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 115 |
Filed: 10/1/2009, Entered: None |
Case Management Conference |
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CASE MANAGEMENT CONFERENCE
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 114 |
Filed: 10/1/2009, Entered: None |
Case Management Conference |
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Case Management Conference
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 Request |
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| 113 |
Filed: 8/7/2009, Entered: None |
Order |
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O2: ORDER DENYING DEFS' DEMURRER TO PLTF'S COMPLAINT, SIGNED BY JUDGE GRANDSAERT ON 08/06/09 FILED.
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| 112 |
Filed: 8/7/2009, Entered: None |
Order |
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O2: ORDER DENYING DEFS' SPECIAL MOTION TO STRIKE PORTIONS OF COMPLAINT (SLAPP), SIGNED BY JUDGE GRANDSAERT ON 08/06/09 FILED.
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| 111 |
Filed: 8/7/2009, Entered: None |
Order |
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O2: ORDER RE DEFENDANTS' MOTION TO STRIKE, SIGNED BY JUDGE GRANDSAERT ON 08/06/09 FILED.
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| 110 |
Filed: 8/7/2009, Entered: None |
Request For Dismissal |
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REQDEA: REQUEST FOR DISMISSAL OF ENTIRE ACTION WITHOUT PREJUDICE FILED AND ENTERED.
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Request |
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| 109 |
Filed: 8/7/2009, Entered: None |
Proof of Service |
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POSI: PROOF OF SERVICE OF REQ FOR DISMISSAL SERVED ON GARY M GANSLE BY MAIL WITH A SERVICE DATE OF 08/07/09.
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Request |
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| 108 |
Filed: 7/29/2009, Entered: None |
Conversion Minute |
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PLAINTIFF'S EVIDENTIARY OBJECTIONS ARE OVERRULED AS TO OBJECTIONS NOS. 1-30, 32-33 AND SUSTAINED AS TO OBJECTION NOS. 31 AND 34.
DEFENDANTS' EVIDENTIARY OBJECTIONS ARE OVERRULED AS TO OBJECTIONS NOS. 1-18, 20-26, 28-35, 37-45, 48-115, 118-143 AND SUSTAINED AS TO OBJECTION NOS. 19, 27, 36, 46-47 AND 116-117.
PLAINTIFF'S REQUEST FOR JUDICIAL NOTICE IS GRANTED.
THE COURT MUST UNDERTAKE A TWO-STEP PROCESS IN DETERMINING THE MERITS OF A SLAPP MOTION. FIRST, THE COURT MUST DECIDE IF THE DEFENDANTS HAVE MADE A THRESHOLD SHOWING THAT THE CHALLENGED CAUSES OF ACTION AROSE FROM PROTECTED ACTIVITY. IF THE DEFENDANTS FAIL TO SATISFY THIS BURDEN, THE CHALLENGED CAUSES OF ACTION ARE NOT SUBJECT TO A MOTION TO STRIKE. IF THE COURT FINDS SUCH A SHOWING HAS BEEN MADE, IT MUST THEN DETERMINE WHETHER THE PLAINTIFF HAS DEMONSTRATED A PROBABILITY OF PREVAILING ON THE CLAIMS. (CLARK V. MAZGANI (2009) 170 CAL.APP. 4TH 1281, 1286.) ONLY CAUSES OF ACTION THAT SATISFY BOTH PRONGS OF THE ANTI-SLAPP STATUTE-I.E., THAT ARISE FROM PROTECTED SPEECH OR PETITIONING AND LACKS EVEN MINIMAL MERIT-IS A SLAPP, SUBJECT TO BEING STRICKEN UNDER THE STATUTE. (NAVELLIER V. SLETTEN (2002) 29 CAL. 4TH 82, 89.) ONLY A MINIMAL SHOWING OF MERIT IS REQUIRED TO ESTABLISH A PROBABILITY OF PREVAILING ON PLAINTIFF'S CLAIMS. (SYCAMORE RIDGE APARTMENTS, LLC V. NAUMANN (2008) 157 CAL.APP.4TH 1385, 1392.) THE COURT DOES NOT WEIGH OR COMPARE THE WEIGHT OF THE EVIDENCE; THE COURT ACCEPTS AS TRUE THE EVIDENCE FAVORABLE TO THE PLAINTIFF. (ID., AT 1397.)
