether or not such person is already a party to the action,
if the cause of action asserted in his cross-complaint (1) arises out
of the same transaction, occurrence, or series of transactions or
occurrences as the cause brought against him or (2) asserts a claim,
right, or interest in the property or controversy which is the subject
of the cause brought against him.
CCP 428.20: When a person files a cross-complaint as authorized
by Section 428.10, he may join any person as a cross-complainant
10 or cross-defendant, whether or not such person is already a party to
11 the action, if, had the cross-complaint been filed as an independent
action, the joinder of that party would have
12 been permitted by the statutes governing joinder of parties.
13 CCP 428.50: (a) A party shall file a cross-complaint against any of
14 the parties who filed the complaint or cross-complaint against him
or her before or at the same time as the answer to the complaint or
15 cross-complaint.
(b) Any other cross-complaint may be filed at any time before the
16
court has set a date for trial.
17 (c) A party shall obtain leave of court to file any cross-complaint
except one filed within the time specified in subdivision (a) (b)
18 Leave may be granted in the interest of justice at any time during
the course of the action.
19
Evid Code §452(d) provides that judicial notice may be taken of “[rJecords of (1) any
20
3|2
sla
3|9 21 court of this state or (2) any court of record of the United States or of any state of the United
qa
22 States.” Evidence Code §453 provides that “[t]he trial court shall take judicial notice of any
23 matter specified in §452 if a party requests it and: (a) [g]ives each adverse party sufficient notice
24
of the request, through the pleadings or otherwise, to enable such adverse party to prepare to meet
25
the request; and (b) [fJurnishes the court with sufficient information to enable it to take judicial
26
27 notice of the matter.”
28
2
PLAINTIFF’S REQUEST FOR JUDICIAL NOTICE
The attached operative pleading (See Exhibit A) and the entire docket (See Exhibit B) are
records of the Superior Court of California, County of Fresno, and are therefore judicially
noticeable under Evid Code §452(d).
The Exhibits are relevant to this action as the defendants A nswer, in its Sixth Affirmative
Defense, “...alleges that the matter complained of in plaintiff's complaint and the causes of action
therein, were solely caused by the actions or omissions of a third-party, or parties, other than this
answering defendant.” The sole operative complaint and the entire docket are relevant because
they demonstrate that the only operative complaint in this matter is the Third A mended Complaint
10
11 filed by the plaintiff. Defendants, as they are aware, had ample time to file a cross-complaint
12 against former co-defendant, Larry Matson, and the drivers of vehicles in former accidents where
13 plaintiff was a party in 2010 and 2014, but never did file said cross-complaint. But have from the
14
beginning of the suit blamed Matson and the other prior accidents for plaintiff’s injuries.
15
The Exhibits are further relevant to this action as the defendants Answer, in their Eighth
16
17 Affirmative Defense, “...alleges any non-economic damages sustained by plaintiff in this action
18 were due to the fault of someone other than CITY...” The sole operative complaint and the entire
19
docket are relevant because they demonstrate that the only operative complaint in this matter is
20
3|2 the Third Amended Complaint filed by the plaintiff. Defendants, as they are aware, had ample
sla
3|9 21
22
time to file a cross-complaint against former co-defendant, Larry Matson and the drivers of
qa
23 vehicles in former accidents where plaintiff was a party in 2010 and 2014, but never did file said
24 cross-complaint. But have from the beginning of the suit blamed Matson and the other prior
25
accidents for plaintiff’s injuries.
26
The Exhibits are further relevant to this action as the defendants A nswer, in their Fifteenth
27
28 Affirmative Defense, “...alleges the matter complained of in plaintiffs complaint and the causes
3
PLAINTIFF’S REQUEST FOR JUDICIAL NOTICE
of action therein, were caused by the actions or omissions of an indispensable third-party, or
parties, who have not been named as defendants in plaintiffs complaint, and whose interests are
so involved such that the court cannot render judgment in their absence.” The sole operative
complaint and the entire docket are relevant because they demonstrate that the only operative
complaint in this matter is the Third Amended Complaint filed by the plaintiff. Defendants, as
they are aware, had ample time to file a cross-complaint against former co-defendant, Larry
Matson and the drivers of vehicles in former accidents where plaintiff was a party in 2010 and
2014, but never did file said cross-complaint. But have from the beginning of the suit blamed
10
11 Matson and the other prior accidents for plaintiff’s injuries.
Y
12
13 Dated: September 9, 2021. By ~--- =
14 Jeremy M. Dobbins, Esq.
Attomey for Plaintiff,
15 REZA MOHAMMADI
16
17
18
19
20
3|2
sla
3|9 21
qa
22
23
24
25
26
27
28
4
PLAINTIFF’S REQUEST FOR JUDICIAL NOTICE
EXHIBITA
PLD-PI-001
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): ‘FOR COURT USE ONLY
| Rodney C. Haron, Attorney at aw 061423
A Professional Corporation E-FILED
1617 W. Shaw Ave. Ste B
Fresno, CA 93711 11/2/2017 4:45 PM
Fresno, CA 93711 FRESNO COUNTY
By:
SUPERIOR
. Garcia, Depul
COURT
‘TELEPHONE NO; (559) 441-1421 FAX NO. {Optional}: (559) 441-1911
E-MAIL ADDRESS (Optional): Sonya@rodharonlaw.com
ATTORNEY FOR (Name): Plaintiff
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Fresno
STREETADDRESS: 1130 O Street
maine appress: Unlimited Civil
cry and zip cope: Fresno, CA 93722
brancuname: Central Division
PLAINTIFF: Reza Mohammadi and Farhan Mohammadi (1st MVA),
Reza Mohammadi (2nd MVA)
DEFENDANT: Larry Mattson (1st MVA), City of Fresno and
Steve Wallace (2nd MVA)
(c] Does 1 To 100
COMPLAINT—Personal Injury, Property Damage, Wrongful Death
Lac] AMENDED (Number): THI
Type (check ail that apply):
[3c] MOTOR VEHICLE OTHER (specify): General Negligence
{x] Property Damage (_) Wrongful Death
(&x] Personal Injury [x] Other Damages (specify): Economic and
Noneconomic Damages
Jurisdiction (check ail that apply):
[1 ACTION IS A LIMITED CIVIL CASE CASE NUMBER:
Amount demanded does not exceed $10,000
exceeds $10,000, but does not exceed $25,000 16CECG01808
Gel ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000)
(J ACTION IS RECLASSIFIED by this amended complaint
from limited to unlimited
from unlimited to limited
Plaintiff
(name or names):‘Reza Mohammadi and Farhan Mohammadi (1st MVA), Reza Mohammad
(2nd MVA
alleges causes of action against defendant (name ornames): Larry Mattson (1st MVA) and City of Fresno
and Steve Wallace (2nd MVA
This pleading, including attachments and exhibits, consists of the following number of pages: Five
Each plaintiff named above is a competent adult
a. Co except plaintiff (name):
(1) [__] a corporation qualified to do business in Califomia
(2) [__] an unincorporated entity (describe):
(3) [__] apublic entity (describe):
(4) [] aminor an adult
(a) [] for whom a guardian or conservator of the estate or a guardian ad litem has been appointed
(b) [J other (specify):
(5) [£_] other (specify):
[_] except plaintiff (name):
(1y a corporation qualified to do business in California
(2) an unincorporated entity (describe):
(3) [) a public entity (describe):
(4) C_]_aminor an adult
(@) [_] for whom a guardian or conservator of the estate or a guardian ad litem has been appointed
(b) [J other (specify):
©) (_] other (specify):
[1] Information about additional plaintiffs who are not competent adults is shown in Attachment 3.
Page1 of3
Form Approved for Optional Use COMPLAINT—Personal Injury, Pro,perty sot : Code
of Civil Procedure,
§ 425.12
Judicial Council af California
PLD-P!-001 [Rev. January1. 2007} Damage, Wrongful Death
PLD-PI-004
SHORT TITLE: Mohammadi v Matson (CASE NUMBER:
16CECG01808
4 Cc] Plaintiff (name):
is doing business under the fictitious name (specify):
and has complied with the fictitious business name laws.
5. Each defendant named above is a natural person
except defendant (name): c. [__] except defendant (name):
(1) [_] a business organization, form unknown (1) [_] a business organization, form unknown
(2) [_] acorporation (2) [_) a corporation
(3) [_) an unincorporated entity (describe): (3) [_] an unincorporated entity (describe):
(4) [<] a public entity (describe): City of Fresno (4) (__] a public entity (describe):
(8) [1 other (specify): (5) [_] other (specify):
[1 except defendant (name): [_] except defendant (name):
(1) [J] a business organization, form unknown (1) (_] a business organization, form unknown
(2) (_] acorporation Q) @ corporation
(3) [__] an unincorporated entity (describe): (3) [] an unincorporated entity (describe):
(4) [_] a public entity (describe): (4) [1] a public entity (describe):
(©) [J other (specify): (©) [J other (specify):
{__Jinformation about additional defendants who ave not natural persons is contained in Attachment 5.
The true names of defendants sued as Does are unknown to plaintiff.
a. Doe defendants (specify Doe numbers): 1-100 were the agents or employees of other
named defendants and acted within the scope of that agency or employment.
b. LX] Doe defendants (specify Doe numbers): 1-100 are persons whose capacities are unknown to
plaintiff.
[__] Defendants who are joined under Code of Civil Procedure section 382 are (names):
This court is the proper court because
a. at least one defendant now resides in its jurisdictional area.
b, [] the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area.
