The opinion of the court was delivered by: Judge: Hon. Frank C. Damrell, Jr.
ORDER GRANTING AMENDED REQUEST FOR AUTHORIZATION TO APPEAR TELEPHONICALLY AT HEARING
Date: February 25, 2011 Time: 10:00 a.m.
TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that Veronica H. Garcia of Goins & Associates PLC, attorneys for Plaintiff Jacob Winding in the above-entitled action, hereby respectfully request the Court's authorization to appear telephonically at the February 25, 2011 hearing on Defendant Allstate Insurance Company's Motion to Amend Answer and File Counterclaims. The declaration of Veronica H. Garcia in support of said request is attached hereto and incorporated herein by this reference.
GOINS & ASSOCIATES A Professional Law Corporation a VERONICA H. GARCIA Attorneys for Plaintiff JACOB WINDING
DECLARATION OF VERONICA H. GARCIA
I, Veronica H. Garcia, do hereby declare as follows:
1) I am attorney of record for Plaintiff Jacob Winding in the above-entitled action. I have personal knowledge of the facts contained in this declaration, and, if necessary, I could competently testify to such facts.
2) Currently, Defendant Allstate Insurance Company's Motion to Amend Answer and File Counterclaims is set to be heard on February 25, 2011 by Judge Frank C. Damrell, Jr. in Courtroom 2.
3) My law office is located in Oakland, California.
4) Due to scheduling conflicts, it will be very difficult, if not impossible, for me to personally attend this matter. Further, I believe that no prejudice will result to Defendant and that it will be most cost-effective for my client if I am authorized by this Court to telephonically appear at the February 25, 2011 hearing on Defendant's Motion to Amend Answer and File Counterclaims.
I declare under penalty of perjury that the foregoing is true and correct and executed on this 14th day of ...