Notice of Joinder In Motion To Vacate Order of April 22, 2016

Motion

Cal. Super. - 1st Dist.February 25, 2016

N O 6 0 3 O N U n A W N N O N N N M N N N N N N N N N - = e m e m m d p m p d m d p d p m 0 N N A N b n A W N = O D O N N N B R A W L N D - ~ R , D Robert S. Niemann (87973) niemann@khlaw.com KELLER AND HECKMAN, LLP Three Embarcadero Center, Suite 1420 San Francisco, CA 94111 Telephone: 415 948 2831 Facsimile: 415 948 2808 Attorney for ESTATE OF EDWARD BLAND IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO POODLES, INC., a California corporation, NO. CGC 16-550634 Plaintiff, VS. NOTICE OF JOINDER IN MOTION TO ROGER C. KUHN,et al., VACATE ORDER OF APRIL 22, 2016 Defendants. Hearing Date: October 25, 2018 Time: 9:30 AM Dept: 501 Trial Date: None slsNOTICE OF JOINDER IN MOTION TO VACATE ORDER OF APRIL 22, 2016 N O O0 0 N O N W h A W N N N N N N N N N N N N = m m e m e m e d e m a a 0 0 I A N n n A W N = D O O O 0 0 N D D W N O m , To all parties and their attorneys ofrecord: Please take notice that Defendant, the Estate of Edward Bland, hereby joins those defendants who seek to vacate the order entered in this motion of April 22, 2016 set for hearing on October 25, 2018. In order to avoid burdening the court with repetitive briefing, the Estate of Edward Bland incorporated by reference the Notice of Motion, Memorandum of Points and Authorities, Declaration of Paul Perdue, and Defendant’s Request for Judicial Notice as though fully set forth herein The Estate of Edward Bland also joins in the Reply Brief filed by the defendants as though fully set forth herein. The same claims, arguments, and evidence presented in the motions and briefs filed by Defendant’s apply with equal force to the issues relating to the Estate of Edward Bland. Dated: October 15,2018 Respectfully Submitted, KELLER AND HECKMAN LLP By: /s/ Robert S. Niemann Robert S. Niemann Attorney for Defendant Estate of Edward Bland oO NOTICE OF JOINDER IN MOTION TO VACATE ORDER OF APRIL 22,2016 N O 0 9 O N n n A W N R N N N D N N N N N N m m m m e d e m p m m d e d e d X X 9 O N n n BA A W N = O O O d N R W N = PROOF OF SERVICE I am over the age of eighteen years and not a party to this action. I am a resident of the State of California and am employed in the County of San Francisco. My business address is Keller and Heckman LLP, Three Embarcadero Center, Suite 1420, San Francisco, CA 94111. On October 15, 2018, I served a true and correct copy of the document(s) described below on the parties and/or their attorney(s) of record to this action in the manner indicated: NOTICE OF JOINDER IN MOTION TO VACATE ORDER OF APRIL 22,2016 SERVICE METHOD U.S. MAIL: | am employed in the county where the mailing occurred. Iam readily familiar with this firm’s practicefor collection and processing of correspondence for mailing with the United StatesPostal Service. In the ordinary course of business, such correspondence is deposited with the United States Postal Service in a sealed HGP or package that same day with first-class postage thereon fully prepaid. On the date indicated above, I laced the document(s) listed above in a sealed envelope or package with irst-class postage thereon fully prepaid, and placed the envelope or package for collection and mailing today with the United States Postal Service at San Francisco, California addressed as set forth above. The address(es) shown is/are the same as shown on the envelope or package. I am aware that on motion of the party served, service is presumed invalid if the postal cancellation date orpostage meter date is more than one day after date of deposit for mailing in the affidavit. CCP §§ 1013(a)-(b), 1013a, FRCP § 5(b), FRAP §§ 5(c)-(d). 3. NOTICE OF JOINDER IN MOTION TO VACATE ORDER OF APRIL 22, 2016 N O 0 3 O N n n A A W O N = N N D N D N N N N N N N - m m e k e m p a e m e a e m e m p e 0 J O N n n b h W N = O V U W N D R A W N N D ~ = , D To: COUNSEL Micah Jacobs Jacobs Law Group SF 388 Market Street Suite 1300 San Francisco, CA 94111-5316 Ellis Ross Anderon Jamie C. Couche Anderson & Poole, P.C. 601 California Street, #1300 San Francisco, CA 94108 Randi Austell 64597 Spyglass Ave. Desert Hot Springs, CA 92240 Norman Green Saratoga Retirement Community 14500 Fruitvale Avenue, Saratoga, CA 95070 Executed on October 15, 2018, at San Francisco, California. EEE Kav ali 4- NOTICE OF JOINDER IN MOTION TO VACATE ORDER OF APRIL 22, 2016