Free Brief - District Court of California - California

Case 3:08-cv-01896-PJH

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Neil Gieleghem CSBN 107389 Gieleghem Law Office 1875 Century Park East, Suite 700 Los Angeles, CA 90067 Telephone: (310) 284-3252 Telecopier: (310) 284-3253 [email protected] Attorneys for Plaintiff Nicholas H. Parker

UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 11 12 13 14 15 16 17 18 19 20 TO THIS HONORABLE COURT, AND TO ALL PARTIES AND COUNSEL OF 21 RECORD: 22 PLEASE TAKE NOTICE that Plaintiff, subject to leave of Court, may address the 23 following additional legal authority in connection with the hearing of his Motion to Remand: 24 1. 25 p. 979. 26 \\\ 27 \\\ 28
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NICHOLAS H. PARKER, an individual,

) ) Plaintiff, ) ) vs. ) ) SCOTT MICHAEL MOORE, an individual; ) MOORE INTERNATIONAL LAW OFFICES, ) A PROFESSIONAL CORPORATION, a ) California corporation; MOORE ) INTERNATIONAL LAW OFFICES, A ) PROFESSIONAL CORPORATION, a business ) entity, form unknown; DOES 1 through 20, ) inclusive, ) ) Defendants. ) )

CASE NO. 3:08-CV-01896-PJH Hon. Phyllis J. Hamilton SUPPLEMENTAL AUTHORITY IN SUPPORT OF PLAINTIFF'S REPLY RE MOTION TO REMAND AND REQUEST FOR JUST COSTS AND ACTUAL EXPENSES OF $15,735.65 (REVISED) Date: Time: Courtroom: Wednesday, June 4, 2008 9:00 a.m. Courtroom 3, 17th Floor

9 Witkin, Summary of California Law (10th ed., 2008 supp.) Corporations , § 212,

SUPP. AUTHORITY RE REPLY RE PLAINTIFF'S MOTION TO REMAND, ETC., CASE NO. 3:08-CV-01896-PJH

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For the convenience of the Court and parties, a Westlaw printout of said authority is attached.

Dated: May 27, 2008

GIELEGHEM LAW OFFICE

s/ Neil Gieleghem Neil Gieleghem Attorneys for Plaintiff Nicholas H. Parker

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SUPP. AUTHORITY RE REPLY RE PLAINTIFF'S MOTION TO REMAND, ETC., CASE NO. 3:08-CV-01896-PJH

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PROOF OF SERVICE STATE OF CALIFORNIA COUNTY OF LOS ANGELES ) ) ss. )

I am a resident of the State of California; over the age of 18 years; and not a party to the within action; and my business address is: 1875 Century Park East, Suite 300, Los Angeles, California 90067. On May 27, 2008 I served the foregoing document described as: SUPPLEMENTAL AUTHORITY IN SUPPORT OF PLAINTIFF'S REPLY RE MOTION TO REMAND AND REQUEST FOR JUST COSTS AND ACTUAL EXPENSES OF $15,735.65 (REVISED) [] (BY MAIL ) By placing the true copies of the document(s) listed above in a sealed envelope, fully prepaid, addressed to the recipient(s) listed below. I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. Under that practice it would be deposited with U.S. postal service on that same day with postage thereon fully prepaid at Los Angeles, California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in said affidavit. (BY FAX) By transmitting, on this date, via facsimile, the document(s) listed above to the fax number(s) set forth above. (BY EXPRESS MAIL) By placing the document(s) listed above in a sealed Federal Express envelope and affixing a pre-paid air bill, and causing the envelope to be delivered to a Federal Express agent for delivery. (BY ELECTRONIC TRANSMISSION) By transmitting via electronic mail the document(s) listed above to each recipient listed below (via PACER system). (BY PERSONAL SERVICE) I delivered such envelope by hand to the office of the addressee.

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Scott Michael Moore, Esq. Moore International Law Offices, P.C. 45 Rockefeller Plaza, Suite 2000 (630 5th Avenue, Suite 2000) New York, New York 10111 Tel: (212) 322-3474 Fax: (212) 332-3475 [email protected] Attorneys for Defendants I declare under penalty of perjury under the laws of the State of California, and the United States of America, that the above is true and correct. Executed on May 27, 2008, in Los Angeles, CA.

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s/ Neil Gieleghem Neil Gieleghem

SUPP. AUTHORITY RE REPLY RE PLAINTIFF'S MOTION TO REMAND, ETC., CASE NO. 3:08-CV-01896-PJH

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