Request Dismissal

Cal. Super. - 6th Dist.June 19, 2020

CIV-11O ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR NO; FOR COURT USE ONLY NAME: SHADI SHAYAN, ESQ./ S.B.N. 265467 FIRM NAME: Law Offices of Stephenson, Acquisto & Colman, Inc. Elecuomcally Flled STREETADDREss: 303 N. Glenoaks Blvd., Suite 700 by SUperior court 0f CA, CITY: Burbank STATE: CA ZIP CODE: 91502 county Of santa Clara, TELEPHONE No.: (818) 559-4477 FAX No. : (818) 559-5484 on 10/28/2020 4-00 PM E-MAILADDREss: sshayan@sacfirm.com Reviewed By: F_ Miller ATTORNEY FOR(Name): Plaintiff P SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA vase #ZOCV367479 STREET ADDRESS: 191 N 1st Street Envelope: 5197265 MAILING ADDRESS: 191 N 1st Street CITY AND ZIP CODE: San Jose, CA 951 13 BRANCH NAME: Santa Clara County - Downtown Superior Court PIaintiff/Petitioner: Stanford Health Care Defendant/Respondent: United Agricultural Employee Welfare Benefit Plan & Trust, et al. CASE NUMBER: REQUEST FOR DISMISSAL ZOCV367479 A conformed copy will not be returned by the clerk unless a method of return is provided with the document. This form may not be used for dismissal of a derivative action or a class action or of any party or cause of action in a class action. (Cal. Rules of Court, rules 3.760 and 3.770.) 1. TO THE CLERK: Please dismiss this action as follows: a. (1) E With prejudice (2) E Without prejudice b. (1) E Complaint (2) E Petition (3) E Cross-complaint filed by (name): on (date): (4) E Cross-complaint filed by (name): on (date): (5) E Entire action of all parties and all causes of action (6) E Other (specify):* 2. (Complete in all cases except family law cases.) The courtE did E did not waive court fees and costs for a party in this case. (This information may be obtained from the clerk. If coun‘ fees and costs were waived, the declaration on the back of this form must be completed). Date: October 22, 2020 ’SHADI SHAYAN /S/ Shadi Shayan (TYPE 0R PRINT NAME 0F E ATTORNEY E PARTY WITHOUT ATTORNEY) (SIGNATURE) *If dismissal requested is of specified parties only of specified causes of action only, Attorney 0r party Without attorney for: Stanford Health care or of specified cross-complaints only, so state and identify the parties, causes of E plaintifi/petitioner E Defendant/Respondent action, or cross-complaints to be dismissed. E Cross Complainant 3. TO THE CLERK: Consent to the above dismissal is hereby given.** Date: ’ (TYPE 0R PRINT NAME 0F E ATTORNEY E PARTY WITHOUT ATTORNEY) (SIGNATURE) ** If a cross-complaint - or Response (Family Law) seeking affirmative Attorney or party without attorney for: relief- is on file, the attorney for cross-complainant (respondent) must sign E PIaintifi/Petitioner E Defendant/Respondentthis consent if required by Code of Civil Procedure section 581 (i) or (j). E Cross Complainant (To be completed by clerk) 4. Dismissal entered as requested on (date): 1 0/28/2020 4:00 PM 5 E Dismissal entered on (date): as to only (name): 6. E Dismissal not entered as requested for the following reasons (specify): 7. a. m Attorney or party without attorney notified on (date): 10/28/2020 4:00 PM b. E Attorney or party without attorney not notified. Filing party failed to provide E a 0066 to be conformed E means to return conformed copyDate:1 0/28/ O 4' PM Clerk, by /S/ F. Miller , Deputy p39“ of; Form Adopted for Mandatory Use Code of Civil Procedure, § 581 et seq.; Gov. Code, Judicial Council of California REQUEST FOR DISMISSAL § 68637(c); Cal. Rules of Court, rule 3.1390 ClV-1 10 [Rev. Jan. 1, 2013] www.courts.ca.gov CIV-110 PIaintiff/Petitioner: Stanford Health Care ggsévg'ggiR'm Defendant/Respondent: United Agricultural Employee Welfare Benefit Plan & Trust, et al. COURT'S RECOVERY OF WAIVED COURT FEES AND COSTS If a party whose court fees and costs were initially waived has recovered or will recover $1 0,000 or more in value by way of settlement, compromise, arbitration award, mediation settlement, or other means, the court has a statutory lien on that recovery. The court may refuse to dismiss the case until the lien is satisfied. (Gov. Code, § 68637.) Declaration Concerning Waived Court Fees 1. The court waived court fees and costs in this action for (name): 2. The person named in item 1 is (check one below): a. E not recovering anything of value by this action. b. E recovering less than $10,000 in value by this action. c. E recovering $10,000 or more in value by this action. (If item 20 is checked, item 3 must be completed.) 