¢. [c] injury to person or damage to personal property occurred in its jurisdictional area.
d. (J other (specify):
intiff is required to comply with a claims statute, and
a. has complied with applicable claims statutes, or
bE] Is excused from complying because (specify):
PLD-P/-001 (Rev. January 1, 2007]
COMPLAINT—Personal Injury, Property Page 2.0f3
Damage, Wrongful Death
PLD-P1-004
SHORT TITLE: Mohammadi v Matson ‘CASE NUMBER:
16CECGO1808
10. The following causes of action are attached and the statements above apply to each (each complaint must have one or more
causes of action attached).
Motor Vehicle
b. Ex] General Negligence
« LJ Intentional Tort
aC Products Liability
e LJ Premises Liability
Other (specify)
1 Plaintiff has suffered
wage loss
b. Ge] loss of use of property
hospital and medical expenses
general damage
e. Ex] property damage
loss of earning capacity
other damage (specify); Other economic and noneconomic damages known and unknown
‘to plaintiff at this time, but subject to proof at time of trial Attorney
fees pursuant to statute.
12. f{_] The damages claimed for wrongful death and the relationships of plaintiff to the deceased are
a. [__] listed in Attachment
12.
b.(—_] as follows:
13. The relief sought in this complaint is within the jurisdiction of this court.
14, Plaintiff prays for judgment
for costs of suit; for such relief as is fair, just, and equitable; and for
a. (1) Le] compensatory damages
(2) [_] punitive damages
The amount of damages is (in cases for personal injury or wrongful death, you must check (1):
(1) according to proof
(2) [_] inthe amount of: $
15, [x] The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers).
All
Date: November O02 2017
(TYPE OR PRINT NAME)
PLD-PLOO1 [Rev. January1, 2007]
061423
bRebowg—C Hanon By
COMPLAINT—Personal Injury, Property Page
3 of 3
Damage, Wrongful Death
PLD-PI-001(1)
SHORT TITLE: Mohammadi v Matson CASE NUMBER:
16CECG01808
Firs CAUSE OF ACTION—Motor Vehicle
(number}
ATTACHMENT TO [x] Complaint [_] Cross - Complaint
(Use a separate cause of action form for each cause of action.)
Plaintiff (name): Reza Mohammadi and Farhan Mohammadi (1st MVA), Reza Mohammadi (2nd MVA)
MV-1. Plaintiff alleges the acts of defendants were negligent; the acts were the legal (proximate) cause of injuries
and damages to plaintiff, the acts occurred
on (date): 08/08/2015 (1st MVA) and 11/09/2015 (2nd MVA)
at (place): The Ist MVA occurred on Villa Avenue in the City of Clovis, County of Fresno. Larry
Matson caused the collision by violating Vehicle Code 22107, making an unsafe turning movement.
Defendant crashed into Plaintiff's vehicle. The 2nd MVA occurred at or near the intersection of SR-41
Southbound and 1 mile North of FRe R 29.469, in the City of Fresno, County of Fresno. Defendant Steve
Wallace crashed into Plaintiff Reza Mohammadi's vehicle as a result of his unsafe speed, a violation of Vehicle
Code 22350.
Mv-2, DEFENDANTS
a. Lx_] The defendants who operated a motor vehicle are (names): L: Matson and Steve Wallace and any
eren its own to plaintiff at this time. Plaintiff prays to amend this complaint when
their identities become available.
[x] Does 1 to 20
b. [¢ ] The defendants who employed the persons who operated a motor vehicle in the course of their employment
are (names): Steve Wallace was em, loyed by the City of Fresno at the time of the MVA; am
rf
other defendants are unknown to P| aintiffs at this time. Plaintiffs pray to amend this complaint
when their identities become known.
Does 21 to 30
c. LX ] The defendants who owned the motor vehicle which was operated with their permission are (names):
Unknown to plaintiffs at this time. Plaintiffs pray to amend this complaint when their identities become
known.
Does 31 to 45
The defendants who entrusted the motor vehicle are (names): Unknown to plaintiffs at this time, but
plaintiff prays to amend this complaint when their identities become known.
Cx] Does 46 to 60
e. Lx |The defendants who were the agents and employees of the other defendants and acted within the scope
of the agency were (names): Steve Wallace was employed by the City of Fresno at the time of the
MVA; any other defendants are unknown to Plaintiffs at this time. Plaintiffs pray to amend this
complaint when their identities become known.
[x] Does 61 to BO
f Cz The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are
[J listed in Attachment MV-2f [Lc Jas follows:
Larry Matson for the Ist MVA on 08/08/2015; the City of Fresno and Steve Wallace for the
2nd MVA on 11/09/2015. Plaintiffs pray to amend this complaint when more defendants are
indentified and become known to Plaintiffs.
[x] Does 81 to 100
Form Approved for Optional Use Page1 of?
Judicial Council of California CAUSE OF ACTION—Motor Vehicle Code of Civil Procedura 425.12
PLO-PI-001(1) [Rev. January 1, 2007]
PLD-PI-001(2)
SHORT TITLE: Mohammadi v Mattson CASE NUMBER:
16CECG01808
Second CAUSE OF ACTION—General Negligence Page Five
(number)
ATTACHMENT TO [x] Complaint [—] Cross
- Complaint
(Use a separate cause of action form for each cause of action.)
GN-1. Plaintiff (name): Reza Mohammadi and Farhan Mohammadi (1st MVA), Reza Mohammadi (2nd
MVA
alleges that defendant (name): Larry Matson(1st MVA) and Citty of Fresno and Steve Wallace (2nd
MVA) in violation of California Government Code Section 8 2
[x] Does 1 to 100
was the legal (proximate) cause of damages to plaintiff. By the following acts or omissions to act, defendant
negligently caused the damage to plaintiff
on (date): 08/08/2015 (1st MVA) and 11/09/2015 (2nd MVA)
at (place): 1st MVA occurred on Villa Avenue in the City of Clovis; 2nd MVA occurred near the
intersection of SR-41 S/B and 1 mile North of FRE R 28.469, in the City and County of Fresno
(description of reasons for liability):
GN-2 Plaintiff by this reference hereby incorporates and makes a part here as though fully set forth herein all
and singular the allegations contained in Plaintiff's First Cause of Action of this point and Second Cause of
Action hereafter.
GN-3 The defendants and their agents and employees and each of them, at the above date and location,
negligently and carelessly owned and controlled their vehicle by colliding into plaintiff's vehicle whereby
causing injuries to plaintiffs and more particularity set forth herein.
GN-4 For the above reasons and as a direct and proximate result of defendants acts and omissions, plaintiff
has suffered injuries in mind and in bones, tissues, nerves and nervous system thereof in amounts currently
uncertain but subject to proof at time of trial.
GN-5 Asa direct and proximate result of defendants’ acts and omissions, plaintiffs sustained economic and
noneconomic damages including but not limited to property damage to plaintiff's physical, mental and
emotional condition, loss of consortium, past, present and future. The exact nature of those damages are
unknown at this tine, but shall be established according to proof at the time of trial.
Form Approved for Optional Use Page
1 of 1
5 ire ure
Code of Civil Proced425.12
Judicial Council of California
PLD-P1-001(2) [Rev. January 1, 2007] CAUSE OF ACTION—General Negligence
EXHIBIT B
Case Information
16CECG01808 | Reza Mohammadi vs. City of Fresno
Case Number Court Judicial Officer
16CECG01808 Civil Tharpe, D Tyler
File Date Case Type Case Status
06/06/2016 23 Unlimited - Other Open
PI/PD/WD
Party
Plaintiff Active Attorneys ¥
Mohammadi, Reza Lead Attorney
Aliases
Dobbins, Jeremy M.
Retained
2nd MVA
Plaintiff Active Attorneys ¥
Mohammadi, Farhan Lead Attorney
Dobbins, Jeremy M.
Aliases
Retained
ist MVA
Defendant Active Attorneys ¥
City of Fresno Lead Attorney
Jeffcoach, Mandy L.
Retained
Defendant Active Attorneys ¥
Wallace, Steve Lead Attorney
Jeffcoach, Mandy L.
Aliases Retained
2nd MVA
Defendant Active Attorneys ¥
Matson, Larry Lead Attorney
O'Rourke, Sean T.
