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1 Kenneth N. Greenfield, Esq. (State Bar No. 105721)
Alexandra N. Selfridge, Esq. (State Bar No. 247063)
2
I AW OFFICES OF
KENNETH N. GREENFIELD
DRIVE, SUITE 210
16516 BERNARDO CENTER
SAN DIEGO, CA 92128
SAN MATEO COUNTY
(858) 675-0301
FAX (858) 675-0319 JU
Attorney for Defendant, Cle rl
WAWANESA GENERAL INSURANCE COMPANY
CLERK
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN MATEO
10 GEORGE MARDIKIAN Case No. CIV 517132
Plaintiff, DECLARATIONOF ALEXANDRAN.
SKLFRIDGE IN SUPPORT OF
12 [PROPOSED] ORDER GRANTING
DEFENDANT WAWANKSAGENERAL
13 WAWANESA GENERAL INSURANCE INSURANCE COMPANY'S MOTION
COMPANY, a California corporation; and TO COMPEL RESPONSES TO
14 DOES 1 to 50, inclusive, QUESTIONS NOT ANSWERED AT
DEPOSITION
15 Defendants.
Date: July 15, 2013
16 Time: 9:00 a.m.
Dept.: Law and Motion
17
Date Filed: October 3, 2012
18 Trial Date: November 12, 2013
19 I, Alexandra N. Selfridge, declare as follows:
20 1. I am an attorney duly licensed to practice before all of the courts of the State of
21 California and am an associate with the Law Offices of Kenneth N. Greenfield, attorneys of
22 record for Defendant, Wawanesa General Insurance Company ("Wawanesa"). I have personal
23 knowledge of each of the following facts and, if called as a witness, could and would testify
24 competently hereto except as to those matters which are explicitly set forth as based upon my
25 information and belief and, as to such matters, I am informed and believe that they are true and
26 correct.
27 2. This declaration ismade in support of the [Proposed] Order Granting Wawanesa's
28 Motion to Compel Responses to Questions Not Answered at Deposition.
I
SELFRIDGE DECL. RE: ORDER GRANTING MTC RESPONSES TO DEPOSITION QUESTIONS
1 3. On July 16, 2013, my office served Plaintiff's counsel with a copy of the
2 [Proposed] Order Granting Defendant Wawanesa General Insurance Company's Motion To
3 Compel Responses To Questions Not Answered At Deposition. Attached hereto as Exhibit 1 is a
4 true and correct copy of the July 16, 2013 Proof of Service.
5 4. In accordance with California Rules of Court, rule 3.1312, subdivision (a),
6 Plaintiff had five days to notify Defendant of any objections as to the form of the proposed order,
7 stating any reasons for disapproval, The five day period expired on July 21, 2013, and Plaintiffs
8 counsel has not asserted any objections to the proposed order.
9 I declare under penalty of perjury under the laws of the State of California that the
10 foregoing is true and correct and that this declaration was executed in the City of San Diego, State
11 of California on July 22, 2013.
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4 PcKXXANDRA SELFRIDGE, Declarant
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SELFRIDGE DECL. RE: ORDER GRANTING MTC RESPONSES TO DEPOSITION QUESTIONS
George Mardikian v. Wawanesa General lns. Co., et al. Case No. CIV 517132
i ~
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN MATEO
PROOF OF SERVICE
C.C.P. $ 1013a, C.R.C. 2.300, et seq.
6 STATE OF CALIFORNIA
COUNTY OF SAN DIEGO
I am employed in the aforesaid County, State of California. I am over the age of 18 years and not
a party to the within action; my business address is 1 65 16 Bernardo Center Drive, Suite 21 0, San Diego,
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California 92128.
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On July 22, 2013, I served the following document(s) described as
DECLARATIONOF ALEXANDRAN. SELFRIBGK IN SUPPORT OF [PROPOSED]
12 ORDER GRANTING DEFENDANT WAWANKSAGENERAL INSURANCE
COMPANY'S MOTION TO COMPEL RESPONSES TO QUESTIONS NOT
13
ANSWKREB AT DEPOSITION
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on the interested parties in this action by:
15
[X] Placing the original X a true copy thereof, enclosed in a sealed envelope,
16 addressed as follows.
[ ] Facsimile transmission as stated below.
17
Counsel for Plaintiff
Montie S. Day, Esq.
]9 Day Law Offices
1235 Casa Palermo Circle
20 Henderson, Nevada 89011-3144
T: (208) 280-3766
F: (800) 219-2901
msda vesa ao i. corn
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[X] 'BY MAIL:1 am "readily familiar" with the firm's practice of collection and processing
correspondence for mailing. Under that practice, it would be deposited with the United States
Postal Service on that same day, with postage thereon fully prepaid at San Diego, California in
24
the ordinary course of business. I am aware that on motion of the party served, service is
25 presumed invalid if postal cancellation date or postage meter date is more than one day after
date of deposit for mailing an affidavit.
