On April 17, 2018 a
Motion,Ex Parte
was filed
involving a dispute between
Trujillo, Bryan,
Trujillo, Cindy,
and
Does 1-20,
Does 1-50,
Magee, Stephen,
Sac Aero Flying Club, Inc.,
for (23) Unlimited Other PI/PD/WD
in the District Court of San Mateo County.
Preview
GARRY L. MONTANARI, State Bar No. 89790
JOHN MOON, State Bar No. 253811
MICHAELIS, MONTANARI & JOHNSON, P.C.
4333 Park Terrace Dr. #110
Westlake Village, CA 91361 FILED
Telephone No.: (818) 865-0444 SAN MATEO COUNTY
4}? Attorneys for Defendants, STEPHEN MAGEE
and SAC AERO CLUB FLYING, INC.
FEB 05 2019
SUPERIOR COURT OF THE STATE OF CALIFORNIA —
COUNTY OF SAN MATEO
10
11
BRYAN TRUJILLO and CINDY Case No.: 18CIV01901
12
TRUJILLO, Honorable Robert D. Foiles; Dept. 21
DEFENDANTS’ STATEMENT OF
13
Plaintiffs, NON-OPPOSITION TO NATIONWIDE
MUTUAL INSURANCE COMPANY’S
14
VS. MOTION FOR LEAVE TO
INTERVENE
15 Date: February 15, 2019
STEPHEN MAGEE, SAC AERO FLYING Time: 9:00 a.m.
16
CLUB, INC. and DOES 1 - 50, Dept: Law and Motion
17
Defendants. Complaint filed: April 17, 2018
Trial Date: June 3, 2019
18
19 Defendants STEPHEN MAGEE and SAC AERO FLYING CLUB, INC. respectfully submit
20 this statement of non-opposition to plaintiff-in-intervention NATIONWIDE MUTUAL
21 INSURANCE COMPANY ’s motion for leave to intervene.
22
23 DATED: February 4, 2019 MICHAELIS, MONTANARI & JOHNSON
24
25
cv
Statement
1639539
ote01
w» Gat MONTANA
26
27
It Attot
STEPHEN
s for Defendants
MAGEE
FLYING CLUB, INC.
and SAC AERO
28 N:\17517\pld\p-intervene.non.opp.wpd
-l-
DEFENDANTS’ STATEMENT OF NON-OPPOSITION TO NATIONWIDE MUTUAL INSURANCE
COMPANY’S MOTION FOR LEAVE TO INTERVENE
ne
PROOF OF SERVICE
STATE OF CALIFORNIA )
SS.
COUNTY OF LOS ANGELES )
Jam employed in the County of Los Angeles, State of California. I am over the age of 18
and not a party to the within action; my business address is 4333 Park Terrace Dr. #110, Westlake
Village, California 91361.
On February 4, 2019, I served the foregoing document described as DEFENDANTS’
STATEMENT OF NON-OPPOSITION TO NATIONWIDE MUTUAL INSURANCE
COMPANY’S MOTION FOR LEAVE TO INTERVENE on the interested parties in this action
by placing a true copy thereof in a sealed envelope with postage thereon fully prepaid in the United
States mail at Westlake Village, California, addressed as follows:
SEE EXHIBIT “A” ATTACHED HERETO
10 [X] (MAIL) I deposited such envelope in the mail at Westlake Village, California. The envelope
was mailed with postage thereon fully prepaid. I am “readily familiar” with firm's practice of
11 collection and processing correspondence for mailing. It is deposited with U.S. postal service on that
same day in the ordinary course of business. I am aware that on motion of party served, service is
12 presumed invalid if postal cancellation date or postage meter date is more than 1 day after date of
deposit for mailing in affidavit.
13
14 0 (ELECTRONIC TRANSFER) I caused all of the pages of the above-entitled document to
be sent to the recipient noted above via electronic transfer (email) at the respective email address
15 indicated above.
16 0 (FEDERAL EXPRESS) I deposited such envelope at the Federal Express office located at
Westlake Village, California. The envelope was mailed fully prepaid. I am "readily familiar" with
17 firm's practice of collection and processing correspondence for mailing with Federal Express. It is
deposited with the Westlake Village Federal Express service on that same day in the ordinary course
18 of business. I am aware that on motion of party served, service is presumed invalid if cancellation
date is more than 1 day after date of deposit for overnight mailing in affidavit.
19
I declare under penalty of perjury under the laws of the State of California that the foregoing
20 is true and correct.
21 Executed on February 4, 2019 at Westlake Village, California.
ty
22
Barba a ssi fran, CCLS
23
24
25
26
27
28
e
EXHIBIT “A”
Michael S. Danko, Esq. Attorneys for Plaintiffs
Claire Y. Choo, Esq.