IN THIS CASE, THE DEFENDANTS HAVE MADE A PRIMA FACIE SHOWING THE CHALLENGED CAUSE OF ACTION ARISES FROM AN ACT IN THE FURTHERANCE OF FREE SPEECH. (CODE OF CIV. PROC. SECTION 425.16(E)(3) AND (E)(4).) PLAINTIFF HAS NOT DEFEATED THE DEFENDANTS' THRESHOLD SHOWING THAT THE CAUSES OF ACTION WERE PROTECTED ACTIVITY BY THE DEFENDANT. AS TO THE SECOND PRONG OF THE SLAPP ANALYSIS, HOWEVER, THE COURT FINDS THAT THE PLAINTIFF HAS DEMONSTRATED A PROBABILITY THAT HE WILL PREVAIL ON THE CHALLENGED CAUSES OF ACTION. DEFENDANTS' SPECIAL MOTION TO STRIKE THE 1ST, 2ND, 3RD, 6TH AND 11TH CAUSES OF ACTION OF PLAINTIFF'S COMPLAINT IS, THEREFORE, DENIED:
AS TO THE FIRST AND SECOND CAUSES OF ACTION (DEFAMATION) PLAINTIFF HAS ESTABLISHED A PROBABILITY HE COULD PREVAIL ON AT LEAST SOME OF HIS DEFAMATION/LIBEL CLAIMS RELATING TO STATEMENTS MADE BY MUSK, INCLUDING BUT NOT LIMITED TO, THAT PLAINTIFF CAUSED THE FINANCIAL ISSUES AT TESLA, THAT HE LEFT A "MESS" WHEN HE LEFT THE COMPANY, THAT HE CAUSED THE DELAYS IN THE PRODUCTION OF THE ROADSTER, AND THAT MUSK HAD TO SPEND A LOT OF TIME CORRECTING ALL THE ERRORS MADE BY PLAINTIFF. (COMPLAINT, 89-102; EXHIBITS. 24-30.)
AS TO THE THIRD CAUSE OF ACTION (INJUNCTIVE RELIEF), BECAUSE PLAINTIFF HAS SHOWN THE PROBABILITY HE MAY PREVAIL ON THE MERITS OF A PORTION OF HIS DEFAMATION CLAIMS, HE MAY ALSO PREVAIL ON HIS CLAIM FOR INJUNCTIVE RELIEF. AN INJUNCTION WHICH DOES NO MORE THAN PROHIBIT DEFENDANTS FROM REPEATING THE DEFAMATION IS NOT A PRIOR RESTRAINT AND DOES NOT OFFEND THE FIRST AMENDMENT. (BALBOA ISLAND VILLAGE INN V. LEMEN (2007) 40 CAL.4TH 1141, 1148.)
AS TO THE SIXTH CAUSE OF ACTION (DECLARATORY RELIEF), AN ANTI-SLAPP MOTION IS NOT THE PROPER MECHANISM TO USE TO CONTEST THE VALIDITY OF THIS CAUSE OF ACTION. RATHER, THE SEPARATE MOTION TO STRIKE UNDER CODE OF CIVIL PROCEDURE SECTION 436 ET SEQ CONTEMPORANEOUSLY FILED HEREWITH FULLY AND ADEQUATELY ADDRESSES THIS DISPUTE.
AS TO THE ELEVENTH CAUSE OF ACTION (NEGLIGENCE), THE COMPLAINT DOES NOT PREDICATE THIS CAUSE OF ACTION SOLELY UPON DEFENDANTS' ALLEGED DEFAMATORY STATEMENTS.
NEITHER THESE DETERMINATIONS, HOWEVER, THAT THERE IS A PROBABILITY THAT THE PLAINTIFF WILL PREVAIL ON THESE CAUSES OF ACTION, NOR THE FACT THAT SAID DETERMINATIONS WERE MADE, SHALL BE ADMISSIBLE FOR ANY PURPOSE, NOR SHALL IT AFFECT ANY BURDEN OF PROOF, IN ANY LATER STAGE OF THESE OR RELATED PROCEEDINGS. (CODE CIV. PROC., SECTION 425.16(B)(3).)
