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No. S203735

(Court of Appeal No. H038014)

(Santa Clara County Superior Ct. No. 1-00-CV-788657) IN THE SUPREME COURT OF THE STATE OF CALIFORNIA

ATLANTIC RICHFIELD COMPANY, CONAGRA GROCERY PRODUCTS CO., E.I. DU PONT DE NEMOURS AND CO., NL INDUSTRIES, INC.,

AND THE SHERWIN-WILLIAMS COMPANY

Petitioners,

v.

THE SUPERIOR COURT OF THE STATE OF CALIFORNIA, IN AND FOR THE COUNTY OF SANTA CLARA,

Respondent,

THE PEOPLE OF THE STATE OF CALIFORNIA, ET AL.

Real Parties in Interest.

ANSWER TO PETITION FOR REVIEW

OFFICE OF THE COUNTY COUNSEL

COUNTY OF SANTA CLARA LORI E. PEGG (SBN 129073) GRETA S. HANSEN

(SBN 251471)

JENNY S. LAM (SBN 259819) 70 West Hedding Street

East Wing, 9th Floor San Jose, CA 95110

Telephone: (408) 299-5900 Facsimile: (408) 292-7240

Attorneys for Real Parties in

Interest The People of the State of

California

COTCHETT, PITRE & McCARTHY, LLP NANCY L. FINEMAN (SBN 124870) ARON K. LIANG (SBN 228936) BRIAN M. SCHNARR (SBN 275587)

840 Malcolm Road, Suite 200 Burlingame, CA 94010 Telephone: (650) 697-6000 Facsimile: (650) 697-0577

Attorneys for Real Parties in Interest

The People of the State of California

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SAN FRANCISCO CITY ATTORNEY

Dennis J. Herrera (SBN 139669) City Attorney

Owen J. Clements (SBN 141805) Chief of Special Litigation Erin Bernstein (SBN 231539) Deputy City Attorney

1390 Market Street, Sixth Floor San Francisco, CA 94102 Telephone: (415) 554-3800 Facsimile: (415) 554-3837

Attorneys for Real Parties in Interest The People of the State of California

MARY ALEXANDER & ASSOCIATES

Mary Alexander (SBN 104173) Jennifer L. Fiore (SBN 203618) Sophia Aslami (SBN 262712) 44 Montgomery Street, Suite 1303 San Francisco, CA 94104

Tel: (415) 433-4440 Fax: (415) 433-5440

Attorneys for Real Parties in Interest The People of the State of California

OFFICE OF THE COUNTY COUNSEL ALAMEDA COUNTY

Donna R. Ziegler, County Counsel (SBN 142415)) Andrew Massey, Deputy County Counsel (SBN 240995)

1221 Oak Street, Ste 450 Oakland, CA 94612-4296 Telephone: (510) 272-6700 Facsimile: (510) 272-5020

Attorneys for Real Parties in Interest The People of the State of California

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LOS ANGELES COUNTY COUNSEL John F. Krattli (SBN 82149) County Counsel Richard K. Mason (SBN 55055) Robert E. Ragland (SBN 175357) Andrea Ross (SBN 179398) Principal Deputy County Counsel 500 West Temple St, Suite 648 Los Angeles, CA 90012

Tel: (213) 974-1928 Fax: (213) 680-2165

Attorneys for Real Parties in Interest The People of the State of California

OFFICE OF THE COUNTY COUNSEL COUNTY OF MONTEREY

Charles J. McKee, County Counsel (SBN 152458) William M. Litt, Deputy County Counsel (SBN 166614)

168 West Alisal Street 3rd Floor Salinas, CA 93901

Telephone: (831) 755-5045 Facsimile: (831) 755-5283

Attorneys for Real Parties in Interest The People of the State of California

OAKLAND CITY ATTORNEY

Barbara Parker, City Attorney (SBN 69722) William E. Simmons (SBN 121266)

One Frank H. Ogawa Plaza, 6 th Floor Oakland, California 94612

Telephone: (510) 238-3601 Facsimile: (510) 238-6500

Attorneys for Real Parties in Interest The People of the State of California

OFFICE OF THE CITY ATTORNEY CITY OF SAN DIEGO

Jan I. Goldsmith, City Attorney (SBN 70988)