26
27
Proof o( Service
[X] BY E-MAIL: to msdavesa@aol.corn (Courtesy Copy Only.)
[X] STATE: 1 declare under penalty of perjury under the laws of the State of California
that the above istrue and correct.
3
Executed on July 22, 2013, at San Diego, California
Jargoerrero
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Proof of Service
Exhibit 1
ii
George Mardikian v. Wawanesa General lns. Co., et al. i
Case No. CIV 517132
SUPERIOR COURT OF THK STATE OF CALIFORNIA
COUNTY OF SAN MATEO
PROOF OF SERVICE
C.C.P. )1013a, C.R.C. 2.300, etseq.
6 STATE OF CALIFORNIA )
) ss.
COUNTY OF SAN DIEGO )
I am employed in the aforesaid County, State of California. I am over the age of 18 years and not
a party to the within action; my business address is 1651 6 Bernardo Center Drive, Suite 21 0, San Diego,
9
California 92128.
On July 16, 2013, I served the following document{s) described as:
[PROPOSED] ORDER GRANTING DEFENDANT WAWANESA GENERAL
12 INSURANCK COMPANY'S MOTION TO COMPEL RESPONSES TO QUESTIONS
NOT ANSWERED AT DEPOSITION
13
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on the interested parties in this action by:
corn
15 [Xj Placing the original X a true copy thereof, enclosed in a sealed envelope,
addressed as follows.
16 Facsimile transmission as stated below.
[ ]
Counsel for Plaintiff
Montle S. Day, Esq.
Day Law Offices
1235 Casa Palermo Circle
Henderson, Nevada 89011-3144
20
T: {208) 280 3766
F: {800) 219-2901
msdavesa@aol.
22 [X] 'BY MAIL: I am "readily familiar" with the firm's practice of collection and processing
correspondence for mailing, Under that practice, it would be deposited with the United States
23 with
Postal Service on that same day, postage thereon fully prepaid at San Diego, California in
the ordinary course of business, I am aware that on motion of the party served, service is
presumed invalid ifpostal cancellation date or postage meter date is more than one day after
25 date of deposit for mailing an affidavit.
26
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Proof of Service Exhibit 1, Page 1 ~1
[X] BY E-MAIL: to msdavesa@aol.corn (Courtesy Copy Only.)
2 [X] STATE: I declare under penalty of perjury under the laws of the State of California
that the above is tru'eand correct.
3
Fxecuted on July 16, 2013, at San Diego, California.
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Proof of Service Exhibit 1, Page 1.2
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1 Kenneth N. Greenfield, Esq. (State Bar No. 105721) Alexandra N. Selfridge, Esq. (State Bar No. 247063) 2 I AW OFFICES OF KENNETH N. GREENFIELD DRIVE, SUITE 210 16516 BERNARDO CENTER SAN DIEGO, CA 92128 SAN MATEO COUNTY (858) 675-0301 FAX (858) 675-0319 JU Attorney for Defendant, Cle rl WAWANESA GENERAL INSURANCE COMPANY CLERK SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN MATEO 10 GEORGE MARDIKIAN Case No. CIV 517132 Plaintiff, DECLARATIONOF ALEXANDRAN. SKLFRIDGE IN SUPPORT OF 12 [PROPOSED] ORDER GRANTING DEFENDANT WAWANKSAGENERAL 13 WAWANESA GENERAL INSURANCE INSURANCE COMPANY'S MOTION COMPANY, a California corporation; and TO COMPEL RESPONSES TO 14 DOES 1 to 50, inclusive, QUESTIONS NOT ANSWERED AT DEPOSITION 15 Defendants. Date: July 15, 2013 16 Time: 9:00 a.m. Dept.: Law and Motion 17 Date Filed: October 3, 2012 18 Trial Date: November 12, 2013 19 I, Alexandra N. Selfridge, declare as follows: 20 1. I am an attorney duly licensed to practice before all of the courts of the State of 21 California and am an associate with the Law Offices of Kenneth N. Greenfield, attorneys of 22 record for Defendant, Wawanesa General Insurance Company ("Wawanesa"). I have personal 23 knowledge of each of the following facts and, if called as a witness, could and would testify 24 competently hereto except as to those matters which are explicitly set forth as based upon my 25 information and belief and, as to such matters, I am informed and believe that they are true and 26 correct. 27 2. This declaration ismade in support of the [Proposed] Order Granting Wawanesa's 28 Motion to Compel Responses to Questions Not Answered at Deposition. I SELFRIDGE DECL. RE: ORDER GRANTING MTC RESPONSES TO DEPOSITION QUESTIONS 1 3. On July 16, 2013, my office served Plaintiff's counsel with a copy of the 2 [Proposed] Order Granting Defendant Wawanesa General Insurance Company's Motion To 3 Compel Responses To Questions Not Answered At Deposition. Attached hereto as Exhibit 1 is a 4 true and correct copy of the July 16, 2013 Proof of Service. 