Danko Meredith
333 Twin Dolphin Dr. #145
Redwood Shores, CA 94065
tel: (650) 453-3600; fax: (650) 394-8672
Email: cchoo@dankolaw.com
Ashley E. Bauerle, Esq. Attorneys for Plaintiff-in-Intervention
Cozen O’Connor
501 West Broadway #1610
San Diego, CA 92101
tel: (800) 782-3366; fax: (619) 234-7831
Email: abauerle@cozen.com
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Document Filed Date
February 07, 2019
Case Filing Date
April 17, 2018
Category
(23) Unlimited Other PI/PD/WD
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
GARRY L. MONTANARI, State Bar No. 89790 JOHN MOON, State Bar No. 253811 MICHAELIS, MONTANARI & JOHNSON, P.C. 4333 Park Terrace Dr. #110 Westlake Village, CA 91361 FILED Telephone No.: (818) 865-0444 SAN MATEO COUNTY 4}? Attorneys for Defendants, STEPHEN MAGEE and SAC AERO CLUB FLYING, INC. FEB 05 2019 SUPERIOR COURT OF THE STATE OF CALIFORNIA — COUNTY OF SAN MATEO 10 11 BRYAN TRUJILLO and CINDY Case No.: 18CIV01901 12 TRUJILLO, Honorable Robert D. Foiles; Dept. 21 DEFENDANTS’ STATEMENT OF 13 Plaintiffs, NON-OPPOSITION TO NATIONWIDE MUTUAL INSURANCE COMPANY’S 14 VS. MOTION FOR LEAVE TO INTERVENE 15 Date: February 15, 2019 STEPHEN MAGEE, SAC AERO FLYING Time: 9:00 a.m. 16 CLUB, INC. and DOES 1 - 50, Dept: Law and Motion 17 Defendants. Complaint filed: April 17, 2018 Trial Date: June 3, 2019 18 19 Defendants STEPHEN MAGEE and SAC AERO FLYING CLUB, INC. respectfully submit 20 this statement of non-opposition to plaintiff-in-intervention NATIONWIDE MUTUAL 21 INSURANCE COMPANY ’s motion for leave to intervene. 22 23 DATED: February 4, 2019 MICHAELIS, MONTANARI & JOHNSON 24 25 cv Statement 1639539 ote01 w» Gat MONTANA 26 27 It Attot STEPHEN s for Defendants MAGEE FLYING CLUB, INC. and SAC AERO 28 N:\17517\pld\p-intervene.non.opp.wpd -l- DEFENDANTS’ STATEMENT OF NON-OPPOSITION TO NATIONWIDE MUTUAL INSURANCE COMPANY’S MOTION FOR LEAVE TO INTERVENE ne PROOF OF SERVICE STATE OF CALIFORNIA ) SS. COUNTY OF LOS ANGELES ) Jam employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action; my business address is 4333 Park Terrace Dr. #110, Westlake Village, California 91361. On February 4, 2019, I served the foregoing document described as DEFENDANTS’ STATEMENT OF NON-OPPOSITION TO NATIONWIDE MUTUAL INSURANCE COMPANY’S MOTION FOR LEAVE TO INTERVENE on the interested parties in this action by placing a true copy thereof in a sealed envelope with postage thereon fully prepaid in the United States mail at Westlake Village, California, addressed as follows: SEE EXHIBIT “A” ATTACHED HERETO 10 [X] (MAIL) I deposited such envelope in the mail at Westlake Village, California. The envelope was mailed with postage thereon fully prepaid. I am “readily familiar” with firm's practice of 11 collection and processing correspondence for mailing. It is deposited with U.S. postal service on that same day in the ordinary course of business. I am aware that on motion of party served, service is 12 presumed invalid if postal cancellation date or postage meter date is more than 1 day after date of deposit for mailing in affidavit. 13 14 0 (ELECTRONIC TRANSFER) I caused all of the pages of the above-entitled document to be sent to the recipient noted above via electronic transfer (email) at the respective email address 15 indicated above. 16 0 (FEDERAL EXPRESS) I deposited such envelope at the Federal Express office located at Westlake Village, California. The envelope was mailed fully prepaid. I am "readily familiar" with 17 firm's practice of collection and processing correspondence for mailing with Federal Express. It is deposited with the Westlake Village Federal Express service on that same day in the ordinary course 18 of business. I am aware that on motion of party served, service is presumed invalid if cancellation date is more than 1 day after date of deposit for overnight mailing in affidavit. 19 I declare under penalty of perjury under the laws of the State of California that the foregoing 20 is true and correct. 21 Executed on February 4, 2019 at Westlake Village, California. ty 22 Barba a ssi fran, CCLS 23 24 25 26 27 28 e EXHIBIT “A” Michael S. Danko, Esq. Attorneys for Plaintiffs Claire Y. Choo, Esq. Danko Meredith 333 Twin Dolphin Dr. #145 Redwood Shores, CA 94065 tel: (650) 453-3600; fax: (650) 394-8672 Email: cchoo@dankolaw.com Ashley E. Bauerle, Esq. Attorneys for Plaintiff-in-Intervention Cozen O’Connor 501 West Broadway #1610 San Diego, CA 92101 tel: (800) 782-3366; fax: (619) 234-7831 Email: abauerle@cozen.com 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28