RESPONDING PARTY SHALL PREPARE AND SUBMIT A FORMAL ORDER COMPLYING WITH CALIFORNIA RULE OF COURT 3.1312 FOR THE COURT'S SIGNATURE.
MICMS: ENTERED BY PATTY VAN DER SCHOOR ON 07/29/09.
COMM: PROPOSED ORDER DENYING IN PART, ETC. RECEIVED IN DEPARTMENT 11 FOR CONSIDERATION.
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Request |
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| 107 |
Filed: 7/29/2009, Entered: None |
Conversion Minute |
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TRA: TENTATIVE RULING ADOPTED AND BECOMES THE ORDER:
THE "STATEMENT OF INTENT TO INTRODUCE ORAL TESTIMONY" SUBMITTED BY PLAINTIFF IS NOT REFERENCED IN CRC 3.1306(B). TO THE EXTENT THAT THE COURT CONSIDERS SAID STATEMENT OF INTENT TO INTRODUCE ORAL TESTIMONY TO CONSTITUTE THE REQUIRED REQUEST TO INTRODUCE ORAL TESTIMONY, THE REQUEST TO INTRODUCE ORAL TESTIMONY IS DENIED. THE PLAINTIFF HAS NOT SHOWN THE "NATURE AND EXTENT" OF THE PROPOSED TESTIMONY, A "REASONABLE TIME ESTIMATE FOR THE HEARING" THEREOF, AND HAS NOT IN ANY OTHER WAY MADE THE REQUIRED GOOD CAUSE SHOWING THAT IS A PREREQUISITE FOR SUCH ORAL TESTIMONY. THE DETERMINATION OF THE MOTIONS SUBMITTED WILL BE BASED UPON THE EVIDENCE PRESENTED BY DECLARATIONS SUBMITTED WITH THE MOTIONS.
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Request |
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| 106 |
Filed: 7/29/2009, Entered: None |
Conversion Minute |
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MAS: MATTER ARGUED BY COUNSEL AND SUBMITTED TO THE COURT.
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Request |
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| 105 |
Filed: 7/29/2009, Entered: None |
Conversion Minute |
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AT: ATTORNEY(S): GARY M. GANSLE APPEARED ON BEHALF OF THE DEFENDANT
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Request |
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| 104 |
Filed: 7/29/2009, Entered: None |
Conversion Minute |
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AT: ATTORNEY(S): YOSEF PERETZ AND EMILY KNOLES APPEARED ON BEHALF OF THE PLAINTIFF
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Request |
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| 103 |
Filed: 7/29/2009, Entered: None |
Conversion Minute |
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Judicial Officer: Grandsaert, John L.
JCRB: HONORABLE JOHN L. GRANDSAERT, JUDGE PRESIDING. CLERK: PATRICIA A. VAN DER SCHOOR, COURT REPORTER: WENDY WACHHORST
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Request |
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| 102 |
Filed: 7/29/2009, Entered: None |
Hearing |
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Judicial Officer: Grandsaert, John L.
HEARING: MOTION RE: SPEC MOT TO STRIKE PORTIONS OF COMPL AS SLAPP FILED BY ELON MUSK, TESLA MOTORS, INC
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Request |
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| 101 |
Filed: 7/29/2009, Entered: None |
Conversion Minute |
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MICMS: ENTERED BY PATTY VAN DER SCHOOR ON 07/29/09.
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Request |
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| 100 |
Filed: 7/29/2009, Entered: None |
Conversion Minute |
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MOVING PARTY SHALL PREPARE AND SUBMIT A FORMAL ORDER COMPLYING WITH CALIFORNIA RULE OF COURT 3.1312 FOR THE COURT'S SIGNATURE.
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Request |
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| 99 |
Filed: 7/29/2009, Entered: None |
Conversion Minute |
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GRANTED AS TO "COUNT TWO" OF THE SIXTH CAUSE OF ACTION. THIS COUNT IS DUPLICATIVE OF THE FOURTH AND FIFTH CAUSES OF ACTION ASSERTED IN THE COMPLAINT.