Aliases
Retained
1st MVA
ESA Mattson, Larry
Events and Hearings
06/06/2016 Civil case cover sheet ¥
Civil Document
06/06/2016 Civil Complaint filed +
Civil Document
06/06/2016 Notice of Hearing v
Civil Document
Comment
CMC
06/06/2016 Summons issued and filed ¥
Civil Document
10/11/2016 Case Management Conference ¥
Hearing Time
10:00 AM
Result
Heard
10/11/2016 Minute Order Attachment v
Minute Order Attachment
12/19/2016 Case Management Conference v
Hearing Time
10:00 AM
Result
Heard
12/19/2016 Minute Order Attachment +
Minute Order Attachment
02/21/2017 Case Management Conference ¥
Hearing Time
10:00 AM
Result
Heard
02/21/2017 Minute Order Attachment ¥
Minute Order Attachment
04/24/2017 Case Management Conference ¥
Hearing Time
10:00 AM
Result
Heard
04/24/2017 Minute Order Attachment ¥
Minute Order Attachment
06/26/2017 Case Management Conference v
Hearing Time
10:00 AM
Result
Heard
06/26/2017 Minute Order Attachment ¥
Minute Order Attachment
08/02/2017 Amended Document Filed v
Amended Complaint - Claim Amount Unchanged (No Fee)
Comment
amended complaint
08/29/2017 Proof of Service
Proof of Service
Comment
City of Fresno- Amended complaint
08/29/2017 Summons and Complaint¥
08/31/2017 60-Day Continued OSC ¥
Judicial Officer
Cullers, Mark
Hearing Time
9:31 AM
Result
Heard
08/31/2017 Minute Order Attachment ¥
Minute Order Attachment
09/07/2017 Proof of Service
Proof of Service
Comment
Larry Matson
09/07/2017 Summons and Complaintv
Comment
First Amended Complaint
09/25/2017 Declaration Filed
Declaration
Comment
Declaration of SMS Pursuant to CCP 430.41
09/27/2017 Amended Document Filed
Amended Document Filed
Comment
Second Amendment to Complaint
10/06/2017 Proof of Service v
Proof of Service of Summons
Comment
City of Fresno
10/12/2017 Summons and Complaint¥
10/17/2017 Proof of Service v
Proof of Service
Comment
Steve Wallace
10/17/2017 Summons and Complaint¥
Comment
First and Second Amended Complaint
11/02/2017 Order to Show Cause - Pre ¥
Judicial Officer
Diaz, Monica
Hearing Time
8:32 AM
Result
Heard
11/02/2017 Amended Document Filed ¥
Amended Complaint - Claim Amount Unchanged (No Fee)
Comment
Third Amended Complaint
11/02/2017 Amended Document Filed ~
AMENDED Civil Case Cover Sheet
Comment
Civil Case Cover Sheet
11/02/2017 Minute Order Attachment v
Minute Order Attachment
11/30/2017 Motion - Strike ¥
Judicial Officer
McGuire, Rosemary
Hearing Time
3:28 PM
Cancel Reason
Off Calendar
Comment
Stephanie Snyder
12/01/2017 Summons issued and filed ¥
Amended Summons to Third Amended Complaint
Summons issued and filed
Comment
Amended Summons to Third Amended Complaint
12/19/2017 Answer Filed v
Answer/Response/Denial/Demurrer - No Fee
Comment
to Third Amended Complaint
12/19/2017 Government Exemption Claimed
12/21/2017 Proof of Service v
Proof of Service
Comment
Larry Matson
12/21/2017 Summons and Complaint¥
Comment
Second Amended Complaint
01/22/2018 Notice of Hearing v
Answer/Response/Denial/Demurrer - First Appearance Fee
Comment
Notice of Hearing on Demurrer to Third Amended Complaint;
Demurrer to Third Amended Complaint; Memorandum of Points and
Authorities in Support of Demurrer to Third Amended Complaint;
Declaration Pursuant to CCP Section 430.41
02/01/2018 Order to Show Cause - Pre ¥
Judicial Officer
Diaz, Monica
Hearing Time
8:32 AM
Result
Heard
02/01/2018 Minute Order Attachment ¥
Minute Order Attachment
02/21/2018 Notice Filed v
Notice
Comment
of Change of Attorney
02/22/2018 Opposition filed ¥
Opposition
Comment
Opposition
02/22/2018 Declaration Filed
Declaration
Comment
Declaration
02/28/2018 Reply filed ¥
Reply
Comment
Reply Memorandum of Points and Authorities in Support of
Demurrer to Third Amended Complaint
02/28/2018 Ex parte Filed v
Ex Parte Application
Comment
Ex Parte Application For Order Shortening Time on a Notice For
Motion For Relief From Dismissal
02/28/2018 Order Received for Signature ¥
Proposed Order
Comment
Proposed Order Shortening Time of Notice For A Motion For Relief
From Dismissal
02/28/2018 Declaration Filed +
Declaration
Comment
Declaration of Rodney C. Haron In Support of Motion for Relief From
Dismissal
02/28/2018 Memorandum of Points and Authorities ¥
Memorandum of Points & Authorities
Comment
Memorandum of Points & Authorities
03/01/2018 Ex Parte Hearing ¥
Judicial Officer
Black, Donald
Hearing Time
3:29 PM
Result
Heard
Comment
OST for motion pursuant CCP 473; Ron Haron
03/01/2018 Minute Order Attachment ¥
Minute Order Attachment
03/06/2018 Order Received for Signature ¥
Proposed Order
Comment
Signed and returned to clerk's office for further processing
Proposed Order For Heairng on Defendant's Demurrer and Plaintiff's
Motion for Relief From Dismissal (Pending Until Hearing)
03/07/2018 Opposition filed ¥
Opposition
Comment
Defendant Larry Matson's Opposition to Plaintiffs' Motion for Relief
03/13/2018 Order filed ¥
Civil Document
Judicial Comment
Officer on Demurrer and Plaintiff's motion for relief from
Black, dismissal
Donald
03/14/2018 Demurrer ¥
Judicial Officer
Black, Donald
Hearing Time
3:27 PM
Result
Uncontested
Comment
Shawn O'Rourke
03/14/2018 Hearing ¥
Judicial Officer
Black, Donald
Hearing Time
3:28 PM
Result
Uncontested
Comment
Motion For Relief From Dismissal
03/14/2018 Minute Order Attachment (Tentative Rulings Only) ¥
Civil Document
03/28/2018 Answer Filed ¥
Answer/Response/Denial/Demurrer - No Fee
Comment
Defendant's Answer to Plaintiffs' Third Amended Complaint
04/05/2018 Order to Show Cause - Pre ¥
Judicial Officer
Diaz, Monica
Hearing Time
8:32 AM
Result
Heard
04/05/2018 Minute Order Attachment ¥
Minute Order Attachment
04/23/2018 Case Management Conference ¥
Hearing Time
11:00 AM
Result
Heard
04/23/2018 Deposit, payment,disbursment +
Deposit, payment,disbursment
Comment
Jury Deopsit
04/23/2018 Minute Order Attachment ¥
Minute Order Attachment
04/23/2018 Jury Trial Requested by Both Parties v
Comment
Requested by both parties with estimated time of 2-3 weeks
04/23/2018 Referral to ADR
04/23/2018 Deposit, payment,disbursment ¥
Deposit, payment,disbursment
Comment
Jury Fees
04/26/2018 Notice Filed v
Notice
Comment
Notice of Change of Attorney
05/01/2018 Request for Refund Received - Pending Review v
Request for Refund Received - Pending Review
Comment
Type of Refund:Overpayment
05/30/2018 ADR Stipulation Mediation filed ¥
Stipulation
Comment
Parties to engage in mediation. Mediator:Lee Jacobson
06/11/2018 Proof of Service v
Proof of Service
Comment
of statement of damages as to Larry Matson
06/12/2018 Proof of Service v
Proof of Service
Comment
of statement of damages as to City of Fresno
06/28/2018 OSC - ADR Stipulation +
Judicial Officer
Diaz, Monica
Hearing Time
8:37 AM
Cancel Reason
Off Calendar
07/23/2018 Request for Pre-Trial Discovery filed
Request
Comment
Forwarded to dept. 502
08/06/2018 Opposition to Request for Pre-Trial Discovery filed ¥
Opposition
Comment
Forwarded to dept. 502
08/09/2018 Notice Filed v
Notice
Comment
to Withdraw Request for PreTrial Discovery Conference
12/19/2018 Motion - Compel ¥
Judicial Officer
Black, Donald
Hearing Time
3:28 PM
Cancel Reason
Off Calendar
Comment
Kristi Costa
02/05/2019 Notice Filed ¥
Notice Filed
Comment
Notice of Calendar Setting with regards to change of Civil Presiding
Depts from 501 to 502
03/20/2019 Substitution of Attorney Filed ¥
Substitution of Attorney
Comment
Old Attorney:Kristi M. Costa New Attorney:Mandy L. Jeffcoach
03/25/2019 Substitution of Attorney Filed ¥
Substitution of Attorney
Comment
Old Attorney: Kristi M. Costa New Attorney: Mandy L. Jeffcoach
03/25/2019 Substitution of Attorney Filed ¥
Substitution of Attorney
Comment
Old Attorney:Kristi M. Costa New Attorney:Mandy L. Jeffcoach
04/16/2019 Motion - Compel v
Judicial Officer
Simpson, Alan
Hearing Time
3:27 PM
Cancel Reason
Off Calendar
Comment
Kristi Costa
05/14/2019 Motion - Compel ¥
Judicial Officer
Simpson, Alan
Hearing Time
3:27 PM
Cancel Reason
Off Calendar
Comment
Kristi Costa
05/22/2019 Ex parte Filed v
Ex Parte Application
Comment
for OST to Continue Trial; Notice of Hrg on Ex Parte App; Memo of
Ps&As and Dec of STO ISO Thereof
05/22/2019 Ex parte Filed v
Ex Parte Application
Comment
EX PARTE APPLICATION FOR OST TO CONTINUE TRIAL; ETC.
05/22/2019 Notice Filed v
Notice Filed
Comment
Case reassigned to Judge Kimberly Gaab
05/22/2019 Pursuant to CCP 170.1 - Judge Disqualifies Self v
Pursuant to CCP 170.1 - Judge Disqualifies Self
Comment
Donald S. Black
05/22/2019 Order Received for Signature
Proposed Order
Comment
Pending Hearing Order Shortening Time for Motion to Continue Trial
05/23/2019 Ex Parte Hearing ¥
Judicial Officer
Gaab, Kimberly
Hearing Time
3:29 PM
Result
Heard
Comment
MCT - Shawn O'Rourke
05/23/2019 Minute Order Attachment ¥
Minute Order Attachment
Comment
attached certificate of mailing
06/14/2019 Ex parte Filed v
HRG 6/18/19 - Notice of Ex Parte Application and Ex Parte Ap
Comment
and Ex Parte Application for Motion to Compel
06/14/2019 Declaration Filed
HRG 6/18/19 - Declaration of Mandy L. Jeffcoach
Comment
of Mandy L. Jeffcoach
06/14/2019 Declaration Filed
HRG 6/18/19 - Declaration of Mandy L. Jeffcoach
Comment
of Mandy L. Jeffcoach
06/14/2019 Memorandum of Points and Authorities ¥
HRG 6/18/19 - Memorandum of Points & Authorities
06/14/2019 Proof of Service ¥
HRG 6/18/19 - Proof of Service
Comment
ISO Documents
06/18/2019 Ex Parte Hearing ¥
Judicial Officer
Gaab, Kimberly
Hearing Time
3:29 PM
Cancel Reason
Off Calendar
Comment
Compel - Mandy Jeffcoach
06/21/2019 Notice Filed ¥
Notice of Change of Firm Name
Comment
of Change of Firm Name and E-Mail Address
07/02/2019 Notice Filed v
Comment
Mandatory Settlement Conference Statement
07/10/2019 Mandatory Settlement Conference v
Judicial Officer
Hamilton, Jeffrey Y.
