Free Declaration in Support - District Court of California - California

Case 4:07-cv-04786-CW
(

Document 2

Filed 09/17/2007
( ,

Page 1 of 2

I

HANSON BRlDGETT MARCUS VLAHOS & RUDY, LLP

WILLlAM D.TAYLOR- JJ4449
2
3

CHRISTINA M. NUGENT - 199646 980 Ninth Street, Suite 1500 Sacramento, CA 95814
Telephone: (916) 442-3333 Facsimile: (916) 442-2348
!¡ ;:

O~18GHNAL
§ II

4
5

cn ugent(qansonbrid gett. com

FfLFO

Attorneys for Defendant
6

SEP 1 7 Z007

CENT~\L TRANSPORT

7
8

NORTHERN oi~T~Ii;,TRICT COURT
ICT OF CALIFORNI/l

ClEAK. U. c" iVEl\/i\lG

RICHARD W \.

UNITED STATES DISTRICT COURT

9 10
11

FOR THE NORTHERN DISTRICT OF CALIFORNIA

TIlE FLESH COMPANY,
12

c

"i")" ¡"'''~!

í1 i~ "'¡~

Yse Ño.

i" fit ;: '""J ~

'ii A' ~o"i /i? ~'f~ 8' "

íí

, Plaintiff,
13

DECLARATION OF CHRISTINA I
NUGENT IN SUPl)ORT OF DEFENDANT

C

v.
14

CENTRAL TRANSPORT'S NOTICE OF !
REMOVAL OF ACTION )'URSUANT TO 28l).S.C. §§ 1331 (Federal Question) and
1337

PRINTJNG STRATEGY, me.
15

Defendant.
J6

, J7
18

PRINTING STRATEGY, INC.,
l'' ~ pI'

20 v.
24

19

Cross-complainant,

il~ii \~

f~~ ¿L\i.)(

21 BEST WAY FREIGHT COivlPANY; CENTRAL TRANSPORT; and THE 22 FLESH COMPANY, and DOES 1-20,

23 Cross-defendant.

25 III 26 III 27 III 28 III
DECL or CHRISTINA NUGENT 1N SUPPORT OF DEFENDANT CENTRAL
TRANSPORT'S NOTICE OF REMOV AL OF ACTlON PURSUANT TO 28 U.S.C. § 1331 (FEDERAL QUESTlON)
IJ54885,I

Case 4:07-cv-04786-CW
(
\

Document 2

Filed 09/17/2007
(

Page 2 of 2

1

I, CHRISTINA NUGENT, declare:
1.

2

I am licensed to practice law in the state of California, and I am an attorney with

3 the law firm Hanson, Bridgett, Marcus, Vlahos & Rudy LLP, attorneys of record for Defendant
4 Central Transport herein. I make this declaration on my own personal knowledge and, if called as
5 a witness, I could and would testify competently as to these facts.

6

2.

After receiving service of the Cross-complaint in the state court action entitled The

7 Flesh Company v. Printing Strategy, Inc., Superior Court ofthe State of California, Napa County,
8 Case No. 26-34438, and related Cross-complaint, my office telephoned the Clerk of

the Court for

9 Napa County Superior Court on September 13, 2007, to inquire as to whether any proof of service
i 0 relating to cross-defendant BestW ay Freight Company had been filed with the Court by Crossi i complainant. The Clerk responded that no such proof of service had been filed.

12
13

3.

On September 13,2007, and again on September 17,2007, my offce contacted the

office of counsel for Cross-complainant Printing Strategy, Inc. to inquire as to whether Cross-

14
15

defendant Best Way Freight Company had been served with the Cross-complaint. On
September 13, a woman called Lois indicated that she did not know whether Best Way Freight

16 17
18

Company had been served, but would return the call. On September 17, Lois indicated that her
fie did not contain a

proof of service for Best Way Freight Company, but that she would confirm

the same with her supervising attorney.

19

I declare under penalty of perjury under the laws of the State of California and the United States of America that the foregoing is true and correct and that this declaration was executed this
17th day of September, at Sacramento, California.

20
21

22
23

24
25

~

26

28 - 2 27

DECL. OF CHRISTINA NUGENT IN SUPPORT OF DEFENDANT CENTRAL TRANSPORT'S NOTICE OF REMOVAL OF ACTION PURSUANT TO 28 U.S.C. § 1331 (FEDERAL QUESTION)

1354885.1