Jury Demand: Ashley Hiracheta, et al. vs Helal Majid et al.

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                                1   KEVIN J. GRAY, ESQ. (SBN 142685)                                           Electronically Filed
     kgray@tysonmendes.com                                              Superior Court of California
 2                                                                          County of San Joaquin
     IAN P. WILSON, ESQ. (SBN 271075)
                                                                               2021-11-24 18:31:55
 3   iwilson@tysonmendes.com
                                                                           Clerk: Taylor Hiedeman
     TYSON & MENDES LLP
 4   371 Bel Marin Keys Blvd., Suite 100
     Novato, CA 94949
 5   Telephone:    (628) 253-5070
     Facsimile:    (415) 785-3165
 6

 7   Attorneys for Defendant
     LANDSTAR RANGER, INC.
 8

 9                        SUPERIOR COURT OF THE STATE OF CALIFORNIA

10                                    COUNTY OF SAN JOAQUIN

11   ASHLEY HIRACHETA, individually, as heir of              Case No. STK-CV-UPI-2021-0001240
     SHELLY LEON, deceased, as heir of ANGELINA
12   HIRACHETA, deceased, and as parent and                  Assigned to Hon. Barbara Kronlund
     guardian of SAMUEL DIEGO-PINEDA, a minor;               Department 10D
13   MICHAEL HIRACHETA, as heir of ANGELINA
     HIRACHETA, deceased, and as parent and                  DEFENDANT LANDSTAR RANGER,
14   guardian of NEVEAH HIRACHETA, a minor;                  INC.’S DEMAND FOR JURY TRIAL
     MIGUEL A. QUIROS MARTINEZ, individually;                AND NOTICE OF POSTING JURY
15   and RAQUEL RIVERA McNIEL, ANHELICA                      FEES
     RIVERA, MIGUEL QUIROS MARTINEZ,
16   SHELLY QUIROS MARTINEZ, as heirs of
     SHELLY LEON, deceased,
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            Plaintiffs,
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            v.
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     HELAL MAJID, an individual, and TONY
20   TRANS, INC., a California corporation, and
     DOES 1-100,
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            Defendants.
22                                                           Date Filed:    February 10, 2021
                                                             FAC Filed:     July 8, 2021
23                                                           Trial Date:    Not set
24   TO ALL PARTIES HEREIN AND TO THEIR ATTORNEYS OF RECORD:

25          PLEASE TAKE NOTICE that Defendant LANDSTAR RANGER, INC., hereby demands

26   a trial by jury in the above-referenced action. Defendant herewith post jury fees in the amount of

27   $150.00.

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                                                       1
        DEFENDANT LANDSTAR RANGER, INC.’S DEMAND FOR JURY TRIAL AND NOTICE OF POSTING JURY FEES
 1   Dated: November 24, 2021                  TYSON & MENDES LLP
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 4                                             By:
                                                     KEVIN J. GRAY
 5                                                   Attorneys for Defendant
                                                     LANDSTAR RANGER, INC.
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                                                  2
        DEFENDANT LANDSTAR RANGER, INC.’S DEMAND FOR JURY TRIAL AND NOTICE OF POSTING JURY FEES
                                                                     Hiracheta, et al. v. Majid, et al.
                                   San Joaquin Superior Court Case No.: STK-CV-UPI-2021-0001240

 1                                        PROOF OF SERVICE
 2
            I declare that:
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     I am a citizen of the United States, employed in the County of Marin, California, over the age of
 4   eighteen years, and not a party to the within cause. My business address is 371 Bel Marin Keys
     Boulevard, Suite 100, Novato, CA 94949. I served the within:
 5
            DEFENDANT LANDSTAR RANGER, INC.’S DEMAND FOR JURY TRIAL
 6          AND NOTICE OF POSTING JURY FEES

 7   PARTIES SERVED:
          Plaintiffs                                      Plaintiffs
 8        Daniel O’Leary, Esq.                            David A. Cutt, Esq. (Pro Hac Vice)
          Law Office of Daniel M. O’Leary                 Eisenberg, Cutt, Kendell & Olson
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          2300 Westwood Boulevard, Suite 105              215 South State Street, Suite 900
10        Los Angeles, California 90064                   Salt Lake City, Utah 84111
          Email: dan@danolearylaw.com                     dcutt@eckolaw.com
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     ___    BY MAIL: on the parties in said cause, by placing a true and correct copy thereof
13          enclosed in a sealed envelope with postage thereon fully prepaid, in the United States
            mail at Novato, California, as addressed on the service list.
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     ___    BY OVERNIGHT DELIVERY: I deposited copies of the above document at a Federal
15          Express facility regularly maintained, in an envelope or package designated by FedEx
16          with delivery fees paid or provided for the office indicated below.

17   _X_    BY ELECTRONIC TRANSMISSION ONLY. Only by electronic submission of the
            document(s) to the person(s) at the email address(es) listed, based on notice provided on
18          March 19, 2020 that during the ongoing COVID-19 coronavirus pandemic this office will
            be working remotely, unable to send and receive physical mail as usual, and is using only
19          electronic mail at this time. No electronic message or other indication that the
20          transmission was unsuccessful was received within a reasonable time after the
            transmission of the document(s).
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             I certify and declare under penalty of perjury that the foregoing is true and correct and
22   that this declaration was executed on November 24, 2021, at Novato, California.

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                                                           ____________________________________
25                                                         Michelle L. Flores

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