Hearing Time
10:00 AM
Result
Heard
07/10/2019 Consent to Confer filed ¥
Consent to Confer filed
07/10/2019 Minute Order Attachment ¥
Minute Order Attachment
Comment
re: Settlment Conference
07/15/2019 Notice of Settlement filed
Notice of Settlement of Entire Case
Comment
Treated as an Unconditional Settlement
07/16/2019 Fax Received v
Comment
Fax cover sheet and letter received via fax and forward to: 503 Re:
Counsel no longer represents former client.
07/17/2019 Notice of Hearing ¥
Notice of Hearing
Comment
Notice of Dismissal Hearing
07/19/2019 Ex parte Filed ¥
Joint Ex Parte Application and Application for Order Enforci
Comment
Joint Ex Parte Application and Application for Order Enforcing
Settlement
07/19/2019 Notice Filed ¥
Notice of Joint Exparte Application to Enforce Settlement
Comment
Notice of Joint Exparte Application to Enforce Settlement
07/19/2019 Declaration Filed ¥
Declaration
Comment
Declaration
07/19/2019 Declaration Filed ¥
Declaration
Comment
Declaration
07/19/2019 Memorandum of Points and Authorities v
Memorandum of Points & Authorities
Comment
Memorandum of Points & Authorities
07/19/2019 Proof of Service
Proof of Service
Comment
Proof of Service
07/19/2019 Request Filed ¥
Request
Comment
Request
07/23/2019 Ex Parte Hearing ¥
Judicial Officer
Simpson, Alan
Hearing Time
3:29 PM
Result
Heard
Comment
Withdraw as Counsel - (KAG unavailable) - Rod Haron (Settlement filed -
Mr. Haron wants this ex parte to remain on)
07/23/2019 Ex Parte Hearing
Judicial Officer
Simpson, Alan
Hearing Time
3:29 PM
Result
Heard
Comment
Enforce Settlement - (KAG unavailable) Mandy Jeffcoach
07/23/2019 Fax Received v
Comment
Fax received after five with an Ex Parte Application for Order
Shortening Time forward to: 502
07/23/2019 Ex parte Filed
HRG 7/23/19 Ex Parte Application
Comment
for Order Shortening Time of Motion to be Relieved as Counsel
07/23/2019 Order Received for Signature ¥
Proposed Order
Comment
Order Shortening Time of Motion to be Relieved as Counsel
07/23/2019 Minute Order Attachment ¥
Minute Order Attachment
07/23/2019 Order Appointing Court Approved Reporter
Order Appointing Court Approved Reporter
Judicial
Officer
Simpson,
Alan
08/09/2019 Trial Readiness v
Judicial Officer
Simpson, Alan
Hearing Time
9:30 AM
Cancel Reason
Settled
08/12/2019 Jury Trial ¥
Judicial Officer
Simpson, Alan
Hearing Time
9:00 AM
Cancel Reason
Settled
Comment
Requested by both parties with estimated time of 2-3 weeks.
08/26/2019 Substitution of Attorney Filed ¥
Substitution of Attorney
Comment
Old Attorney: Rodney C. Haron New Attorney: Jeremy M Dobbins
09/04/2019 Memorandum of Points and Authorities ¥
Opposition
Comment
In support of opposition to joint application to enforce settlement
09/04/2019 Declaration Filed v
Declarations of Counsel
Comment
Declarations of Counsel
09/10/2019 Reply filed ¥
In Suport Of Joint Application To Enforce Settlement
Comment
In Suport Of Joint Application To Enforce Settlement
09/10/2019 Declaration Filed
In Support Of Reply To Opposition
Comment
In Support Of Reply To Opposition
09/10/2019 Reply filed
Reply
Comment
Reply to Opposition to Motion to Enforce Settlement Made on July
10, 2019; Declaration of Sean T. O'Rourke (09/17/19)
09/17/2019 Motion - Withdrawal of Attorney ¥
Judicial Officer
Tharpe, D Tyler
Hearing Time
3:27 PM
Cancel Reason
Off Calendar
Comment
Set at 7/23/19 hearing
09/17/2019 Motion - Enforce Settlement ~
Judicial Officer
Hamilton, Jeffrey Y.
Hearing Time
4:15 PM
Result
Heard
Comment
Set at 7/23/19 hearing
09/17/2019 Notice Filed v
Notice
Comment
Notice of Attorney Lien Against Settlement or Judgment
09/17/2019 Order Appointing Court Approved Reporter
Order Appointing Court Approved Reporter
Judicial Comment
Officer court reporter, Shelly Davis
Hamilton,
Jeffrey Y.
09/17/2019 Minute Order Attachment (Tentative Rulings Only) ¥
Minute Order Attachment (Tentative Rulings Only)
Comment
re: Motion Enforce Settlement
09/17/2019 Taken Under Submission or Advisement
09/25/2019 Order Received for Signature
Comment
Proposed Order - fw003
09/25/2019 Notice of Appeal Filed - Civil
Notice of Appeal
Comment
Notice of Appeal; DCA F080055
09/27/2019 Notification of Filing Notice of Appeal - Civil ¥
Comment
with Clerk's Certificate of Mailing
10/02/2019 Mediation Notice from 5th DCA - Appeal Suspended ¥
Comment
Pursuant to 5th DCA Local Rule 2 DCA: F080055
10/08/2019 Court Reporter's Waiver of Deposit ¥
Comment
CSR S. Davis
10/08/2019 Appellant Notice Designating Record - CTX, RTX ¥
Appellant's Notice Designating on Appeal
Comment
Clerk's and Reporter's Transcripts
10/10/2019 Respondent Notice Designating Record - CTX only ¥
Respondent's Notice Designating Record on Appeal
Comment
Clerk's Transcripts only
10/10/2019 Respondent Notice Designating Record - CTX, RTX ¥
Respondent's Notice Designating on Appeal
Comment
Clerk's and Reporter's Transcripts
10/16/2019 Mediation Notice from 5th DCA - Appeal Reinstated +
Comment
Pursuant to 5th DCA Local Rule 2 DCA: F080055
10/17/2019 Notice of Estimate on Clerk's Transcript ¥
Comment
with Clerk's Certificate of Mailing
10/17/2019 Court Reporter's Waiver of Deposit ¥
Comment
Waiver of Deposit by Court Reporter A. Ekmalian
10/21/2019 Deposit for Reporter's Transcript on Appeal
10/22/2019 Respondents Deposit for Clerk's Transcript on Appeal ¥
Comment
DCA: F080055 $153.00 CTX
10/23/2019 Notice to Court Reporter - Civil ¥
Comment
with Clerk's Certificate of Mailing
10/23/2019 Letter of Documents Returned Without Filing ¥
Letter of Documents Returned Without Filing
Comment
We are unable to process your request for an electronic transcript as
a court reporter was present for the 9-17-19 hearing . The court
reporter, Shelly Davis, must be contacted directly to obtain this
transcript. Ms. Davis contact information is available on our court
website under Court Reporter Information. Our website is
www.fresno.courts.ca.gov. If you have any further questions, please
feel free to contact the Fresno Superior Court at 559-457-1900.
