Non Opposition

Cal. Super. - 6th Dist.June 24, 2019

Rebecca D. Martino, Esq. - SBN 236094 Ka n C. Klaus, Esq. - SBN 205923 CODDINGTON, HICKS 8c DANFORTH A Professional Corporation, Lawyers 555 Twin Dolphin Drive, Suite 300 Redwood City, CA 94065-2133 TeL: 650.592.5400 Fax: 650.592.5027 ATTORNEYS FOR Plaintiff Bikram Saha IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SANTA CLARA 10 11 12 13 14 15 16 17 18 BII~ SAHA, vs. Plaintiff, REPLY LOGISTICS INC., a Delaware Corporation; MOHIT RANDHAWA, an individual; and DOES 1 thtough 10, inclusive, Defendants. Case No. 19CV350171 NOTICE OF NON-OPPOSITION TO MOTION FOR TERMINATING SANCTIONS AND MONETARY SANCTIONS, OR, IN THE ALTERNATIVE,REQUEST FOR ISSUE, EVIDENTIARY AND MONETARY SANCTIONS Date: 9/24/2020 Time: 9:00 a.m. Dept.: 21 19 20 Plaintiff Bikram Saba, respectfully submits this Notice of Non-Opposition in support of plaintiff's motion for terminating sanctions and monetary sanctions, or, in the alternative, request for issue, evidentiary and monetary sanctions. 22 23 24 25 26 27 28 Dated: September 15, 2020 CODDINGTON, HICKS & DANFORTH /s/ ~~ B. M~~ By: Rebecca D. Martino Attorneys for Plaintiff Bikram Saba 1 Notice of Non-Opposition to Motion for Terminating Sanctions and Monetary Sanctions, or, in the Alternative, Request for Issue, Evidentiary and Monetary Sanctions; Case No: 19CV350171 703354 Electronically Filed by Superior Court of CA, County of Santa Clara, on 9/15/2020 2:17 PM Reviewed By: A. Floresca Case #19CV350171 Envelope: 4934775 19CV350171 Santa Clara - Civil A. Floresca PROOF OF SERVICE California Code of Civil Procedure sections 1011, 1013, 1013a, 2015.5 California Rule of Court rule 2.251 Federal Rule of Civil Procedure Rule 5(b) I, the undersigned, declare that I am employed in the County of San Mateo, State of California. I am over the age of eighteen (18) years and not a patty to the within action. My business address is 555 Twin Dolphin Drive, Suite 300, Redwood City, California 94065. My electronic mail address is hporterlRchdlawvers.corn. 10 12 I am readily familiat with my employer's business practice for collection and processing of correspondence and documents for mailing with the United States Postal Service, mailing via overnight delivery, ttansmission by facsimile machine, and delivery by hand. On September 15, 2020, I served a copy of each of the documents listed below by placing them for processing as indicated herein. 13 14 15 NOTICE OF NON-OPPOSITION TO MOTION FOR TERMINATING SANCTIONS AND MONETARY SANCTIONS, OR, IN THE ALTERNATIVE,REQUEST FOR ISSUE, EVIDENTIARY AND MONETARY SANCTIONS 16 17 19 20 21 22 23 24 25 26 27 28 United States Mail:The correspondence or documents were placed in sealed, labeled envelopes with postage thereon fully prepaid on the above date placed for collection and mailing at my place of business to be deposited with the U.S. Postal Service at Redwood City, California on this same date in the ordinary course of business. Overnight Delivery: The correspondence or documents were placed in sealed, labeled packaging for overnight delivery, with Federal Express, with all charges to be paid by my employer on the above date for collection at my place of business to be deposited in a facility regularly maintained by the overnight delivery carrier, or delivered to a courier or driver authorized by the overnight deIiyery carrier to receive such packages, on this date in the ordinary course of business. Hand Delivery: The correspondence or documents were placed in sealed, labeled envelopes and served by personal delivery to the party or attorney indicated herein, or if upon attorney, by leaving the labeled envelopes with a receptionist or other person+aving charge of the attorney's offtce. Facsimile Transmission: The correspondence or documents were placed for transmission from (650) 592-5027 at Redwood City, California, and were transmitted to a facsimile machine maintained by the party or attorney to be served at the facsimile machine telephone number provided by said party or attorney, on this same date in the ordinary course of business. The transmission was reported as complete and without error, and a record of the transmission was properly issued by the transmitting facsimile machine. Electronic Transmission: The correspondence or documents were transmitted electronically to the electronic address set forth below. State. The recipient has filed and served notice that he or she accepts electronic service; the recipient has electronically filed a document with the court; and/or the Court has mandated that the parties serve documents through its Court approved vendor. The printed form of this document bearing the original signature is on file and available for inspection at the request of the court or any party to the action or proceeding in which it is filed, in the manner provided in California Rule of Court Rufe 2.257(a). Federal The recipient of this electronic service has consented to this method of service in writing, a copy of which is on file and available for inspection in my employer's office. I have received no indication the electronic transmission did not reach the recipient. 10 PERSONS OR PARTIES SERVED: 13 14 Attorneys for Defendants ReplyLogistics, Inc. and ltrlohit Randhawa David C. Johnston, Esq. Attorney at Law 1600 G Street, Suite 102 Modesto, CA 95354 15 16 Telephone: (209) 579-1150 Facsunile: (209) 579-9420 david(Riohnstnnbusinesslaw.corn 17 18 19 I certify (or declare) under penalty of perIury under the laws of the State of California that the foregoing is true and conect and that this decl S ber 15, 2020. 20 21 Helen Porter 22 23 24 Conte Supuior Court ofCalifornia, Sauta Clara Couutr Action No: 19CV350171 Case Name: Saba, Bikram o. Repg Logutut luo., ot al. 25 26 27 28