Southern California Institute of Law v. TCS Education System et al

Filing 29

RESPONSE filed by Plaintiff Southern California Institute of Lawto Motion Hearing, Link Motions to Minutes,, 24 Plaintiff's response to OSC re Dismissal (Attachments: # 1 Declaration, # 2 Declaration, # 3 Declaration, # 4 Affidavit)(Shohet, George)

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George A. Shohet SBN 112697
LAW OFFICES OF GEORGE A. SHOHET,
A PROFESSIONAL CORPORATION
245 Main Street, Suite 310
Venice, CA 90291-5216
Tel.: [phone]
Fax: [phone]
Gretchen M. Nelson SBN 112566
KREINDLER & KREINDLER LLP
707 Wilshire Blvd, Suite 4100
Los Angeles, CA 90017
Tel.: [phone]
Fax: [phone]
Attorneys for Plaintiff
Southern California Institute of Law

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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SOUTHERN CALIFORNIA
INSTITUTE OF LAW, a California
corporation,
Plaintiff,
vs.

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TCS EDUCATION SYSTEM, an
Illinois corporation; DAVID J.
FIGULI, an individual; and GLOBAL
EQUITIES, LTD. d/b/a HIGHER
EDUCATION GROUP, a Colorado
limited liability company,

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CASE NO.: CV10-8026 PSG (AJWx)
[Assigned to Hon. Philip S. Gutierrez]
PROOF OF SERVICE BY CERTIFIED
MAIL OF PLAINTIFF'S RESPONSE
TO ORDER TO SHOW CAUSE
REGARDING DISMISSAL
PURSUANT TO FED. R. CIV. P. 4(m)
AND SUPPORTING DECLARATIONS
Action Filed: Oct. 25, 2010
Hearing Date: None Set
Ctrm: 880

Defendants.
________________________________________________________________
PROOF OF SERVICE BY CERTIFIED MAIL OF PLAINTIFF'S RESPONSE TO ORDER TO SHOW
CAUSE REGARDING DISMISSAL PURSUANT TO FED. R. CIV. P. 4(m) AND SUPPORTING
DECLARATIONS

PROOF OF SERVICE

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I, George A. Shohet, declare as follows:

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I am employed in the County of Los Angeles, State of California, by the Law

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Offices of George A. Shohet, A Professional Corporation, whose business address is

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245 Main Street, Suite 310, Venice, California 90291. I am over the age of 18 and

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not a party to this action. On April 18, 2011, I served the following document(s):

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PLAINTIFF'S RESPONSE TO ORDER TO SHOW CAUSE

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REGARDING DISMISSAL PURSUANT TO FED. R. CIV. P. 4(m);

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DECLARATION OF GEORGE A. SHOHET IN SUPPORT OF

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PLAINTIFF'S RESPONSE TO ORDER TO SHOW CAUSE

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REGARDING DISMISSAL PURSUANT TO FED. R. CIV. P. 4(m);

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DECLARATION OF PAMELA VAUGHN REGARDING SERVICE OF

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PROCESS ON DEFENDANTS DAVID J. FIGULI AND GLOBAL

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EQUITIES, LLC D/B/A HIGHER EDUCATION GROUP; and

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DECLARATION OF STUART SORENSEN REGARDING

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ATTEMPTED SERVICE OF PROCESS ON DEFENDANTS DAVID

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J. FIGULI AND GLOBAL EQUITIES, LLC D/B/A HIGHER

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EDUCATION GROUP

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by placing a true copies thereof in two envelopes addressed to each of the defendants

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named below at the addresses shown:

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David J. Figuli
Global Equities, LLC
8697 S. Blue Creek Road
Evergreen, CO 80439

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________________________________________________________________
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DECLARATION OF GEORGE A. SHOHET IN SUPPORT OF PLAINTIFF'S RESPONSE TO ORDER TO
SHOW CAUSE REGARDING DISMISSAL PURSUANT TO FED. R. CIV. P. 4(m)

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AND

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David J. Figuli
Global Equities, LLC
P.O. Box 392
Conifer, CO 80433

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[ ]

BY PERSONAL SERVICE: I placed a true copy in a sealed envelope

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addressed to each person[s] named at the address[es] shown and giving same to a

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messenger employed by Now Legal Services, whose business address is 1301 W.

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2nd Street, Suite 101, Los Angeles, California 90026, for personal delivery before

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5:00 p.m. on April 18, 2011.

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BY FEDERAL EXPRESS: On the above-mentioned date, I placed a

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true copy of the above mentioned document(s), in a sealed envelope or package

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designated by Federal Express with delivery fees paid or provided for, addressed to

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the person(s) as indicated above and deposited same in a box or other facility

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regularly maintained by Federal Express or delivered same to an authorized courier

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or driver authorized by Federal Express.

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[X]

BY CERTIFIED MAIL: On April 18, 2011, I deposited a true copy

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of the above mentioned documents in a sealed envelope with the United States

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Postal Service in Santa Monica, California fully pre-paid to be sent to the defendants

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identified above by First Class Mail combined with Certified Mail, return receipt

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requested.

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[ ]

BY FACSIMILE: From facsimile machine telephone number (310)

452-2270, on April 18, 2011, I served a full and complete copy of the above________________________________________________________________
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DECLARATION OF GEORGE A. SHOHET IN SUPPORT OF PLAINTIFF'S RESPONSE TO ORDER TO
SHOW CAUSE REGARDING DISMISSAL PURSUANT TO FED. R. CIV. P. 4(m)

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referenced document[s] by facsimile transmission to the person[s] at the number[s]

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indicated.

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BY E-MAIL: On April 18, 2011, I served a full and complete copy of

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the above-referenced document[s] by e-mail transmission to the person[s] at the e-

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mail addresses indicated above.

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I declare under penalty of perjury under the laws of the State of California that

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the foregoing is true and correct, that the original of the aforementioned document(s)

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was/were printed on recycled paper, and that this Proof of Service was executed by

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me on April 18, 2011, at Los Angeles, California.

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George A. Shohet

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________________________________________________________________
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DECLARATION OF GEORGE A. SHOHET IN SUPPORT OF PLAINTIFF'S RESPONSE TO ORDER TO
SHOW CAUSE REGARDING DISMISSAL PURSUANT TO FED. R. CIV. P. 4(m)

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CERTIFICATE OF SERVICE
The undersigned hereby certifies that all counsel of record who have

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consented to electronic service are being served with a copy of the foregoing

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document via Central District of California CM/ECF system on April 18, 2011

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____/s/ George A. Shohet_______________

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---------------------------------------------------------------------------------------------------------------------------CERTIFICATE OF SERVICE