10/24/2019 Respondents Deposit for Clerk's Transcript on Appeal ¥
Comment
F080055 $153.00 CTX
10/29/2019 CRC 3.1385 After Settlement v
Original Type
CRC 3.1385 After Settlement
Judicial Officer
Tharpe, D Tyler
Hearing Time
3:31 PM
Result
Heard
10/29/2019 Minute Order Attachment +
Minute Order Attachment
12/02/2019 Notice of Completion of Transcript on Appeal - Civil ¥
Comment
with Clerk's Certificate of Mailing
12/02/2019 Clerk's Certificate of Mailing Civil Appeals
Comment
Document Mailed: Receipt for Record on Appeal
12/04/2019 Notice of Omission/Correction for Record on Civil Appeal ¥
Comment
Correction RTX A. Ekmalian
12/04/2019 Notice to Court Reporter - Civil +
Comment
with Clerk's Certificate of Mailing
12/17/2019 Appeals Receipt Filed v
Comment
Sean T. O'Rourke
12/19/2019 Clerk's Certificate of Mailing Civil Appeals ¥
Comment
Document Mailed Corrected Reporter's Transcript Vol 1
12/20/2019 Clerk's Certificate of Mailing Civil Appeals +
Comment
Document Mailed 2nd Corrected Vol 1 RTX
12/23/2019 Appeals Receipt Filed v
Comment
5th DCA; Record on Appeal
12/23/2019 Appeals Receipt Filed v
Comment
5th DCA; Record on Appeal Re: Correction Email
12/23/2019 Appeals Receipt Filed v
Comment
5th DCA; Record on Appeal Re: Correction Email
12/30/2019 Appeals Receipt Filed v
Preview
Jeremy M. Dobbins, Esq. (SBN 320648) Law ffice of Jeremy M. Dol ins E-FILED 1225 E. Divisadero, hird Floor Fresno, California 93721 9/13/2021 8:00 AM Telephone No.: (559) 306-6580 Superior Court of California Facsimile No.: (559) 316-4070 County of Fresno Email: jeremy@jeremydobbins.com By: C. York, Deputy Attomey for Plaintiff, REZA MOHAMMADI SUPERIOR COURT OF CALIFORNIA COUNTY OF FRESNO 10 11 REZA MOHAMMADI and FARHAN Case Number: 16C ECG01808 MOHAMMADI [1% MVA]; REZA 12 MOHAMMAD! [2 MVA]; PLAINTIFF’S REQUEST FOR J UDICIAL NOTICE 13 Plaintiffs, 14 Vv. Action Filed: June 6, 2016 Trial Date: September 13, 2021 15 LARRY MATTSON [1% MVA]; CITY OF FRESNO and STEVE WALLACE [2"¢ 16 MVA\] and DOES 1 through 100, inclusive. 17 Defendants. 18 TO THE HONORABLE COURT: 19 PLAINTIFF REZA MOHAMMADLI, under the provisions of Evidence Code §§451, 452, 20 and 453 requests that the court take judicial notice of the following: 21 22 (1) The plaintiffs third amended complaint filed in the Superior Court of California, 23 County of Fresno, in this action as the only operative pleading in this action. A true 24 and correct copy of the third amended complaint is attached as Exhibit A. 25 (2) The Docket in this case, printed on September 3, 2021, a true and correct copy of 26 27 which is attached as Exhibit B. 28 Relevant rules regarding Cross Complaints in California are as follows: 1 PLAINTIFF’S REQUEST FOR JUDICIAL NOTICE CCP 428.10: A party against whom a cause of action has been asserted in a complaint or cross-complaint may file a cross- complaint setting forth either or both of the following: (a) Any cause of action he has against any of the parties who filed the complaint or cross-complaint against him.... (b) Any cause of action he has against a person alleged to be liable thereon, whether or not such person is already a party to the action, if the cause of action asserted in his cross-complaint (1) arises out of the same transaction, occurrence, or series of transactions or occurrences as the cause brought against him or (2) asserts a claim, right, or interest in the property or controversy which is the subject of the cause brought against him. CCP 428.20: When a person files a cross-complaint as authorized by Section 428.10, he may join any person as a cross-complainant 10 or cross-defendant, whether or not such person is already a party to 11 the action, if, had the cross-complaint been filed as an independent action, the joinder of that party would have 12 been permitted by the statutes governing joinder of parties. 13 CCP 428.50: (a) A party shall file a cross-complaint against any of 14 the parties who filed the complaint or cross-complaint against him or her before or at the same time as the answer to the complaint or 15 cross-complaint. (b) Any other cross-complaint may be filed at any time before the 16 court has set a date for trial. 17 (c) A party shall obtain leave of court to file any cross-complaint except one filed within the time specified in subdivision (a) (b) 18 Leave may be granted in the interest of justice at any time during the course of the action. 19 Evid Code §452(d) provides that judicial notice may be taken of “[rJecords of (1) any 20 3|2 sla 3|9 21 court of this state or (2) any court of record of the United States or of any state of the United qa 22 States.” Evidence Code §453 provides that “[t]he trial court shall take judicial notice of any 23 matter specified in §452 if a party requests it and: (a) [g]ives each adverse party sufficient notice 24 of the request, through the pleadings or otherwise, to enable such adverse party to prepare to meet 25 the request; and (b) [fJurnishes the court with sufficient information to enable it to take judicial 26 27 notice of the matter.” 28 2 PLAINTIFF’S REQUEST FOR JUDICIAL NOTICE The attached operative pleading (See Exhibit A) and the entire docket (See Exhibit B) are records of the Superior Court of California, County of Fresno, and are therefore judicially noticeable under Evid Code §452(d). The Exhibits are relevant to this action as the defendants A nswer, in its Sixth Affirmative Defense, “...alleges that the matter complained of in plaintiff's complaint and the causes of action therein, were solely caused by the actions or omissions of a third-party, or parties, other than this answering defendant.” The sole operative complaint and the entire docket are relevant because they demonstrate that the only operative complaint in this matter is the Third A mended Complaint 10 11 filed by the plaintiff. Defendants, as they are aware, had ample time to file a cross-complaint 12 against former co-defendant, Larry Matson, and the drivers of vehicles in former accidents where 13 plaintiff was a party in 2010 and 2014, but never did file said cross-complaint. But have from the 14 beginning of the suit blamed Matson and the other prior accidents for plaintiff’s injuries. 15 The Exhibits are further relevant to this action as the defendants Answer, in their Eighth 16 17 Affirmative Defense, “...alleges any non-economic damages sustained by plaintiff in this action 18 were due to the fault of someone other than CITY...” The sole operative complaint and the entire 19 docket are relevant because they demonstrate that the only operative complaint in this matter is 20 3|2 the Third Amended Complaint filed by the plaintiff. Defendants, as they are aware, had ample sla 3|9 21 22 time to file a cross-complaint against former co-defendant, Larry Matson and the drivers of qa 23 vehicles in former accidents where plaintiff was a party in 2010 and 2014, but never did file said 24 cross-complaint. But have from the beginning of the suit blamed Matson and the other prior 25 accidents for plaintiff’s injuries. 26 The Exhibits are further relevant to this action as the defendants A nswer, in their Fifteenth 27 28 Affirmative Defense, “...alleges the matter complained of in plaintiffs complaint and the causes 3 PLAINTIFF’S REQUEST FOR JUDICIAL NOTICE of action therein, were caused by the actions or omissions of an indispensable third-party, or parties, who have not been named as defendants in plaintiffs complaint, and whose interests are so involved such that the court cannot render judgment in their absence.” The sole operative complaint and the entire docket are relevant because they demonstrate that the only operative complaint in this matter is the Third Amended Complaint filed by the plaintiff. Defendants, as they are aware, had ample time to file a cross-complaint against former co-defendant, Larry Matson and the drivers of vehicles in former accidents where plaintiff was a party in 2010 and 2014, but never did file said cross-complaint. But have from the beginning of the suit blamed 10 11 Matson and the other prior accidents for plaintiff’s injuries. Y 12 13 Dated: September 9, 2021. By ~--- = 14 Jeremy M. Dobbins, Esq. Attomey for Plaintiff, 15 REZA MOHAMMADI 16 17 18 19 20 3|2 sla 3|9 21 qa 22 23 24 25 26 27 28 4 PLAINTIFF’S REQUEST FOR JUDICIAL NOTICE EXHIBITA PLD-PI-001 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): ‘FOR COURT USE ONLY | Rodney C. Haron, Attorney at aw 061423 A Professional Corporation E-FILED 1617 W. Shaw Ave. Ste B Fresno, CA 93711 11/2/2017 4:45 PM Fresno, CA 93711 FRESNO COUNTY By: SUPERIOR . Garcia, Depul COURT ‘TELEPHONE NO; (559) 441-1421 FAX NO. {Optional}: (559) 441-1911 E-MAIL ADDRESS (Optional): Sonya@rodharonlaw.com ATTORNEY FOR (Name): Plaintiff SUPERIOR COURT OF CALIFORNIA, COUNTY OF Fresno STREETADDRESS: 1130 O Street maine appress: Unlimited Civil cry and zip cope: Fresno, CA 93722 brancuname: Central Division PLAINTIFF: Reza Mohammadi and Farhan Mohammadi (1st MVA), Reza Mohammadi (2nd MVA) DEFENDANT: Larry Mattson (1st MVA), City of Fresno and Steve Wallace (2nd MVA) (c] Does 1 To 100 COMPLAINT—Personal Injury, Property Damage, Wrongful Death Lac] AMENDED (Number): THI Type (check ail that apply): [3c] MOTOR VEHICLE OTHER (specify): General Negligence {x] Property Damage (_) Wrongful Death (&x] Personal Injury [x] Other Damages (specify): Economic and Noneconomic Damages Jurisdiction (check ail that apply): [1 ACTION