Free Response in Opposition to Motion - District Court of California - California

Case 3:08-cv-00021-JLS-BLM

Document 24-2

Filed 03/14/2008

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JAMES W. ALCANTARA - State Bar No.: 152747 Alcantara & Associates, APC 402 West Broadway, Suite 1170 San Diego, California 92101 Telephone: (619) 233-5900 Facsimile: (619) 233-5999 Email: [email protected] Attorneys for Plaintiff Gregory A. Strasburg,

Individually and as Trustee of the Gregory A. Strasburg Revocable Trust dated 4/8/2003

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA GREGORY A. STRASBURG, Individually and as Trustee of the GREGORY A. STRASBURG REVOCABLE TRUST dated 4/8/2003 Plaintiff, ) CASE NO.: 08CV0021 LJS (BLM) ) ) ) ) ) ) ) CERTIFICATE OF SERVICE ) ) ) ) ) ) ) ) ) )

13 v. 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Defendants. M/Y JUST A NOTION, Official Number 1089525, her engines, tackle, furniture and appurtenances, in rem; PETER BLAIR, in personam; JIM SINGLETON, in personam; and THE YACHT CLUB, LLC., a Nevada Corporation

I, Monique C. Rodrigue hereby certify and declare as follows: 1. 2. I am over the age of 18 years and not a party to this action. My business address is 402 West Broadway, Suite 1170, San Diego California

92101, which is located in the city, county and state where the mailing described below took place. 3. I am readily familiar with the practice of ALCANTARA & ASSOCIATES, APC

with respect to the collection and processing of pleadings, discovery documents, motions and all other documents which must be served upon opposing parties or other counsel in litigation. 4. The document described below was served by electronic filing and U.S. Mail on

March 14, 2008. -1Civil No.: 08CV0021 JLS (BLM) CERTIFICATE OF SERVICE

Case 3:08-cv-00021-JLS-BLM

Document 24-2

Filed 03/14/2008

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PLAINTIFF'S OPPOSITION TO DEFENDANTS' MOTION TO DISMISS THE SECOND, THIRD, FOURTH AND FIFTH CAUSES OF ACTION FOR FAILURE TO STATE A CLAIM UPON WHICH RELIEF CAN BE GRANTED (FRCP 12(b)(6), OR, IN THE ALTERNATIVE, MOTION FOR A MORE DEFINITE STATEMENT

5.

On March 14, 2008, I served the document described below by E-filing in

accordance with the rules governing the electronic filing and subsequent service of documents in the United States District Court in and for the Southern District of California. Notice will be electronically mailed to the following parties by and through their counsel of record: Douglas M. Field, Esq.: [email protected], [email protected] Attorney for Defendants: Yacht Club, LLC, Peter Blair and Jim Singleton 6. The document described above was also served by U.S. Mail, first-class, on March

14, 2008. I deposited in the United States Mail at San Diego, California, true and correct copies of the above-referenced documents addressed to counsel of record for Defendants Yacht Club, LLC, Peter Blair and Jim Singleton: Michael B. McDonnell, Esq. MCDONNELL & ASSOCIATES 2040 Harbor Island Drive San Diego, California 92101 Attorney for Defendants: Yacht Club, LLC, Peter Blair and Jim Singleton

I declare under penalty of perjury that the foregoing is true and correct. EXECUTED this 14th day of March 2008, at San Diego, California.

ALCANTARA & ASSOCIATES, APC

s/ Monique C. Rodrigue Monique C. Rodrigue

-2Civil No.: 08CV0021 JLS (BLM) CERTIFICATE OF SERVICE