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Request |
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| 98 |
Filed: 7/29/2009, Entered: None |
Conversion Minute |
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GRANTED AS TO "COUNT ONE" OF THE SIXTH CAUSE OF ACTION. PLAINTIFF IS IMPROPERLY REQUESTING THE COURT MAKE FACTUAL DETERMINATIONS, AS OPPOSED TO A DECLARATION REGARDING THE PARTIES' LEGAL RIGHTS AND OBLIGATIONS.
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Request |
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| 97 |
Filed: 7/29/2009, Entered: None |
Conversion Minute |
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DENIED AS TO "COUNT THREE" OF THE FOURTH CAUSE OF ACTION. IN RULING ON A MOTION TO STRIKE, THE COURT IS LIMITED TO THE FACE OF THE PLEADINGS AND ANY INFORMATION IT MAY JUDICIALLY NOTICE. (CODE OF CIV. PROC. SECTION 437.) THE EVIDENCE OF THE UPGRADE MAY NOT BE CONSIDERED BY THE COURT. THUS, THERE ARE NO GROUNDS UPON WHICH TO GRANT THE MOTION TO STRIKE.
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Request |
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| 96 |
Filed: 7/29/2009, Entered: None |
Conversion Minute |
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DENIED AS TO "COUNT ONE" OF THE FOURTH CAUSE OF ACTION. A DETERMINATION AS TO WHETHER PLAINTIFF BREACHED THE NONDISPARAGEMENT CLAUSE OF THE BOD RESIGNATION AGREEMENT WOULD REQUIRE INTERPRETATION OF THE CONTRACT AND ITS TERMS, WHICH IS IMPROPER ON A MOTION TO STRIKE.
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Request |
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| 95 |
Filed: 7/29/2009, Entered: None |
Conversion Minute |
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TRA: TENTATIVE RULING ADOPTED AND BECOMES THE ORDER: DEFENDANTS' MOTION TO STRIKE PORTIONS OF PLAINTIFF'S COMPLAINT IS DENIED IN PART AND GRANTED IN PART AS FOLLOWS:
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Request |
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| 94 |
Filed: 7/29/2009, Entered: None |
Conversion Minute |
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MAS: MATTER ARGUED BY COUNSEL AND SUBMITTED TO THE COURT.
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Request |
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| 93 |
Filed: 7/29/2009, Entered: None |
Conversion Minute |
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AT: ATTORNEY(S): GARY M. GANSLE APPEARED ON BEHALF OF THE DEFENDANT
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Request |
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| 92 |
Filed: 7/29/2009, Entered: None |
Conversion Minute |
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AT: ATTORNEY(S): YOSEF PERETZ AND EMILY KNOLES APPEARED ON BEHALF OF THE PLAINTIFF
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Request |
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| 91 |
Filed: 7/29/2009, Entered: None |
Conversion Minute |
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Judicial Officer: Grandsaert, John L.
JCRB: HONORABLE JOHN L. GRANDSAERT, JUDGE PRESIDING. CLERK: PATRICIA A. VAN DER SCHOOR, COURT REPORTER: WENDY WACHHORST
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Request |
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| 90 |
Filed: 7/29/2009, Entered: None |
Hearing |
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Judicial Officer: Grandsaert, John L.
HEARING: MOTION RE: TO STRIKE PORTIONS OF COMPLAINT FILED BY ELON MUSK, TESLA MOTORS, INC
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Request |
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| 89 |
Filed: 7/29/2009, Entered: None |
Conversion Minute |
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MICMS: ENTERED BY PATTY VAN DER SCHOOR ON 07/29/09.
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Request |
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| 88 |
Filed: 7/29/2009, Entered: None |
Conversion Minute |
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RESPONDING PARTY SHALL PREPARE AND SUBMIT A FORMAL ORDER COMPLYING WITH CALIFORNIA RULE OF COURT 3.1312 FOR THE COURT'S SIGNATURE.
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Request |
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| 87 |
Filed: 7/29/2009, Entered: None |
Conversion Minute |
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DEFENDANTS' DEMURRER TO THE 3RD AND 7TH THROUGH 9TH CAUSES OF ACTION OF PLAINTIFF'S COMPLAINT IS OVERRULED IN ITS ENTIRETY.