IS A LIMITED CIVIL CASE CASE NUMBER: Amount demanded does not exceed $10,000 exceeds $10,000, but does not exceed $25,000 16CECG01808 Gel ACTION IS AN UNLIMITED CIVIL CASE (exceeds $25,000) (J ACTION IS RECLASSIFIED by this amended complaint from limited to unlimited from unlimited to limited Plaintiff (name or names):‘Reza Mohammadi and Farhan Mohammadi (1st MVA), Reza Mohammad (2nd MVA alleges causes of action against defendant (name ornames): Larry Mattson (1st MVA) and City of Fresno and Steve Wallace (2nd MVA This pleading, including attachments and exhibits, consists of the following number of pages: Five Each plaintiff named above is a competent adult a. Co except plaintiff (name): (1) [__] a corporation qualified to do business in Califomia (2) [__] an unincorporated entity (describe): (3) [__] apublic entity (describe): (4) [] aminor an adult (a) [] for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (b) [J other (specify): (5) [£_] other (specify): [_] except plaintiff (name): (1y a corporation qualified to do business in California (2) an unincorporated entity (describe): (3) [) a public entity (describe): (4) C_]_aminor an adult (@) [_] for whom a guardian or conservator of the estate or a guardian ad litem has been appointed (b) [J other (specify): ©) (_] other (specify): [1] Information about additional plaintiffs who are not competent adults is shown in Attachment 3. Page1 of3 Form Approved for Optional Use COMPLAINT—Personal Injury, Pro,perty sot : Code of Civil Procedure, § 425.12 Judicial Council af California PLD-P!-001 [Rev. January1. 2007} Damage, Wrongful Death PLD-PI-004 SHORT TITLE: Mohammadi v Matson (CASE NUMBER: 16CECG01808 4 Cc] Plaintiff (name): is doing business under the fictitious name (specify): and has complied with the fictitious business name laws. 5. Each defendant named above is a natural person except defendant (name): c. [__] except defendant (name): (1) [_] a business organization, form unknown (1) [_] a business organization, form unknown (2) [_] acorporation (2) [_) a corporation (3) [_) an unincorporated entity (describe): (3) [_] an unincorporated entity (describe): (4) [<] a public entity (describe): City of Fresno (4) (__] a public entity (describe): (8) [1 other (specify): (5) [_] other (specify): [1 except defendant (name): [_] except defendant (name): (1) [J] a business organization, form unknown (1) (_] a business organization, form unknown (2) (_] acorporation Q) @ corporation (3) [__] an unincorporated entity (describe): (3) [] an unincorporated entity (describe): (4) [_] a public entity (describe): (4) [1] a public entity (describe): (©) [J other (specify): (©) [J other (specify): {__Jinformation about additional defendants who ave not natural persons is contained in Attachment 5. The true names of defendants sued as Does are unknown to plaintiff. a. Doe defendants (specify Doe numbers): 1-100 were the agents or employees of other named defendants and acted within the scope of that agency or employment. b. LX] Doe defendants (specify Doe numbers): 1-100 are persons whose capacities are unknown to plaintiff. [__] Defendants who are joined under Code of Civil Procedure section 382 are (names): This court is the proper court because a. at least one defendant now resides in its jurisdictional area. b, [] the principal place of business of a defendant corporation or unincorporated association is in its jurisdictional area. ¢. [c] injury to person or damage to personal property occurred in its jurisdictional area. d. (J other (specify): intiff is required to comply with a claims statute, and a. has complied with applicable claims statutes, or bE] Is excused from complying because (specify): PLD-P/-001 (Rev. January 1, 2007] COMPLAINT—Personal Injury, Property Page 2.0f3 Damage, Wrongful Death PLD-P1-004 SHORT TITLE: Mohammadi v Matson ‘CASE NUMBER: 16CECGO1808 10. The following causes of action are attached and the statements above apply to each (each complaint must have one or more causes of action attached). Motor Vehicle b. Ex] General Negligence « LJ Intentional Tort aC Products Liability e LJ Premises Liability Other (specify) 1 Plaintiff has suffered wage loss b. Ge] loss of use of property hospital and medical expenses general damage e. Ex] property damage loss of earning capacity other damage (specify); Other economic and noneconomic damages known and unknown ‘to plaintiff at this time, but subject to proof at time of trial Attorney fees pursuant to statute. 12. f{_] The damages claimed for wrongful death and the relationships of plaintiff to the deceased are a. [__] listed in Attachment 12. b.(—_] as follows: 13. The relief sought in this complaint is within the jurisdiction of this court. 14, Plaintiff prays for judgment for costs of suit; for such relief as is fair, just, and equitable; and for a. (1) Le] compensatory damages (2) [_] punitive damages The amount of damages is (in cases for personal injury or wrongful death, you must check (1): (1) according to proof (2) [_] inthe amount of: $ 15, [x] The paragraphs of this complaint alleged on information and belief are as follows (specify paragraph numbers). All Date: November O02 2017 (TYPE OR PRINT NAME) PLD-PLOO1 [Rev. January1, 2007] 061423 bRebowg—C Hanon By COMPLAINT—Personal Injury, Property Page 3 of 3 Damage, Wrongful Death PLD-PI-001(1) SHORT TITLE: Mohammadi v Matson CASE NUMBER: 16CECG01808 Firs CAUSE OF ACTION—Motor Vehicle (number} ATTACHMENT TO [x] Complaint [_] Cross - Complaint (Use a separate cause of action form for each cause of action.) Plaintiff (name): Reza Mohammadi and Farhan Mohammadi (1st MVA), Reza Mohammadi (2nd MVA) MV-1. Plaintiff alleges the acts of defendants were negligent; the acts were the legal (proximate) cause of injuries and damages to plaintiff, the acts occurred on (date): 08/08/2015 (1st MVA) and 11/09/2015 (2nd MVA) at (place): The Ist MVA occurred on Villa Avenue in the City of Clovis, County of Fresno. Larry Matson caused the collision by violating Vehicle Code 22107, making an unsafe turning movement. Defendant crashed into Plaintiff's vehicle. The 2nd MVA occurred at or near the intersection of SR-41 Southbound and 1 mile North of FRe R 29.469, in the City of Fresno, County of Fresno. Defendant Steve Wallace crashed into Plaintiff Reza Mohammadi's vehicle as a result of his unsafe speed, a violation of Vehicle Code 22350. Mv-2, DEFENDANTS a. Lx_] The defendants who operated a motor vehicle are (names): L: Matson and Steve Wallace and any eren its own to plaintiff at this time. Plaintiff prays to amend this complaint when their identities become available. [x] Does 1 to 20 b. [¢ ] The defendants who employed the persons who operated a motor vehicle in the course of their employment are (names): Steve Wallace was em, loyed by the City of Fresno at the time of the MVA; am rf other defendants are unknown to P| aintiffs at this time. Plaintiffs pray to amend this complaint when their identities become known. Does 21 to 30 c. LX ] The defendants who owned the motor vehicle which was operated with their permission are (names): Unknown to plaintiffs at this time. Plaintiffs pray to amend this complaint when their identities become known. Does 31 to 45 The defendants who entrusted the motor vehicle are (names): Unknown to plaintiffs at this time, but plaintiff prays to amend this complaint when their identities become known. Cx] Does 46 to 60 e. Lx |The defendants who were the agents and employees of the other defendants and acted within the scope of the agency were (names): Steve Wallace was employed by the City of Fresno at the time of the MVA; any other defendants are unknown to Plaintiffs at this time. Plaintiffs pray to amend this complaint when their identities become known. [x] Does 61 to BO f Cz The defendants who are liable to plaintiffs for other reasons and the reasons for the liability are [J listed in Attachment MV-2f [Lc Jas follows: Larry Matson for the Ist MVA on 08/08/2015; the City of Fresno and Steve Wallace for the 2nd MVA on 11/09/2015. Plaintiffs pray to amend this complaint when more defendants are indentified and become known to Plaintiffs. [x] Does 81 to 100 Form Approved for Optional Use Page1 of? Judicial Council of California CAUSE OF ACTION—Motor Vehicle Code of Civil Procedura 425.12 PLO-PI-001(1) [Rev. January 1, 2007] PLD-PI-001(2) SHORT TITLE: Mohammadi v Mattson CASE NUMBER: 16CECG01808 Second CAUSE OF ACTION—General Negligence Page Five (number) ATTACHMENT TO [x] Complaint [—] Cross - Complaint (Use a separate cause of action form for each cause of action.) GN-1. Plaintiff (name): Reza Mohammadi and Farhan Mohammadi (1st MVA), Reza Mohammadi (2nd MVA alleges that defendant (name): Larry Matson(1st MVA) and Citty of Fresno and Steve Wallace (2nd MVA) in violation of California Government Code Section 8 2 [x] Does 1 to 100 was the legal (proximate) cause of damages to plaintiff. By the following acts or omissions to act, defendant negligently caused the damage to plaintiff on (date): 08/08/2015 (1st MVA) and 11/09/2015 (2nd MVA) at (place): 1st MVA occurred on Villa Avenue in the City of Clovis; 2nd MVA occurred near the intersection of SR-41 S/B and 1 mile North of FRE R 28.469, in the City and County of Fresno (description of reasons for liability): GN-2 Plaintiff by this reference hereby incorporates and makes a part here as though fully set forth herein all and singular the allegations