Case :-cv-0-sb Docment Filed /0/ Page of Mary-Alice Coleman (SBN: Dianne Schambrg (SBN: 00 LAW OFFICES OF MARY-ALICE COLEMAN, P.C. Kennedy Place, Site Davis, California Telephone:.. Facsimile:.0.00 Attorneys for Plaintiff, ANDI BARONE l ANDI BARONE, Plaintiff, v. UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA Case No.: :-CV-0-SB PLAINTIFF'S NOTICE OF ACCEPTANCE OF RULE OFFER OF JUDGMENT COUNTY OF LASSEN; CALIFORNIA JUDICIAL COUNCIL; CALIFORNIA ADMINISTRATIVE OFFICE OF THE COURTS; TONY R. MALLERY; and DOES -, INCLUSIVE, Defendants. Complaint Filed: September, Trial Date: None Set TO DEFENDANTS AND THEIR RESPECTIVE COUNSEL OF RECORD: PLEASE TAKE NOTICE that Plaintiff ANDI BARONE accepts the offer of jdgment served on her by D efendant COUNTY OF LASSEN on December,, to allow a jdgment to be entered in favor of Plaintiff and against Defendant SUPERIOR COURT in the sm of $0,00, pls all costs of sit incrred to the - - PLAINTIFF'S NOTICE OF ACCEPTANCE OF RULE OFFER OF JUDGMENT Barone v. Sperior Cort of California, Conty of Lassen, et al. Case No.: :-CV-0-SB
Case :-cv-0-sb Docment Filed /0/ Page of date of said defendant's offer, inclding reasonable attorney fees and expert fees where recoverable as costs nder statte, bt exclding any attorney fees or costs of sit incrred thereafter, and withot injnctive or other eqitable relief, in fll satisfaction of all federal and state claims in this action against all Defendants. A tre and correct copy of Defendant SUPERIOR COURT' s Rle Offer of Jdgment is attached hereto as Exhibit "A." Date: December 0, i:i.; ~- N...i ~ ~ '... 0 ' U en Lt' e w' i -...i j.. 0 >< >< ~ ~ [il < ~ 0 I"< z w ~ fl~< e~o - ~... 0 ~,..J ~LICE COLEMAN, ESQ. SCHAUMBURG, ESQ. Att neys for Plaintiff, ANDI BARONE - - PLAINTIFF'S NOTICE OF ACCEPTANCE OF RULE OFFER OF JUDGMENT Barone v. Sperior Cort of California, Conty of Lassen, et al. Case No.: :-CV-0-SB
Case :-cv-0-sb Docment Filed /0/ Page of p.; ~' ~ \0,..J t::. rl 0 ::> \0 U lo ~ w i ::l : p... 0 ~ ~ ~ ~ c... ~ ' 0 } ;; "' ' < tl ~ 0 el rl 0 j EXHIBIT A ~~~~~~~~~~~~~~~~~,
Case :-cv-0-sb Docment Filed /0/ Page of CAROLEE G. KILDUFF, ESQ., SB No. Email: ckildff@akk-law.com ANGELO, KILDAY & KILDUFF, LLP Attorneys at Law 0 University Avene, Site 0 Sacramento, CA Telephone: ( -0 Telecopier: ( - Attorneys for Defendant COUNTY OF LASSEN UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA ANDI BARONE, vs. Plaintiff, COUNTY OF LASSEN; CALIFORNIA JUDICIAL COUNCIL; CALIFORNIA ADMINISTRATIVE OFFICE OF THE COURTS; TONY R. MALLERY; and DOES -, inclsive, Defendants. ~~~~~~~~~~~~~~ TO THE PLAINTIFF AND HER COUNSEL OF RECORD: Case No.: :-cv-0-sb DEFENDANT SUPERIOR COURT OF CALIFORNIA, COUNTY OF LASSEN'S RULE OFFER OF JUDGMENT Defendant Sperior Cort of California, Conty of Lassen [and Defendant Tony R. Mallery] hereby offer to allow entry of jdgment prsant to Rle of the Federal Rles of Civil Procedre as follows: Jdgment in favor of Plaintiff Andi Barone against Sperior Cort S in the sm of $0,00, pls all costs of sit incrred to the date of this offer inclding reasonable attorney fees and expert fees where recoverable as costs wider statte, bt exclding any attorney fees or costs of sit incrred thereafter, and withot injnctive or other eqitable relief. This offer of jdgment is made for the prposes specified in Rle, and is not to be -- DEFENDANT COUNTY OF LASSEN'S RULE OFFER OF JUDGMENT