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Request |
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| 86 |
Filed: 7/29/2009, Entered: None |
Conversion Minute |
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TRA: TENTATIVE RULING ADOPTED AND BECOMES THE ORDER: PLAINTIFF'S REQUEST FOR JUDICIAL NOTICE IS GRANTED AS TO THE EXISTENCE OF THE COMPLAINTS AND DEMURRERS IN THE OTHER ACTIONS. HOWEVER, THE COURT MAY NOT TAKE JUDICIAL NOTICE OF THE TRUTH OF THE STATEMENTS CONTAINED THEREIN.
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Request |
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| 85 |
Filed: 7/29/2009, Entered: None |
Conversion Minute |
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MAS: MATTER ARGUED BY COUNSEL AND SUBMITTED TO THE COURT.
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Request |
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| 84 |
Filed: 7/29/2009, Entered: None |
Conversion Minute |
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AT: ATTORNEY(S): GARY M. GANSLE APPEARED ON BEHALF OF THE DEFENDANT
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Request |
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| 83 |
Filed: 7/29/2009, Entered: None |
Conversion Minute |
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AT: ATTORNEY(S): YOSEF PERETZ AND EMILY KNOLES APPEARED ON BEHALF OF THE PLAINTIFF
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Request |
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| 82 |
Filed: 7/29/2009, Entered: None |
Conversion Minute |
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Judicial Officer: Grandsaert, John L.
JCRB: HONORABLE JOHN L. GRANDSAERT, JUDGE PRESIDING. CLERK: PATRICIA A. VAN DER SCHOOR, COURT REPORTER: WENDY WACHHORST
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Request |
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| 81 |
Filed: 7/29/2009, Entered: None |
Hearing |
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Judicial Officer: Grandsaert, John L.
HEARING: DEMURRER TO COMPLAINT OF EBERHARD BY ELON MUSK, TESLA MOTORS, INC
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Request |
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| 80 |
Filed: 7/29/2009, Entered: None |
Hearing |
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Motion hearings
Judicial Officer: Grandsaert, John L.
Hearing Time: 9:00 AM
Result: Held -
Dept: LM
HEARING: MOTION RE: SPEC MOT TO STRIKE PORTIONS OF COMPL AS SLAPP FILED BY ELON MUSK, TESLA MOTORS, INC
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Request |
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| 79 |
Filed: 7/29/2009, Entered: None |
Hearing |
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Motion hearings
Judicial Officer: Grandsaert, John L.
Hearing Time: 9:00 AM
Result: Held -
Dept: LM
HEARING: MOTION RE: TO STRIKE PORTIONS OF COMPLAINT FILED BY ELON MUSK, TESLA MOTORS, INC
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Request |
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| 78 |
Filed: 7/29/2009, Entered: None |
Hearing |
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Hearing on Demurrer
Judicial Officer: Grandsaert, John L.
Hearing Time: 9:00 AM
Result: Held -
Dept: LM
HEARING: DEMURRER TO COMPLAINT OF EBERHARD BY ELON MUSK, TESLA MOTORS, INC
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Request |
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| 77 |
Filed: 7/27/2009, Entered: None |
Conversion Minute |
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*FEE: 090727-0070-ED WEB/ 5.00 MBF/ 6.00 PAYMT
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Request |
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| 76 |
Filed: 7/27/2009, Entered: None |
Conversion Action |
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EDFEE: E-DELIVERY FEES PAID.
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Request |
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| 75 |
Filed: 7/27/2009, Entered: None |
Conversion Minute |
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*FEE: 090727-0069-ED 036/ 40.00 PAYMT
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Request |
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| 74 |
Filed: 7/27/2009, Entered: None |
First Paper Fee Paid |
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FFP4: MOTION FEE PAID BY MARTIN EBERHARD.
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Request |
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| 73 |
Filed: 7/24/2009, Entered: None |
Notice |
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N2: NOTICE OF INTENT TO INTRODUCE TESTIMONY FILED BY MARTIN EBERHARD.
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Request |
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| 72 |
Filed: 7/24/2009, Entered: None |
Order |
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O: ORDER STRIKING DECLARATION, SIGNED BY JUDGE GRANDSAERT ON 07/24/09, FILED.
