Case 3:07-cv-04778-CRB
Document 10
Filed 12/14/2007
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{ICHAEL G. MILLER (SBN: 136491) tLLR. RAVITCH (SBN: 129787) ERRY. JOHNSON. ANDERSON &MOSKOWITZ, LLP 38 First Street, Fourth Floor Office Box 1028 Rosa, CA 95402-1028
elephone: (707) 525-8800 acsimile: (707) 545-8242
omeys for
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Plaintiff
GENEMOORE
LTNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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GENEMOORE,
CASE NO.: C 07-04778 CRB
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Plaintiff,
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PLAINTIFF EUGENE MOORE'S INITIAL DISCLOSURES (FRCP 26(aXl))
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.,
MANHATTAN MORTGAGE AND Does I through 50,
Defendants.
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Plaintiff EUGENE MOORE hereby submits the following initial disclosures pursuant to
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.R.C.P. Rule 26 (f):
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Eugene Moore
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Lori Cady
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Debbie A1len 24 Denise Beeson
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Jamin Foster 26 Randy Blackenbaker 27
Joseph Myers
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Plaintiff Eueene Moore's Initial Disclosures
Case 3:07-cv-04778-CRB
Document 10
Filed 12/14/2007
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Robeft E. Neale
Rose Story
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Dixie Myers
Patty Ensrud Shan¡on Kilkemy person most knowledgeable from Defendant chase regarding which clients ofPlaintiff
contacted.
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Greeting card and envelope sent to Denise Beeson by Chase Manhattan Mortgage
on
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Greeting card and enclosure card sent to Joseph Myers by Chase Ma¡latten
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ortgage Corporation.
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Plaintiff seeks damages, including future damages, exemplary damages, attomeys' fees,
re-judgement interest, and cost ofsuit, as well as restitution ofall moneys received as a result
,s
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of
alleged conduct. Plaintiff is ìn process of compiling information regarding damages and
provide further detail upon receipt.
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Not Applicable Plaintiff cerlihes to the best of their knowledge, information, and belief' that the
losure is complete and correct as of the time it was made. Plaintiff further. when information is leamed. December 14,2007
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wiil
amend this
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PERRY. JOHNSON. ANDERS ON
MILLER&MOSKO
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Case 3:07-cv-04778-CRB
Document 10
Filed 12/14/2007
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PROOF OF SERVICE
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I declare
as follorvs:
I am employed byPERRY, JOHNSON, ANDERSON, MILLER & MOSKOWITZ, LLP,
whose address is 438 First Street, Fourth Floor, P.O. Box 1028, Santa Rosa, CAg5402-f028.
am over the age
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of
18 years, and not a party to the
within action.
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On December
14,2007,I
serwed the attached document(s) described as:
PLAINTIFF EUGENE MOORI'S INITIAL DISCLOSURI'S (FRCP 26(a)(1)
on the interested parlies in said cause, as follows:
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Robert S. Shwarts, Esq. Amira B. Day, Esq. Orrick, Henington & Sutcliffe LLP 405 Howard Street San Francisco, CA 94105
Attomeys for Defendant
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By Regular U.S. Mail. The documents were placed for collection and mailing, following
ordinary business practice for deposit in the United States Postal Service, in a sealed envelope,
with the postage thereon fully prepaid, addressed
as stated above.
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By personal service. I caused each such envelope to be delivered by hand to the
addresseels) as stated above.
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By facsimile or telecopier transmitted from (707) 545-8242. The document transmission
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was reporled as complete and without error.
Receiving fax number:
Time of transmission:
rs
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A copy of the transmission report properly issued by the transmitting facsimile machine
attached to the original of this proof of service.
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I declare under penalty of perjury under the laws of the State of Califomia that the
foregoing is true and correct, and that this declaration was ex
on December 14,2001
at
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Santa Rosa, California.
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