MEMO
TO: Clerk of Court
Superior Court of California
San Diego County
330 West Broadway
San Diego 92101-3827
CALIFORNIA, USA
FROM: Paul Andrew Mitchell, Plaintiff
Mitchell
v. AOL Time Warner, Inc. et al.
Case Number: GIC807057
DATE: April 30, 2003 A.D.
SUBJECT: enclosed MOTION FOR PRELIMINARY INJUNCTION
BARRING REMOVAL INTO FEDERAL COURT
Dear Clerk:
Please consult first with the assigned judge in the above entitled case, before assigning a hearing date and time for this MOTION.
The sheer number of named defendants (120), and their widespread geographic distribution, have generated extraordinary complexity in our clerical workload.
After round one of mailing our SUMMONS and COMPLAINT to all named Defendants, not one California Defendant has executed the form that we provided for acknowledgment of receipt. See CCP 415.30 and the attached template letter that was customized for each Defendant.
Thus, each of these Defendants will now need to be formally served, further delaying a hearing date on this MOTION.
Also, our FIRST SUPPLEMENT will follow immediately on the heels of the enclosed MOTION TO BAR REMOVAL. It is bulky, and it deserves a separate docket entry.
Thank you in advance for your kind assistance in this routine matter.
Sincerely yours,
/s/ Paul Andrew Mitchell
Paul Andrew Mitchell, B.S., M.S.
Private Attorney General and Plaintiff
enclosure: MOTION FOR PRELIMINARY INJUNCTION BARRING REMOVAL
copy: Hon. Janis Sammartino, Superior Court Judge (assigned)
Hon. Richard E.L. Strauss, Presiding Judge
Kay Rowland, Notary Public and Agent for PROOF OF SERVICE