Daniel F. Bamberg, Chief Deputy City Attorney (SBN 60499) Paul F. Prather, Deputy City Attorney (SBN 252985)

1200 Third Avenue # 1100 San Diego, CA 92101 Telephone: (619) 236-6220 Facsimile: (619) 236-7215

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OFFICE OF THE COUNTY COUNSEL COUNTY OF SAN MATEO

John C. Biers, County Counsel (SBN 144282)

Rebecca M. Archer, Deputy County Counsel (SBN 202743) 400 County Center Sixth Floor

Redwood City, CA 94063 Telephone: (650) 363-4760 Facsimile: (650) 363-4034

Attorneys for Real Parties in Interest The People of the State of California

OFFICE OF THE COUNTY COUNSEL SOLANO COUNTY

Dennis Bunting, County Counsel (SBN 55499) 675 Texas Street, Ste 6600

Fairfield, CA 94533

Telephone: (707) 784-6140 Facsimile: (707) 784-6862

Attorneys for Real Parties in Interest The People of the State of California

OFFICE OF THE COUNTY COUNSEL COUNTY OF VENTURA

Leroy Smith, County Counsel (SBN 107702)

Eric Walts, Assistant County Counsel (SBN 233042) 800 S. Victoria Avenue L/C #1830

Ventura, CA 93009

Telephone: (805)654-2580 Facsimile: (805)654-2185

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O

CERTIFICATE OF INTERESTED ENTITIES OR PERSONS CAL. R. CT. 8.208

Since all Plaintiffs are governmental entities, there are no interested entities or parties to list in this Certificate per California Rules of Court, Rule 8.208(d).

I declare under penalty of perjury under California law that the foregoing is true and correct.

Dated: July 23, 2012

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TABLE OF CONTENTS

Page(s)

CERTIFICATE OF INTERESTED ENTITIES OR PERSONS

INTRODUCTION AND SYNOPSIS OF ARGUMENT 1

BACKGROUND 2

LEGAL DISCUSSION 2

CONCLUSION 6

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TABLE OF AUTHORITIES

Page(s) CASES

People ex rel. Sorenson v. Randolph

(1979) 99 Cal. App. 3d 183 5

People v. Bhakta

(2008) 162 Cal.App.4th 973 3, 5

People v. Englebrecht

(2001) 88 Cal.App.4th 1236 3, 5

People v. Frangadakis

(1960) 184 Cal.App.2d 540 3, 5

People v. One 1941 Chevrolet Coupe

(1951) 37 Cal.2d 283 4

Schneider v. Schneider

(1947) 82 Cal.App.2d 860 4

Wolford v. Thomas

(1987) 190 Cal.App.3d 347 3, 5

STATUTES AND RULES California Rules of Court

Rule 8.500(b) 3

Rule 8.500(b)(1) 3

Code of Civil Procedure

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OTHER AUTHORITIES

9 Witkin

California Procedure

Appeal

§ 515 (5th ed. 2010) 6

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INTRODUCTION AND SYNOPSIS OF ARGUMENT

This Answer to Petition for Relief ("Answer") is being submitted by the People of the State of California, acting by and through Acting Santa Clara County Counsel Lori E. Pegg; San Francisco City Attorney Dennis Herrera; Alameda County Counsel Donna R. Ziegler; Los Angeles County Counsel John F. Krattli; Monterey County Counsel Charles McKee; Oakland City Attorney Barbara Parker; San Diego City Attorney Jan Goldsmith; San Mateo County Counsel John C. Beiers; Solano County Counsel Dennis Bunting; and Ventura County Counsel Leroy Smith (collectively referred to as the "People")) The People request that the Court summarily deny the Petition for Review filed on July 3, 2012 by Petitioners and Defendants Atlantic Richfield Co.; Conagra Grocery Products Co.; E.I. Du Pont de Nemours and Co.; NL Industries, Inc.; and the Sherwin-Williams Co ("Petitioners") because the Petition does not rise to the standard for review which is required under Rule of Court 8.500(b).

The action is brought in the name of the People of the State of California by the City Attorneys and County Counsels of the ten public entities listed above pursuant to Code of Civil Procedure section 731.