Case :-cv-0-sb Docment Filed /0/ Page of constred as an admission of liability. This jdgment shall be in fll satisfaction of all federal and state law claims or rights that Plaintiff may have to damages. or any other form of relief, arisjng ot.of the fi}leged acts or omissions of Sperior Cort of California, Conty of Lassen and Defendant Tony R. Mallery in connection with the alleged facts, and GirG.mstancses that are the sbject of this action. Acceptance. of the offer will act to release and discharge both.. defendants the Sperior Cort of California, Conty Of Lassen. and Tony R. Mallery from any and all claims that were or cold have been aileged by Plaintiff in the above-referenced action. The amont of costs and fees shall be agreed pon by the parties within 0 days of the O acceptance of this offer or, if the parties do not timely agree on the amont, will be determined by the. district cort pon a motion to be tiled by Plaintiff no later than 0 days from the date of acceptance of this offer. Dated: December,. Attorneys for Def enda:nt COUNTY OF LASSEN Dated: December, OFFICE OF THE ATTORNEY GENERAL z -- DEFENDANT COUNTY OF LASSEN'S RULE OFFER OF JUDGMENT
Case :-cv-0-sb Docment Filed /0/ Page of. COURT: CASE NO. CASE NAME: USDC-ED :-cv-0-tln-cmk. Barone v.. Sperior Cort of California, et al. PROOF OF SERVICE I am a citizen of the United States, employed in the Conty of Sacramento, State of California. My bsiness address is 0 University Avene, Site 0, Sacramento, California. I am over the age of years and not a party to the above-entitled action. On December,, I cased the within DEFENDANT SUPERIOR COURT OF CALIFORNIA, COUNTY OF LASSEN'S RULE OFFER OF JUDGMENT, the original of which was prodced on recycled paper, to be served via MAIL--- I am readily familiar with Angelo, Kilday & Kildffs practice for collection and processing of correspondence for mailing with the United States Postal Service. Prsant to said practice, each docment is placed in an envelope, the envelope is sealed, the appropriate postage is placed thereon and the sealed envelope is placed in the office mail receptacle. Each day's mail is collected and deposited in a U.S. mailbox at or before the close of each day's bsiness. (Code Civ. Proc. section a( or Fed.R.Civ.P. (a and.; USDC (E.D. CA L.R. -(a. I placed in the United States Mail at Sacramento, California in an envelope with postage thereon flly prepaid addressed as follows: Mary-Alice Coleman Dianne Schambrg Law Offices of Mary-Alice Coleman Kennedy Place, Site Davis, CA I declare that I am employed in the office of a member of the bar of this Cort at whose direction the service was made. I declare nder penalty of perjry nder the laws of the United States of America that the above is tre and correct. Exected on December, at Sacramento, California. -- DEFENDANT SUPEIUOR COURT OF CALIFORNIA, COUNTY OF LASSEN'S RULE OFFER OF JUDGMENT
Case :-cv-0-sb Docment Filed /0/ Page of p.; z' ~ N,..J ~ ~ '... 0 (./' ' II ~ ' ' ~ < -,..J :s ~ ~ p... 0,... >-<!!:I,,.; Cl,..J < ~ <... ~ ~ ~ z 0 ~ > <I ' < ~oo... tt:... 0 ~ <...i Barone v. California Sperior Cort, Conty of Lassen, et al. United States District Cort, Eastern District of California Case No.: :-CV-0-SB CERTIFICATE OF SERVICE MAIL I, the ndersigned declare that I am employed in the Conty of Yolo, State of California. I am over the age of eighteen ( years and not a party to the within action; my bsiness address is: Kennedy Place, Site, Davis, CA. On December 0,, I served the within: PLAINTIFF'S NOTICE OF ACCEPTANCE OF RULE OFFER OF JUDGMENT By placing a tre copy thereof enclosed in a sealed envelope with prepaid postage thereon flly prepaid for deposit in the United States Post Office mail box, at my bsiness address shown above, following the Law Offices of Mary Alice Coleman, P.C.' s ordinary bsiness practices for the collection and processing of correspondence for mailing, of which I am readily familiar, to the individals and addresses as set forth below. M.s. Carolee G. Kildff, Esq. ANGELO, KILDAY & KILDUFF, LLP 0 University Avene, Site 0 Sacramento, CA Mr. Peter D. Halloran, Esq. CA DEPARTMENT OF JUSTICE 00 I Street, Site Sacramento, CA Attorney for Defendant, COUNTY OF LASSEN Attorney for Defendant, TONY R. MALLERY I declare nder the penalty of perjry nder the laws of the State of California that the foregoing is tre and correct, and that this declaration was exected on December 0,, in Davis, California. t:if#ir Paralegal - - PROOF OF SERVICE