ELIZABETH KARNAZES VS. JOHN J. HARTFORD et al

Complaint Information

(650) 345-9200 CLERK

BY: Plaintiff in pro per

SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO

ELIZABETH KARNAZES Case No. CGC-12-521174 Plaintiff, RESPONSE TO JOHN J. HARTFORD’S ) AND ALBERT W. LEE’S MOTION TO Vs ; QUASH SERVICE OF SUMMONS ON

FIRST AMENDED COMPLAINT AND

JOHN J. HARTFORD, ALBERT W. LEE, | DOES 1-100. g FIRST AMENDED COMPLAINT ) ) Date: August 7, 2015 Defendants. ) Time: 9:30 a.m. Dept. 302

signature by facsimile

TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD HEREIN:

PLEASE TAKE NOTICE that Plaintiff ELIZABETH KARNAZES (hereinafter referred to as “Plaintiff” or “KARNAZES”) responds to Defendant attorneys JOHN J. HARTFORD’S and ALBER W. LEE’S (hereinafter referred to as “HARTFORD,” “LEE,” and collectively as “defendants”) Motio To Quash Service Of Summons On First Amended Complaint And First Amended Complaint

(hereinafter referred to as “Motion to Quash”) as follows:

DECLARATION OF ELIZABETH KARNAZES

I, ELIZABETH KARNAZES, declare as follows: 1. T am the Plaintiff herein, and I am currently representing myself in this matter. 2. I caused to be filed a verified amended petition, declaration in support thereof, proposed verified

amended complaint, and summons thereon on May 27, 2015.

Resp. OSC Karnazesv. Hartford 1 Case. No. CGC-12-521174

Resp. OSC Karnazesv. Hartford 1 Case. No. CGC-12-521174 (g) This section shall not apply to disclosures and discovery requests, responses, objections, and motions.

(g) This section shall not apply to disclosures and discovery requests, responses, objections, and motions.

(h) A motion for sanctions brought by a party or a party's attorney primarily for an improper purpose, such as to harass or to cause unnecessary delay or needless increase in the cost of litigation, shall itself be subject to a motion for sanctions. It is the intent of the Legislature that courts shall vigorously use its sanctions authority to deter that improper conduct or comparable conduct by others similarly situated.

(i) This section shall apply to a complaint or petition filed on or after January 1, 1995, and any other pleading, written notice of motion, or other similar paper filed in that matter. Cal Code Civ. Proc. § 128.7 (2006).

9. I am experiencing serious physical problems caused by an accident that necessitated emergency

surgery, which led to a serious adverse reaction to the anesthesia, causing me further problems. I am under physician’s orders to be off work completely at least through August 19, 2015, and 1

expect my recovery may take longer due to complications.

. I will provide a true and correct copy of my physician’s order upon request by the court, for

reasons of privacy.

. I am taking prescribed strong pain killers that effect my ability to work think clearly.

. My right arm is my dominant arm, and I cannot use it and must keep it elevated above my head

to eleviate pain.

. I am typing this with fingers on my left hand and with great difficulty. . I am legally indigent, a senior citizen, and I have no secretarial support.

. The hearing on the amended petition is set for August 31, 2015, and this Motion to Quash is a

sham pleading filed to harass me and needlessly increase the cost of this litigation.

The clerk of the court is still having trouble understanding the correct filing procedures for this case.

Despite multiple letters and numerous requests for assistance from the court, the original documents in this case have not been correctly filed.

The Petition was presented for filing and was supposed to be filed as the first paper in this case, hearing set, and after the hearing, the Complaint that was submitted with the Petition would then be filed.

. The clerk of the court apparently improperly filed the Complaint and not the Petition as the first

document in this case.

. T have contacted the court multiple times, but the problem has not been fixed.

. The Petition in this case needs to be filed effective May 28, 2012, when it was submitted for

filing, and a date needs to be set for hearing thereon before the Complaint can be properly filed

Resp. Mot. Quash Karnazes v. Hartford 5 Case. No. CGC-12-521174

Tentative Rulings