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BACKGROUND

Pursuant to an opinion issued by the Court of Appeal, the People's only claim in this action is for abatement of a public nuisance; there is no claim for damages. (See County of Santa Clara v. Atlantic Richfield Co. (2006)137 Cal.App.4th 292, 310-311.) Accordingly, the People allege that Petitioners, who are former manufacturers, distributors, or promoters of lead-based paint and coatings (hereinafter "Lead"), concealed the dangers of Lead to the public, mounted a campaign against the regulation of Lead, and promoted Lead for both interior and exterior use. (See The People's Fourth Amended Complaint, 4.) As a result of Petitioners' conduct, there now exists a widespread presence of lead-based paint in homes throughout the State of California, including homes located within the jurisdictions of the ten public entities whose prosecutorial agencies have brought this representative cause of action. (See id. at 7194-96.) The People allege this condition amounts to a public nuisance under Code of Civil Procedure 0 section 731, and seek purely equitable relief in the form of abatement.

LEGAL DISCUSSION

The Supreme Court may order review of a Court of Appeal decision when "(1) necessary to secure uniformity of decision or to settle an

important question of law; (2) [w]hen the Court of Appeal lacked jurisdiction; (3) [w]hen the Court of Appeal decision lacked the

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concurrence of sufficient qualified justices; (4) [f]oror the purpose of transferring the matter to the Court of Appeal for such proceedings as the Supreme Court may order." (California Rules of Court, Rule 8.500(b).) Here, the Petition for Review fails to meet any of the standards proscribed by Rule 8.500(b), and thus a grant of review should be denied.2

Under well-established case law, there is no right to a jury trial for a purely equitable cause of action.

(See Wolford v. Thomas

(1987) 190 Cal.App.3d 347, 353 ["California courts recognize that a party is not entitled to a jury trial in an action to abate a nuisance."] [citations omitted];

see also People v. Bhakta

(2008) 162 Cal.App.4th 973;

People v.

Frangadakis

(1960) 184 Cal.App.2d 540, 545 [holding that because an action to abate a public nuisance did not exist at common law, there was no right to a jury trial in such an action in 1850];

People v. Englebrecht

(2001) 88 Cal.App.4th 1236 [no right to jury trial in proceeding to abate street gang activity as a public nuisance].) As set forth in the People's moving papers submitted to the trial court, these cases have served as precedent in California for over 50 years. The fact that these authorities have withstood the test of time and have not been overruled in over five decades suggests

2

The Petition for Review does not address the grounds for review set forth under California Rule of Court, Rule 8.500(b), and the People presume that only Rule 8.500(b)(1) is implicated by the arguments made therein.

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that Petitioners' analysis is incorrect, rather than that these well-established cases were wrongly decided.

(See Schneider v. Schneider

(1947) 82 Cal.App.2d 860, 862 ["The rule announced in these cases has never been overruled and is binding upon this court. The mere fact that it has not been questioned in over 63 years is cogent evidence of its soundness and

recognition by the legal profession in this state."].) In fact, Petitioners cannot establish that an inconsistency in the law exists where a claimant presents a purely equitable cause of action for a public nuisance.

Consequently, there are no grounds for review on this issue.

In applying this settled precedent, the issue of whether a jury was required in this case was correctly decided by both the Hon. James P. Kleinberg of the Santa Clara County Superior Court—which properly struck Petitioners' jury demands—and the Sixth Appellate District—which denied Petitioners' Petition for Writ of Prohibition or Other Appropriate Relief. In issuing its decision, the trial court relied on the Supreme Court's opinion in

People v. One 1941 Chevrolet Coupe

(1951) 37 Ca1.2d 283, 298, which stated unequivocally: "The right to trial by jury did not exist at

El common law in a suit to abate a public nuisance. [Citation.] Hence it is not

a constitutional right now." (Appendix, Exhibit Z, 111:475 (Order After Hearing of February 6, 2012).) Indeed, California courts have consistently denied parties a jury trial in a public nuisance action where the only remedy

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sought is abatement.