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Request |
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| 71 |
Filed: 7/24/2009, Entered: None |
Declaration |
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DEC: DECLARATION OF YOSEF PERETZ
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| 70 |
Filed: 7/24/2009, Entered: None |
Request |
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REQ: REQUEST FOR JUDICIAL NOTICE.
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Request |
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| 69 |
Filed: 7/24/2009, Entered: None |
Memorandum of Points & Authorities |
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MPA: MEMORANDUM OF POINTS AND AUTHORITIES FILED BY MARTIN EBERHARD IN SUPPORT OF MOTION FOR ORDER STRIKING DECLARATION
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Request |
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| 68 |
Filed: 7/24/2009, Entered: None |
Conversion Minute |
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*FEE: 090727-0012-CK 036/ 40.00 PAYMT
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Request |
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| 67 |
Filed: 7/24/2009, Entered: None |
Ex Parte |
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EPA: EX-PARTE APPLICATION FOR ORDER STRIKING DECLARATION OF MICHAEL MARKS FILED BY MARTIN EBERHARD
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Request |
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| 66 |
Filed: 7/22/2009, Entered: None |
Proof of Service |
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POSI: PROOF OF SERVICE OF DEFENDANTS' REPLY MEMORANDUM, ETC. SERVED ON YOUSEF PERETZ, EMILY BERG BY EXPRESS MAIL WITH A SERVICE DATE OF 07/22/09.
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Request |
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| 65 |
Filed: 7/22/2009, Entered: None |
Order Received |
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POR: PROPOSED ORDER RECEIVED.
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Request |
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| 64 |
Filed: 7/22/2009, Entered: None |
Document |
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FILED: DEFS' RESPONSES TO PLTF'S OBJECTIONS TO EVIDENCE IN SUPPORT OF SPECIAL MOTION TO STRIKE, FILED.
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Request |
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| 63 |
Filed: 7/22/2009, Entered: None |
Document |
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FILED: DEFS' RESPONSES TO PLTF'S OBJECTIONS TO EVIDENCE IN OPPOSITION TO SPECIAL MOTION TO STRIKE, FILED.
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Request |
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| 62 |
Filed: 7/22/2009, Entered: None |
Document |
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FILED: REPLY MPA IN SUPPORT OF DEFENDANTS' DEMURRER TO AND MOTION TO STRIKE PORTIONS OF COMPLAINT, FILED.
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Request |
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| 61 |
Filed: 7/22/2009, Entered: None |
Declaration |
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DECL: DECLARATION OF ELON MUSK IN SUPPORT OF DEFS' SPECIAL MOTION TO STRIKE PORTIONS OF PLAINTIFF'S COMPLAINT FILED BY ELON MUSK, PARTY: 0
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| 60 |
Filed: 7/22/2009, Entered: None |
Declaration |
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DECL: DECLARATION OF MICHAEL E. MARKS ISO DEFS' SPECIAL MOTION TO STRIKE PORTIONS OF PLAINTIFF'S COMPLAINT FILED BY ELON MUSK, TESLA MOTORS, INC
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| 59 |
Filed: 7/22/2009, Entered: None |
Declaration |
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 This document contains a second letter from Stanford University confirming that Elon Musk was accepted to its graduate program in Material Science Engineering in 1995. This is the same letter quoted by Ashlee Vance in the appendix to his biography of Elon Musk.
DECL: DECLARATION OF MARY BETH BROWN ISO DEFS' SPECIAL MOTION TO STRIKE PORTIONS OF COMPLAINT FILED BY ELON MUSK, TESLA MOTORS, INC
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| 58 |
Filed: 7/22/2009, Entered: None |
Document |
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FILED: REPLY MPA IN SUPPORT OF DEFS' SPECIAL MOTION TO STRIKE PORTIONS OF COMPLAINT, FILED.
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Request |
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| 57 |
Filed: 7/16/2009, Entered: None |
Order Received |
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POR: PROPOSED ORDER RECEIVED.
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Request |
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| 56 |
Filed: 7/16/2009, Entered: None |
Order Received |
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POR: PROPOSED ORDER RECEIVED.