contained in Plaintiff's First Cause of Action of this point and Second Cause of Action hereafter. GN-3 The defendants and their agents and employees and each of them, at the above date and location, negligently and carelessly owned and controlled their vehicle by colliding into plaintiff's vehicle whereby causing injuries to plaintiffs and more particularity set forth herein. GN-4 For the above reasons and as a direct and proximate result of defendants acts and omissions, plaintiff has suffered injuries in mind and in bones, tissues, nerves and nervous system thereof in amounts currently uncertain but subject to proof at time of trial. GN-5 Asa direct and proximate result of defendants’ acts and omissions, plaintiffs sustained economic and noneconomic damages including but not limited to property damage to plaintiff's physical, mental and emotional condition, loss of consortium, past, present and future. The exact nature of those damages are unknown at this tine, but shall be established according to proof at the time of trial. Form Approved for Optional Use Page 1 of 1 5 ire ure Code of Civil Proced425.12 Judicial Council of California PLD-P1-001(2) [Rev. January 1, 2007] CAUSE OF ACTION—General Negligence EXHIBIT B Case Information 16CECG01808 | Reza Mohammadi vs. City of Fresno Case Number Court Judicial Officer 16CECG01808 Civil Tharpe, D Tyler File Date Case Type Case Status 06/06/2016 23 Unlimited - Other Open PI/PD/WD Party Plaintiff Active Attorneys ¥ Mohammadi, Reza Lead Attorney Aliases Dobbins, Jeremy M. Retained 2nd MVA Plaintiff Active Attorneys ¥ Mohammadi, Farhan Lead Attorney Dobbins, Jeremy M. Aliases Retained ist MVA Defendant Active Attorneys ¥ City of Fresno Lead Attorney Jeffcoach, Mandy L. Retained Defendant Active Attorneys ¥ Wallace, Steve Lead Attorney Jeffcoach, Mandy L. Aliases Retained 2nd MVA Defendant Active Attorneys ¥ Matson, Larry Lead Attorney O'Rourke, Sean T. Aliases Retained 1st MVA ESA Mattson, Larry Events and Hearings 06/06/2016 Civil case cover sheet ¥ Civil Document 06/06/2016 Civil Complaint filed + Civil Document 06/06/2016 Notice of Hearing v Civil Document Comment CMC 06/06/2016 Summons issued and filed ¥ Civil Document 10/11/2016 Case Management Conference ¥ Hearing Time 10:00 AM Result Heard 10/11/2016 Minute Order Attachment v Minute Order Attachment 12/19/2016 Case Management Conference v Hearing Time 10:00 AM Result Heard 12/19/2016 Minute Order Attachment + Minute Order Attachment 02/21/2017 Case Management Conference ¥ Hearing Time 10:00 AM Result Heard 02/21/2017 Minute Order Attachment ¥ Minute Order Attachment 04/24/2017 Case Management Conference ¥ Hearing Time 10:00 AM Result Heard 04/24/2017 Minute Order Attachment ¥ Minute Order Attachment 06/26/2017 Case Management Conference v Hearing Time 10:00 AM Result Heard 06/26/2017 Minute Order Attachment ¥ Minute Order Attachment 08/02/2017 Amended Document Filed v Amended Complaint - Claim Amount Unchanged (No Fee) Comment amended complaint 08/29/2017 Proof of Service Proof of Service Comment City of Fresno- Amended complaint 08/29/2017 Summons and Complaint¥ 08/31/2017 60-Day Continued OSC ¥ Judicial Officer Cullers, Mark Hearing Time 9:31 AM Result Heard 08/31/2017 Minute Order Attachment ¥ Minute Order Attachment 09/07/2017 Proof of Service Proof of Service Comment Larry Matson 09/07/2017 Summons and Complaintv Comment First Amended Complaint 09/25/2017 Declaration Filed Declaration Comment Declaration of SMS Pursuant to CCP 430.41 09/27/2017 Amended Document Filed Amended Document Filed Comment Second Amendment to Complaint 10/06/2017 Proof of Service v Proof of Service of Summons Comment City of Fresno 10/12/2017 Summons and Complaint¥ 10/17/2017 Proof of Service v Proof of Service Comment Steve Wallace 10/17/2017 Summons and Complaint¥ Comment First and Second Amended Complaint 11/02/2017 Order to Show Cause - Pre ¥ Judicial Officer Diaz, Monica Hearing Time 8:32 AM Result Heard 11/02/2017 Amended Document Filed ¥ Amended Complaint - Claim Amount Unchanged (No Fee) Comment Third Amended Complaint 11/02/2017 Amended Document Filed ~ AMENDED Civil Case Cover Sheet Comment Civil Case Cover Sheet 11/02/2017 Minute Order Attachment v Minute Order Attachment 11/30/2017 Motion - Strike ¥ Judicial Officer McGuire, Rosemary Hearing Time 3:28 PM Cancel Reason Off Calendar Comment Stephanie Snyder 12/01/2017 Summons issued and filed ¥ Amended Summons to Third Amended Complaint Summons issued and filed Comment Amended Summons to Third Amended Complaint 12/19/2017 Answer Filed v Answer/Response/Denial/Demurrer - No Fee Comment to Third Amended Complaint 12/19/2017 Government Exemption Claimed 12/21/2017 Proof of Service v Proof of Service Comment Larry Matson 12/21/2017 Summons and Complaint¥ Comment Second Amended Complaint 01/22/2018 Notice of Hearing v Answer/Response/Denial/Demurrer - First Appearance Fee Comment Notice of Hearing on Demurrer to Third Amended Complaint; Demurrer to Third Amended Complaint; Memorandum of Points and Authorities in Support of Demurrer to Third Amended Complaint; Declaration Pursuant to CCP Section 430.41 02/01/2018 Order to Show Cause - Pre ¥ Judicial Officer Diaz, Monica Hearing Time 8:32 AM Result Heard 02/01/2018 Minute Order Attachment ¥ Minute Order Attachment 02/21/2018 Notice Filed v Notice Comment of Change of Attorney 02/22/2018 Opposition filed ¥ Opposition Comment Opposition 02/22/2018 Declaration Filed Declaration Comment Declaration 02/28/2018 Reply filed ¥ Reply Comment Reply Memorandum of Points and Authorities in Support of Demurrer to Third Amended Complaint 02/28/2018 Ex parte Filed v Ex Parte Application Comment Ex Parte Application For Order Shortening Time on a Notice For Motion For Relief From Dismissal 02/28/2018 Order Received for Signature ¥ Proposed Order Comment Proposed Order Shortening Time of Notice For A Motion For Relief From Dismissal 02/28/2018 Declaration Filed + Declaration Comment Declaration of Rodney C. Haron In Support of Motion for Relief From Dismissal 02/28/2018 Memorandum of Points and Authorities ¥ Memorandum of Points & Authorities Comment Memorandum of Points & Authorities 03/01/2018 Ex Parte Hearing ¥ Judicial Officer Black, Donald Hearing Time 3:29 PM Result Heard Comment OST for motion pursuant CCP 473; Ron Haron 03/01/2018 Minute Order Attachment ¥ Minute Order Attachment 03/06/2018 Order Received for Signature ¥ Proposed Order Comment Signed and returned to clerk's office for further processing Proposed Order For Heairng on Defendant's Demurrer and Plaintiff's Motion for Relief From Dismissal (Pending Until Hearing) 03/07/2018 Opposition filed ¥ Opposition Comment Defendant Larry Matson's Opposition to Plaintiffs' Motion for Relief 03/13/2018 Order filed ¥ Civil Document Judicial Comment Officer on Demurrer and Plaintiff's motion for relief from Black, dismissal Donald 03/14/2018 Demurrer ¥ Judicial Officer Black, Donald Hearing Time 3:27 PM Result Uncontested Comment Shawn O'Rourke 03/14/2018 Hearing ¥ Judicial Officer Black, Donald Hearing Time 3:28 PM Result Uncontested Comment Motion For Relief From Dismissal 03/14/2018 Minute Order Attachment (Tentative Rulings Only) ¥ Civil Document 03/28/2018 Answer Filed ¥ Answer/Response/Denial/Demurrer - No Fee Comment Defendant's Answer to Plaintiffs' Third Amended Complaint 04/05/2018 Order to Show Cause - Pre ¥ Judicial Officer Diaz, Monica Hearing Time 8:32 AM Result Heard 04/05/2018 Minute Order Attachment ¥ Minute Order Attachment 04/23/2018 Case Management Conference ¥ Hearing Time 11:00 AM Result Heard 04/23/2018 Deposit, payment,disbursment + Deposit, payment,disbursment Comment Jury Deopsit 04/23/2018 Minute Order Attachment ¥ Minute Order Attachment 04/23/2018 Jury Trial Requested by Both Parties v Comment Requested by both parties with estimated time of 2-3 weeks 04/23/2018 Referral to ADR 04/23/2018 Deposit, payment,disbursment ¥ Deposit, payment,disbursment Comment Jury Fees 04/26/2018 Notice Filed v Notice Comment Notice of Change of Attorney 05/01/2018 Request for Refund Received - Pending Review v Request for Refund Received - Pending Review Comment Type of Refund:Overpayment 05/30/2018 ADR Stipulation Mediation filed ¥ Stipulation Comment Parties to engage in mediation. Mediator:Lee Jacobson 06/11/2018 Proof of Service v Proof of Service Comment of statement of damages as to Larry Matson 06/12/2018 Proof of Service v Proof of Service Comment of statement of damages as to City of Fresno 06/28/2018 OSC - ADR Stipulation + Judicial Officer Diaz, Monica Hearing Time 8:37 AM Cancel Reason Off Calendar 07/23/2018 Request for Pre-Trial Discovery filed Request Comment Forwarded to dept. 502 08/06/2018 Opposition to Request for Pre-Trial Discovery filed ¥ Opposition Comment Forwarded to dept. 502 08/09/2018 Notice Filed v Notice Comment to Withdraw Request for PreTrial Discovery Conference 12/19/2018 Motion - Compel ¥ Judicial Officer Black, Donald Hearing Time 3:28 PM Cancel Reason Off Calendar Comment Kristi Costa 02/05/2019 Notice Filed ¥ Notice Filed Comment Notice of Calendar Setting with regards to change of Civil Presiding Depts from 501 to 502 03/20/2019 Substitution of Attorney Filed ¥ Substitution of Attorney Comment Old Attorney:Kristi M. Costa New Attorney:Mandy L. Jeffcoach 03/25/2019 Substitution of Attorney Filed ¥ Substitution of Attorney Comment Old Attorney: Kristi M. Costa New Attorney: Mandy L. Jeffcoach 03/25/2019 