(See e.g. People v. Bhakta

(2008) 162 Cal.App.4th 973, 978 ["An action to abate a public nuisance did not exist at common law, and therefore there was no right to a jury trial in such an action in

1849. For this reason, it is not a constitutional right now. (Citation.)"];

People v. Englebrecht

(2001) 88 Cal.App.4th 1236 [no right to jury trial in proceeding to abate street gang activity as a public nuisance];

Wolford v.

Thomas

(1987) 190 Cal.App.3d 347, 353 ["California courts recognize that a party is not entitled to a jury trial in an action to abate a nuisance."];

People ex rel. Sorenson v. Randolph

(1979) 99 Cal. App. 3d 183, 189 [denying jury trial in action to abate a public nuisance];

People v.

Frangadakis

(1960) 184 Cal.App.2d 540, 545 [holding that because an action to abate a public nuisance did not exist at common law, there was no right to a jury trial].)

Petitioners' invitation to disturb this long line of precedent based upon their contention that these cases were all wrongly decided should be declined. Petitioners ignore the fundamental concept of established precedent. As explained by Witkin: "The long acceptance of a rule by the courts, as where it is followed in other cases, and by the legal profession and the public generally in governing their conduct and relations is a potent argument in favor of allowing it to stand. Although this factor is

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statutory provisions, it is also important in cases dealing with other types of questions. The principal reason for following a settled rule is the

desirability of certainty in the law, . . ." (9 Witkin

California Procedure

Appeal § 515 (5th ed. 2010).) Petitioners do not demonstrate why this case warrants a change in the law.

CONCLUSION

Accordingly, this case does not present an issue that warrants review and the People respectfully request that this Court summarily deny the Petition.

Dated: July 23, 2012 COTCHETT, PITRE & McCARTHY, LLP

By: \ 7

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NA

qt.

FINEMAN

Attorneys for Real Parties in Interest The

People of the State of California

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CERTIFICATE OF WORD COUNT (Cal. Rules of Court, Rule 14(c)(1))

The text of this Answer consists of 1,256 words as counted by Word Perfect processing program used to generate this Answer.

Dated: July 23, 2012

co4

1VC\ TT, PITRE & 1V,JcCA 2THY, LLP

By: \,

NA FINEIMAN

Attorneys for Real Parties in Interest The

People of the State of California

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PROOF OF SERVICE

I am employed in San Mateo County, which is where service of the document(s) referred to below occurred. I am over the age of 18 and not a party to the within action. My business address is Cotchett, Pitre &

McCarthy, LLP, 840 Malcolm Road, Suite 200, Burlingame, California 94010. I am readily familiar with this firm's practices for the service of documents. On this date, I served or caused to be served a true copy of the following document(s) in the manner listed below:

ANSWER TO PETITION FOR REVIEW

3 BY MAIL: I caused the sealed envelope containing the

aforementioned document(s) to be deposited with the United States Postal Service on that same day in the ordinary course of business.

[SEE ATTACHED SERVICE LIST]

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed at Burlingame, California, on July 23, 2012

JoAnne Lein

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SERVICE LIST

Jerome B. Falk, Jr.

ARNOLD & PORTER, LLP Three Ernbarcadero Center, 7 th Floor San Francisco, CA 94111 Tel: (415) 471-3100 Fax: (415) 471-3400 [email protected] ATTORNEYS FOR DEFENDANT ATLANTIC RICHFIELD COMPANY Sean Morris

ARNOLD & PORTER

777 South Figueroa Street, 44th Floor Los Angeles, CA 90017-5844 Tel: (213) 243-4000 Fax: (213) 243-4199 [email protected] ATTORNEYS FOR DEFENDANT ATLANTIC RICHFIELD COMPANY James McManis William Faulkner McMANIS FAULKNER

50 W. San Fernando Street, 10th Floor San Jose, CA 95113 Tel: (408) 279-8700 Fax: (408) 279-3244 [email protected] [email protected] ATTORNEYS FOR DEFENDANT NL INDUSTRIES, INC. Allen J. Ruby

SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP 525 University Ave., Suite 1100 Palo Alto, CA 94301 Tel: 650-470-4500 Fax: 650-470-4570 [email protected] ATTORNEYS FOR DEFENDANT CONAGRA GROCERY PRODUCTS COMPANY