3. E A|| court fees and court costs that were waived in this action have been paid to the court (check one): Yes No | declare under penalty of perjury under the laws of the State of California that the information above is true and correct. Date: ’ (TYPE 0R PRINT NAME 0F E ATTORNEY E PARTY MAKING DECLARATION) (S'GNATURE) cnv-110[Rev. Januam, 2013] REQUEST FOR DISMISSAL Pagezofz For your protection and privacy. please press the Clear This Form button after you have printed the form. Print this form I l save this form I GOOQQUl-RUJNr-ik NNNNNNNNNr-dr-dr-dr-Ar-Ar-Ar-Ar-AHH OOQQU‘I-hUJNF-‘OKOOOQQU‘I-bUJNHO PROOF OF SERVICE I am employed in the county 0f Los Angeles, State of California. I am over the age 0f 18 and not a party t0 the Within action; my business address is 303 North Glenoaks Boulevard, Suite 700, Burbank, California 91502-3226. On October 28, 2020, I served the foregoing document(s) entitled: REQUEST FOR DISMISSAL by placing a true copy thereof enclosed in a sealed envelope addressed per the attached Service List. [] [] [] Mark C. Nielsen, Esq. Groom Law Group 1701 Pennsylvania Avenue, NW Washington, DC 20006 Attorneysfor Defendant MNielsen@groom.com BY MAIL: I am "readily familiar" with the firm's practice 0f collection and processing correspondence for mailing. Under that practice it would be deposited With the United States Postal Service 0n that same day with postage thereon fully prepaid at Burbank, California in the ordinary course 0f business. I am aware that 0n motion of the party served, service is presumed invalid if postal cancellation date 0r postage meter date is more than one day after date 0f deposit for mailing in affidavit. [C.C.P. 1013a(3); F.R.C.P. 5(b)] BY FEDERAL EXPRESS: I caused such envelope(s), with overnight Federal Express Delivery Charges to be paid by this firm, t0 be deposited with the Federal Express Corporation at a regularly maintained facility 0n the aforementioned date. [C.C.P. 10 1 3(0) 10 1 3(d)] BY PERSONAL SERVICE: I caused the above-stated document(s) t0 be served by personally delivering a true copy thereof to the individuals identified above. [C.C.P. 101 1(a); F.R.C.P. 5(b)] BY EXPRESS MAIL: I caused such envelope(s), with postage thereon fully prepaid and addressed t0 the party(s) shown above, t0 be deposited in a facility operated by the U.S. Postal Service and regularly maintained for the receipt 0f Express Mail on the aforementioned date. [C.C.P. 1013(0)] GOOQQUl-RUJNr-ik NNNNNNNNNr-dr-dr-dr-Ar-Ar-Ar-Ar-AHH OOQQU‘I-hUJNF-‘OKOOOQQU‘I-bUJNHO [] [X] [X] BY TELECOPIER: Service was effected 0n all parties at approximately_ am/pm by transmitting said document(s) from this firm's facsimile machine (818/559-4477) t0 the facsimile machine number(s) shown above. Transmission t0 said numbers was successful as evidenced by a Transmission Report produced by the machine indicating the documents had been transmitted completely and Without error. C.R.C. 2008(6), Cal. CiV. Proc. Code § 1013(6). BY ELECTRONIC SERVICE: By emailing true and correct copies t0 the persons at the electronic notification address(es) shown 0n the accompanying service list. The document(s) was/Were served electronically, and the transmission was reported as complete and without error. State: I declare under penalty of perjury under the laws 0f the State 0f California that the above is true and correct. Executed on October 28, 2020 in Burbank, California. /S/ Melissa Cruz Melissa Cruz