Substitution of Attorney Filed ¥ Substitution of Attorney Comment Old Attorney:Kristi M. Costa New Attorney:Mandy L. Jeffcoach 04/16/2019 Motion - Compel v Judicial Officer Simpson, Alan Hearing Time 3:27 PM Cancel Reason Off Calendar Comment Kristi Costa 05/14/2019 Motion - Compel ¥ Judicial Officer Simpson, Alan Hearing Time 3:27 PM Cancel Reason Off Calendar Comment Kristi Costa 05/22/2019 Ex parte Filed v Ex Parte Application Comment for OST to Continue Trial; Notice of Hrg on Ex Parte App; Memo of Ps&As and Dec of STO ISO Thereof 05/22/2019 Ex parte Filed v Ex Parte Application Comment EX PARTE APPLICATION FOR OST TO CONTINUE TRIAL; ETC. 05/22/2019 Notice Filed v Notice Filed Comment Case reassigned to Judge Kimberly Gaab 05/22/2019 Pursuant to CCP 170.1 - Judge Disqualifies Self v Pursuant to CCP 170.1 - Judge Disqualifies Self Comment Donald S. Black 05/22/2019 Order Received for Signature Proposed Order Comment Pending Hearing Order Shortening Time for Motion to Continue Trial 05/23/2019 Ex Parte Hearing ¥ Judicial Officer Gaab, Kimberly Hearing Time 3:29 PM Result Heard Comment MCT - Shawn O'Rourke 05/23/2019 Minute Order Attachment ¥ Minute Order Attachment Comment attached certificate of mailing 06/14/2019 Ex parte Filed v HRG 6/18/19 - Notice of Ex Parte Application and Ex Parte Ap Comment and Ex Parte Application for Motion to Compel 06/14/2019 Declaration Filed HRG 6/18/19 - Declaration of Mandy L. Jeffcoach Comment of Mandy L. Jeffcoach 06/14/2019 Declaration Filed HRG 6/18/19 - Declaration of Mandy L. Jeffcoach Comment of Mandy L. Jeffcoach 06/14/2019 Memorandum of Points and Authorities ¥ HRG 6/18/19 - Memorandum of Points & Authorities 06/14/2019 Proof of Service ¥ HRG 6/18/19 - Proof of Service Comment ISO Documents 06/18/2019 Ex Parte Hearing ¥ Judicial Officer Gaab, Kimberly Hearing Time 3:29 PM Cancel Reason Off Calendar Comment Compel - Mandy Jeffcoach 06/21/2019 Notice Filed ¥ Notice of Change of Firm Name Comment of Change of Firm Name and E-Mail Address 07/02/2019 Notice Filed v Comment Mandatory Settlement Conference Statement 07/10/2019 Mandatory Settlement Conference v Judicial Officer Hamilton, Jeffrey Y. Hearing Time 10:00 AM Result Heard 07/10/2019 Consent to Confer filed ¥ Consent to Confer filed 07/10/2019 Minute Order Attachment ¥ Minute Order Attachment Comment re: Settlment Conference 07/15/2019 Notice of Settlement filed Notice of Settlement of Entire Case Comment Treated as an Unconditional Settlement 07/16/2019 Fax Received v Comment Fax cover sheet and letter received via fax and forward to: 503 Re: Counsel no longer represents former client. 07/17/2019 Notice of Hearing ¥ Notice of Hearing Comment Notice of Dismissal Hearing 07/19/2019 Ex parte Filed ¥ Joint Ex Parte Application and Application for Order Enforci Comment Joint Ex Parte Application and Application for Order Enforcing Settlement 07/19/2019 Notice Filed ¥ Notice of Joint Exparte Application to Enforce Settlement Comment Notice of Joint Exparte Application to Enforce Settlement 07/19/2019 Declaration Filed ¥ Declaration Comment Declaration 07/19/2019 Declaration Filed ¥ Declaration Comment Declaration 07/19/2019 Memorandum of Points and Authorities v Memorandum of Points & Authorities Comment Memorandum of Points & Authorities 07/19/2019 Proof of Service Proof of Service Comment Proof of Service 07/19/2019 Request Filed ¥ Request Comment Request 07/23/2019 Ex Parte Hearing ¥ Judicial Officer Simpson, Alan Hearing Time 3:29 PM Result Heard Comment Withdraw as Counsel - (KAG unavailable) - Rod Haron (Settlement filed - Mr. Haron wants this ex parte to remain on) 07/23/2019 Ex Parte Hearing Judicial Officer Simpson, Alan Hearing Time 3:29 PM Result Heard Comment Enforce Settlement - (KAG unavailable) Mandy Jeffcoach 07/23/2019 Fax Received v Comment Fax received after five with an Ex Parte Application for Order Shortening Time forward to: 502 07/23/2019 Ex parte Filed HRG 7/23/19 Ex Parte Application Comment for Order Shortening Time of Motion to be Relieved as Counsel 07/23/2019 Order Received for Signature ¥ Proposed Order Comment Order Shortening Time of Motion to be Relieved as Counsel 07/23/2019 Minute Order Attachment ¥ Minute Order Attachment 07/23/2019 Order Appointing Court Approved Reporter Order Appointing Court Approved Reporter Judicial Officer Simpson, Alan 08/09/2019 Trial Readiness v Judicial Officer Simpson, Alan Hearing Time 9:30 AM Cancel Reason Settled 08/12/2019 Jury Trial ¥ Judicial Officer Simpson, Alan Hearing Time 9:00 AM Cancel Reason Settled Comment Requested by both parties with estimated time of 2-3 weeks. 08/26/2019 Substitution of Attorney Filed ¥ Substitution of Attorney Comment Old Attorney: Rodney C. Haron New Attorney: Jeremy M Dobbins 09/04/2019 Memorandum of Points and Authorities ¥ Opposition Comment In support of opposition to joint application to enforce settlement 09/04/2019 Declaration Filed v Declarations of Counsel Comment Declarations of Counsel 09/10/2019 Reply filed ¥ In Suport Of Joint Application To Enforce Settlement Comment In Suport Of Joint Application To Enforce Settlement 09/10/2019 Declaration Filed In Support Of Reply To Opposition Comment In Support Of Reply To Opposition 09/10/2019 Reply filed Reply Comment Reply to Opposition to Motion to Enforce Settlement Made on July 10, 2019; Declaration of Sean T. O'Rourke (09/17/19) 09/17/2019 Motion - Withdrawal of Attorney ¥ Judicial Officer Tharpe, D Tyler Hearing Time 3:27 PM Cancel Reason Off Calendar Comment Set at 7/23/19 hearing 09/17/2019 Motion - Enforce Settlement ~ Judicial Officer Hamilton, Jeffrey Y. Hearing Time 4:15 PM Result Heard Comment Set at 7/23/19 hearing 09/17/2019 Notice Filed v Notice Comment Notice of Attorney Lien Against Settlement or Judgment 09/17/2019 Order Appointing Court Approved Reporter Order Appointing Court Approved Reporter Judicial Comment Officer court reporter, Shelly Davis Hamilton, Jeffrey Y. 09/17/2019 Minute Order Attachment (Tentative Rulings Only) ¥ Minute Order Attachment (Tentative Rulings Only) Comment re: Motion Enforce Settlement 09/17/2019 Taken Under Submission or Advisement 09/25/2019 Order Received for Signature Comment Proposed Order - fw003 09/25/2019 Notice of Appeal Filed - Civil Notice of Appeal Comment Notice of Appeal; DCA F080055 09/27/2019 Notification of Filing Notice of Appeal - Civil ¥ Comment with Clerk's Certificate of Mailing 10/02/2019 Mediation Notice from 5th DCA - Appeal Suspended ¥ Comment Pursuant to 5th DCA Local Rule 2 DCA: F080055 10/08/2019 Court Reporter's Waiver of Deposit ¥ Comment CSR S. Davis 10/08/2019 Appellant Notice Designating Record - CTX, RTX ¥ Appellant's Notice Designating on Appeal Comment Clerk's and Reporter's Transcripts 10/10/2019 Respondent Notice Designating Record - CTX only ¥ Respondent's Notice Designating Record on Appeal Comment Clerk's Transcripts only 10/10/2019 Respondent Notice Designating Record - CTX, RTX ¥ Respondent's Notice Designating on Appeal Comment Clerk's and Reporter's Transcripts 10/16/2019 Mediation Notice from 5th DCA - Appeal Reinstated + Comment Pursuant to 5th DCA Local Rule 2 DCA: F080055 10/17/2019 Notice of Estimate on Clerk's Transcript ¥ Comment with Clerk's Certificate of Mailing 10/17/2019 Court Reporter's Waiver of Deposit ¥ Comment Waiver of Deposit by Court Reporter A. Ekmalian 10/21/2019 Deposit for Reporter's Transcript on Appeal 10/22/2019 Respondents Deposit for Clerk's Transcript on Appeal ¥ Comment DCA: F080055 $153.00 CTX 10/23/2019 Notice to Court Reporter - Civil ¥ Comment with Clerk's Certificate of Mailing 10/23/2019 Letter of Documents Returned Without Filing ¥ Letter of Documents Returned Without Filing Comment We are unable to process your request for an electronic transcript as a court reporter was present for the 9-17-19 hearing . The court reporter, Shelly Davis, must be contacted directly to obtain this transcript. Ms. Davis contact information is available on our court website under Court Reporter Information. Our website is www.fresno.courts.ca.gov. If you have any further questions, please feel free to contact the Fresno Superior Court at 559-457-1900. 10/24/2019 Respondents Deposit for Clerk's Transcript on Appeal ¥ Comment F080055 $153.00 CTX 10/29/2019 CRC 3.1385 After Settlement v Original Type CRC 3.1385 After Settlement Judicial Officer Tharpe, D Tyler Hearing Time 3:31 PM Result Heard 10/29/2019 Minute Order Attachment + Minute Order Attachment 12/02/2019 Notice of Completion of Transcript on Appeal - Civil ¥ Comment with Clerk's Certificate of Mailing 12/02/2019 Clerk's Certificate of Mailing Civil Appeals Comment Document Mailed: Receipt for Record on Appeal 12/04/2019 Notice of Omission/Correction for Record on Civil Appeal ¥ Comment Correction RTX A. Ekmalian 12/04/2019 Notice to Court Reporter - Civil + Comment with Clerk's Certificate of Mailing 12/17/2019 Appeals Receipt Filed v Comment Sean T. O'Rourke 12/19/2019 Clerk's Certificate of Mailing Civil Appeals ¥ Comment Document Mailed Corrected Reporter's Transcript Vol 1 12/20/2019 Clerk's Certificate of Mailing Civil Appeals + Comment Document Mailed 2nd Corrected Vol 1 RTX 12/23/2019 Appeals Receipt Filed v Comment 5th DCA; Record on Appeal 12/23/2019 Appeals Receipt Filed v Comment 5th DCA; Record on Appeal Re: Correction Email 12/23/2019 Appeals Receipt Filed v Comment 5th DCA; Record on Appeal Re: Correction Email 12/30/2019 Appeals Receipt Filed v