Benjamin v. Google Inc. Doc. 45

Transcription

1 Benjamin v. Google Inc. Doc. 0 0 FEDERICO CASTELAN SAYRE, ESQ. SBN 00 KENT M. HENDERSON, ESQ. SBN 0 HECTOR E. SALITRERO, ESQ. SBN 0 LAW OFFICES OF FEDERICO CASTELAN SAYRE E-FILED //0 00 North Broadway, th Floor Santa Ana, CA 0 ( 0- ( 0- fax Attorneys for Plaintiffs, Catalina Rodriguez Barcenas, Ines Barcenas-Silva, Amada G. Barcenas and Hipolito Martinez UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE BRANCH CATALINA RODRIGUEZ BARCENAS, INES BARCENAS- SILVA, AMADA G. BARCENAS, and HIPOLITO MARTINEZ, vs. Plaintiffs, FORD MOTOR COMPANY, a Delaware corporation;, INC., an Ohio corporation; and DOES through 0, Inclusive, Defendants. CASE NO. C0 0 RMW (EAI DECLARATION OF KENT M. HENDERSON IN SUPPORT OF SUPPORT OF PLAINTIFF S MOTION IN LIMINE TO EXCLUDE EVIDENCE REGARDING SUBSEQUENT NEGLIGENT TREATMENT [Filed Concurrently with Supporting Documents.] Pre-Trial Conference: March, 00 Time: :00 p.m. Courtroom: Judge: Ronald M. Whyte TRIAL DATE: MARCH, 00 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD HEREIN: \\\ C:\staging\FEC-0A-0FD\in\FEC-0A-0FD.doc Dockets.Justia.com

2 C:\staging\FEC-0A-0FD\in\FEC-0A-0FD.doc 0 I, Kent M. Henderson, do hereby declare and state as follows:. I am an attorney at law duly licensed to practice before all courts of the State of California and before the United States District Court for the Northern District of California. The facts stated in this declaration are of my own personal knowledge and/or I am informed and believe they are true and if called and sworn as a witness, I could and would competently testify thereto. I am an associate attorney with the Law Offices of Federico C. Sayre, counsel for the Plaintiffs in the above-entitled action.. Attached hereto and labeled as Exhibit No. are true and correct copies of pages from the deposition of CHP Office Steven Pierce. I declare under the penalty of perjury that foregoing is true and correct and that this declaration is executed on the th day of February 00 at Santa Ana, California. /S/ KENT M. HENDERSON Kent M. Henderson, Declarant 0

3 C:\staging\FEC-0A-0FD\in\FEC-0A-0FD.doc 0 0 PROOF OF SERVICE I, the undersigned, declare that I am a citizen of the United States of America and a resident of and/or am employed in the County o Orange, State of California. I am over the age of eighteen years and not a party to the within action. My business address is 00 North Broadway, th Floor, Santa Ana, California 0. On February, 00, I served the foregoing document, entitled IN SUPPORT OF SUPPORT OF MOTION IN LIMINE TO EXCLUDE EVIDENCE COMPARATIVE FAULT on the interested parties to this action by placing true copies thereof enclosed in sealed envelopes addressed as follows: [SEE ATTACHED SERVICE MAILING LIST] [X] BY MAIL: 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 Santa Ana, California, in the ordinary court 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 affidavit. [X] FEDERAL: I declare under penalty of perjury that I am employed in the office of a member of the bar of this Court at whose direction the service was made. [ ] STATE: I declare under penalty of perjury under the laws of the State of California that the above is true and correct. EXECUTED on February, 00, at Santa Ana, California. /S STEPHANIE LUNA Stephanie Luna

4 C:\staging\FEC-0A-0FD\in\FEC-0A-0FD.doc 0 0 BARCENAS, et al vs. FORD MOTOR COMPANY, et al U.S.D.C. NORTHERN DIVISION CASE NO: C0 0 RMW (EAI SERVICE MAILING LIST Client File No:.00 Patrick J. Becherer Angus MacLeod BECHERER KANNETT & SCHWEITZER 00 Powell Street, Suite 0 Emeryville, CA 0 Phone (0-00 Fax (0 - Associated Counsel for Defendant David M. McLaughlin ROPERS, MAJESKI KOHN & BENTLEY 00 Marshall Street Redwood City, CA 0 Phone (0-00 Fax (0 0-0 Scott Edwards HARTLINE DACUS BARGER DREYER & KERN LLP North Central Expressway, Suite 000 Dallas, TX 0 -- NORTH Marc R. Brosseau KERR BROSSEAU BARTLETT O'BRIEN 00 Broadway Suite 00 Denver, CO Richard H. Schliem, III YOCKEY YOCKEY & SCHLIEM, P.C. West Mile Road Farmington Hills, MI --00

5 C:\staging\FEC-0A-0FD\in\FEC-0A-0FD.doc 0 0 Susan T. Dwyer HERRICK FEINSTEIN Park Avenue New York, NY Thomas R. Woodrow HOLLAND & KNIGHT South Dearborn Street Chicago, Il Attorneys for Defendant FORD MOTOR COMPANY Ashley Day, Esq. Janice K. O Grady, Esq. BOWMAN & BROOKE, LLP Technology Dr. Suite 00 San Jose, CA 0 Phone (0 - Fax (0 - Attorneys for Defendant FORD MOTOR COMPANY Robert J. Gibson /D. Rodman SNELL & WILMER LLP 0 Main Street, Ste. 00 Irvine, CA -0 Phone ( -00 Fax ( -0 Attorneys for Plaintiffs Fernando Chavez Thomas A. Brill Douglas A. Gessell LAW OFFICES OF SAYRE & CHAVEZ J Street, Suite 0 Sacramento, CA Phone ( - Fax ( -0