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Clement L. Glynn

GLYNN & FINLEY LLP 100 Pringle Avenue, Suite 500 Walnut Creek, CA 94596 Tel: (925) 210-2800 Fax: (925) 945-1975 [email protected]

ATTORNEYS FOR

DEFENDANT E.I. DU PONT E NEMOURS AND

COMPANY

Steven R. Williams

McGUIRE WOODS LLP One James Center

901 East Cary Street Richmond, Virginia 23219 Tel: (804) 775-1000 Fax: (804) 775-1061

[email protected]

ATTORNEYS FOR

DEFENDANT E.I. DU PONT DE NEMOURS AND

COMPANY

Donald T. Scott

BARTLIT, BECK, HERMAN, PALENCHAR & SCOTT

1899 Wynkoop Street, Suite 800 Denver, CO 80202 Tel: (303) 592-3100 Fax: (303) 592-3140 [email protected] ATTORNEYS FOR DEFENDANT NL INDUSTRIES, INC. Timothy Hardy 300 West 1 lth Avenue, #8B Denver, CO 80204 Tel: (303) 303-1279 [email protected] ATTORNEYS FOR DEFENDANT NL INDUSTRIES, INC. Robert A. Mittelstaedt JONES DAY

555 California Street, 26 th Floor San Francisco, CA 94104 Tel: 415-626-3939 Fax: 415-875-5700

ATTORNEYS FOR DEFENDANT

THE SHERWIN WILLIAMS COMPANY

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John W. Edwards, II JONES DAY 1755 Embarcadero Road Palo Alto, CA 94303 Tel: (650) 739 3912 Fax: (650) 739 3900 [email protected] ATTORNEYS FOR DEFENDANT

THE SHERWIN WILLIAMS COMPANY

Donna R. Ziegler County Counsel Andrew Massey

Deputy County Counsel ALAMEDA COUNTY OFFICE OF THE COUNTY COUNSEL

1221 Oak Street, Suite 450 Oakland, CA 94612-4296 Tel: (510) 272-6700 Fax: (510) 272-5020

[email protected]

OFFICE OF THE COUNTY COUNSEL

COUNTY OF ALAMEDA

John F. Krattli County Counsel Robert E. Ragland

Principal Deputy County Counsel Andrea Ross

Senior Deputy County Counsel LOS ANGELES COUNTY COUNSEL

500 West Temple St, Suite 648 Los Angeles, CA 90012

Tel: (213) 974-1811 Fax: (213) 626-7446

[email protected] [email protected]

LOS ANGELES COUNTY COUNSEL

COUNTY OF LOS ANGELES

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Charles J. McKee County Counsel William M. Litt

Deputy County Counsel OFFICE OF THE COUNTY COUNSEL

COUNTY OF MONTEREY 168 West Alisal Street 3rd Floor Salinas, CA 93901

Tel: (831) 755-5045 Fax: (831) 755-5283

[email protected]

OFFICE OF THE COUNTY COUNSEL

COUNTY OF MONTEREY

Barbara Parker City Attorney William Simmons

OAKLAND CITY ATTORNEY One Frank H. Ogawa Plaza

6th Floor Oakland, CA 94612 Tel: (510) 238-6520 Fax: (510) 238-6500 [email protected] OAKLAND CITY ATTORNEY CITY OF OAKLAND Jan Goldsmith City Attorney Daniel F. Bamberg

Chief Deputy City Attorney

Paul Prather, Deputy City Attorney OFFICE OF THE SAN DIEGO CITY ATTORNEY

CITY OF SAN DIEGO 1200 Third Avenue # 1100 San Diego, CA 92101 Tel: (619) 236-6220 Fax: (619) 236-7215 [email protected] [email protected]

OFFICE OF THE SAN DIEGO CITY ATTORNEY CITY OF SAN DIEGO

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Dennis J. Herrera City Attorney Owen J. Clements

Chief of Special Litigation Erin Bernstein

Deputy City Attorney SAN FRANCISCO CITY ATTORNEY

Fox Plaza

1390 Market Street, Seventh Floor San Francisco, CA 94102

Tel: (415) 554-3800 Fax: (415) 554-3985 [email protected] [email protected]

SAN FRANCISCO CITY ATTORNEY

CITY AND COUNTY OF SAN FRANCISCO

John C. Beiers County Counsel Rebecca M. Archer Deputy County Counsel OFFICE OF THE COUNTY COUNSEL