5 4. In accordance with California Rules of Court, rule 3.1312, subdivision (a), 6 Plaintiff had five days to notify Defendant of any objections as to the form of the proposed order, 7 stating any reasons for disapproval, The five day period expired on July 21, 2013, and Plaintiffs 8 counsel has not asserted any objections to the proposed order. 9 I declare under penalty of perjury under the laws of the State of California that the 10 foregoing is true and correct and that this declaration was executed in the City of San Diego, State 11 of California on July 22, 2013. 12 O 13 g 4 PcKXXANDRA SELFRIDGE, Declarant a~Z(- 14 ~a~ V 15 K 5o9 la, ~z 16 17 18 19 20 21 22 23 24 25 26 27 28 2 SELFRIDGE DECL. RE: ORDER GRANTING MTC RESPONSES TO DEPOSITION QUESTIONS George Mardikian v. Wawanesa General lns. Co., et al. Case No. CIV 517132 i ~ SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN MATEO PROOF OF SERVICE C.C.P. $ 1013a, C.R.C. 2.300, et seq. 6 STATE OF CALIFORNIA COUNTY OF SAN DIEGO I am employed in the aforesaid County, State of California. I am over the age of 18 years and not a party to the within action; my business address is 1 65 16 Bernardo Center Drive, Suite 21 0, San Diego, 9 California 92128. 10 On July 22, 2013, I served the following document(s) described as DECLARATIONOF ALEXANDRAN. SELFRIBGK IN SUPPORT OF [PROPOSED] 12 ORDER GRANTING DEFENDANT WAWANKSAGENERAL INSURANCE COMPANY'S MOTION TO COMPEL RESPONSES TO QUESTIONS NOT 13 ANSWKREB AT DEPOSITION 14 on the interested parties in this action by: 15 [X] Placing the original X a true copy thereof, enclosed in a sealed envelope, 16 addressed as follows. [ ] Facsimile transmission as stated below. 17 Counsel for Plaintiff Montie S. Day, Esq. ]9 Day Law Offices 1235 Casa Palermo Circle 20 Henderson, Nevada 89011-3144 T: (208) 280-3766 F: (800) 219-2901 msda vesa ao i. corn 22 [X] 'BY MAIL:1 am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. Under that practice, it would be deposited with the United States Postal Service on that same day, with postage thereon fully prepaid at San Diego, California in 24 the ordinary course of business. I am aware that on motion of the party served, service is 25 presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing an affidavit. 26 27 Proof o( Service [X] BY E-MAIL: to msdavesa@aol.corn (Courtesy Copy Only.) [X] STATE: 1 declare under penalty of perjury under the laws of the State of California that the above istrue and correct. 3 Executed on July 22, 2013, at San Diego, California Jargoerrero 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Proof of Service Exhibit 1 ii George Mardikian v. Wawanesa General lns. Co., et al. i Case No. CIV 517132 SUPERIOR COURT OF THK STATE OF CALIFORNIA COUNTY OF SAN MATEO PROOF OF SERVICE C.C.P. )1013a, C.R.C. 2.300, etseq. 6 STATE OF CALIFORNIA ) ) ss. COUNTY OF SAN DIEGO ) I am employed in the aforesaid County, State of California. I am over the age of 18 years and not a party to the within action; my business address is 1651 6 Bernardo Center Drive, Suite 21 0, San Diego, 9 California 92128. On July 16, 2013, I served the following document{s) described as: [PROPOSED] ORDER GRANTING DEFENDANT WAWANESA GENERAL 12 INSURANCK COMPANY'S MOTION TO COMPEL RESPONSES TO QUESTIONS NOT ANSWERED AT DEPOSITION 13 14 on the interested parties in this action by: corn 15 [Xj Placing the original X a true copy thereof, enclosed in a sealed envelope, addressed as follows. 16 Facsimile transmission as stated below. [ ] Counsel for Plaintiff Montle S. Day, Esq. Day Law Offices 1235 Casa Palermo Circle Henderson, Nevada 89011-3144 20 T: {208) 280 3766 F: {800) 219-2901 msdavesa@aol. 22 [X] 'BY MAIL: I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing, Under that practice, it would be deposited with the United States 23 with Postal Service on that same day, postage thereon fully prepaid at San Diego, California in the ordinary course of business, I am aware that on motion of the party served, service is presumed invalid ifpostal cancellation date or postage meter date is more than one day after 25 date of deposit for mailing an affidavit. 26 27 Proof of Service Exhibit 1, Page 1 ~1 [X] BY E-MAIL: to msdavesa@aol.corn (Courtesy Copy Only.) 2 [X] STATE: I declare under penalty of perjury under the laws of the State of California that the above is tru'eand correct. 3 Fxecuted on July 16, 2013, at San Diego, California. 10 12 13 15 16 17 18 19 20 21 22 23 24 25 26 27 Proof of Service Exhibit 1, Page 1.2