COUNTY OF SAN MATEO 400 County Center Sixth Floor Redwood City, CA 94063

Tel: (650) 363-4686 (Rebecca's direct) Fax: (650) 363-4034

OFFICE OF THE COUNTY COUNSEL

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Lori E. Pegg Greta Hansen

Lead Deputy County Counsel Jenny S. Lam

Deputy County Counsel

OFFICE OF THE COUNTY COUNSEL, SANTA CLARA COUNTY

70 West Hedding Street East Wing, 9th Floor San Jose, CA 95110 Tel: (408) 299-5900 Fax: (408) 291-7240

[email protected] [email protected]

OFFICE OF THE COUNTY COUNSEL COUNTY OF SANTA CLARA

Dennis Bunting County Counsel

SOLANO COUNTY COUNSEL Solano County Courthouse

675 Texas Street, Suite 6600 Fairfield, CA 94533

Tel: (707) 784-6140 Fax: (707) 784-6862

[email protected]

OFFICE OF THE COUNTY COUNSEL SOLANO COUNTY COUNSEL Leroy Smith County Counsel Eric Walts

Assistant County Counsel OFFICE OF THE COUNTY COUNSEL COUNTY OF VENTURA 800 S. Victoria Avenue L/C #1830 Ventura, CA 93009 Tel: 805-654-2580 Fax: 805-654-2185 [email protected]

OFFICE OF THE COUNTY COUNSEL

COUNTY OF VENTURA

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Lori E. Pegg, ActingCounty Counsel Greta Hansen

Lead Deputy County Counsel Jenny S. Lam

Deputy County Counsel OFFICE OF THE COUNTY COUNSEL, SANTA CLARA COUNTY

70 West Hedding Street East Wing, 9th Floor San Jose, CA 95110 Tel: (408) 299-5900 Fax: (408) 291-7240

[email protected] [email protected]

OFFICE OF THE COUNTY COUNSEL, COUNTY OF SANTA CLARA

Dennis Bunting County Counsel

SOLANO COUNTY COUNSEL Solano County Courthouse

675 Texas Street, Suite 6600 Fairfield, CA 94533

Tel: (707) 784-6140 Fax: (707) 784-6862

[email protected]

OFFICE OF THE COUNTY COUNSEL SOLANO COUNTY COUNSEL Leroy Smith County Counsel Eric Walts

Assistant County Counsel OFFICE OF THE COUNTY COUNSEL COUNTY OF VENTURA 800 S. Victoria Avenue L/C #1830 Ventura, CA 93009 Tel: 805-654-2580 Fax: 805-654-2185 [email protected]

OFFICE OF THE COUNTY COUNSEL

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Fidelma Fitzpatrick MOTLEY RICE LLC 321 South Main Street Providence, RI 02903-7108 Tel: (401) 457-7700

Fax: (401) 457-7708

[email protected]

ATTORNEYS FOR THE PEOPLE OF THE STATE OF CALIFORNIA, ACTING BY AND THROUGH THE CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO AND THE COUNTY COUNSEL OF LOS ANGELES

ATTORNEYS FOR THE PEOPLE OF THE STATE OF CALIFORNIA, ACTING BY AND THROUGH THE CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

Mary Alexander Jennifer L. Fiore

MARY ALEXANDER & ASSOCIATES

44 Montgomery Street, Suite 1303 San Francisco, CA 94104

Tel: (415) 433-4440 Fax: (415) 433-5440

[email protected] [email protected]

ATTORNEYS FOR THE PEOPLE OF THE STATE OF CALIFORNIA

Peter G. Earle

LAW OFFICE OF PETER EARLE, LLC

839 N. Jefferson Street, Suite 300 Milwaukee, WI 53202-3744 Tel: (414) 276-1076

Fax: (414) 899-9521 [email protected]

Santa Clara County Superior Court Hon. James P. Kleinberg

191 N. First Street San Jose, CA 95113

California Court of Appeal

Sixth Appellate District, Division One 333 West Santa Clara Street

Suite 1060

San Jose, CA 95113

Figure

TABLE OF AUTHORITIES

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