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| 55 |
Filed: 7/16/2009, Entered: None |
Conversion Action |
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APPEND: APPENDIX OF NON-CALIF AUTHOR IN MEMO P&A TO PLTF OPP TO DEFTS SPEC MOT TO STRIKE PORTIONS OF COMP AS SLAPP FILED BY MARTIN EBERHARD
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| 54 |
Filed: 7/16/2009, Entered: None |
Document |
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FILED: PLTF INDEX OF EXHIBITS IN OPP TO DEFTS SPEC MOT TO STRIKE SLAPP, BY EBERHARD, FILED.
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Request |
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| 53 |
Filed: 7/16/2009, Entered: None |
Request For Judicial Notice |
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RJN: REQUEST FOR JUDICIAL NOTICE OF SEE LIST FILED BY MARTIN EBERHARD.
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| 52 |
Filed: 7/16/2009, Entered: None |
Declaration |
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This document includes the key court filings from the 2007 O'Reilly lawsuit against Elon Musk involving the founding of Zip2. It also contains a scanned copy of Musk's University of Pennsylvania diploma for his degree in Economics, and correspondence from Stanford University contradicted by the appendix to Ashlee Vance's biography, which relies on a second letter. The issuance of Musk's Physics degree was separately confirmed by the University of Pennsylvania in 2019.
DECL: DECLARATION OF YOSEF PERETZ IN SUPPORT OF PLTF OPP TO DEFTS SPEC MOT STRIKE PORTIONS OF COMPL AS SLAPP FILED BY MARTIN EBERHARD
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| 51 |
Filed: 7/16/2009, Entered: None |
Declaration |
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DECL: DECLARATION OF JOSHUA KATZ IN SUPPORT OF PLTF OPP TO DEFTS SPEC MOT STRIKE PORTIONS OF COMPL AS SLAPP FILED BY MARTIN EBERHARD
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| 50 |
Filed: 7/16/2009, Entered: None |
Declaration |
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DECL: DECLARATION OF CHRISMON NOFSINGER IN SUPPORT OF PLTF OPP TO DEFTS SPEC MOT STRIKE PORTIONS OF COMP AS SLAPP FILED BY MARTIN EBERHARD
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| 49 |
Filed: 7/16/2009, Entered: None |
Declaration |
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DECL: DECLARATION OF MARC TARPENNING IN SUPPORT OF PLTF OPP TO DEFTS SPEC MOT STRIKE PORTIONS OF COMPL AS SLAPP FILED BY MARTIN EBERHARD
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| 48 |
Filed: 7/16/2009, Entered: None |
Declaration |
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DECL: DECLARATION OF GENEVIEVE GUERTIN IN SUPPORT OF PLTF OPP TO DEFTS SPEC MOT STRIKE PORTIONS OF COMPL AS SLAPP FILED BY MARTIN EBERHARD
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| 47 |
Filed: 7/16/2009, Entered: None |
Declaration |
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On page 644 of this document, Elon Musk admits to being an illegal immigrant.
DECL: DECLARATION MARTIN EBERHARD IN SUPPORT OF PLTF OPP TO DEFTS SPEC MOT STRIKE PORTIONS OF COMPL AS SLAPP FILED BY MARTIN EBERHARD
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| 46 |
Filed: 7/16/2009, Entered: None |
Conversion Action |
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OBJ: OBJECTION TO TO EVIDENCE BY DEFTS IN SUKPPORT PLTF OPP TO DEFTS SPEC MOT STRIKE PORTIONS OF COMP AS SLAPP FILED BY MARTIN EBERHARD
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Request |
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| 45 |
Filed: 7/16/2009, Entered: None |
Memorandum of Points & Authorities |
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MPA: MEMORANDUM OF POINTS AND AUTHORITIES FILED BY MARTIN EBERHARD IN OPP TO DEFTS SPEC MOT TO STRIKE PORTIONS OF COMPLAINT AS SLAPP
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| 44 |
Filed: 7/16/2009, Entered: None |
Order Received |
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POR: PROPOSED ORDER RECEIVED.
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| 43 |
Filed: 7/16/2009, Entered: None |
Conversion Action |
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APPEND: APPENDIX OF NON-CALIF AUTHOR REF IN MEMO P&A TO SUPPORT PLTF OPP TO DEFTS DEMURRER & MOT TO STRIKE FILED BY MARTIN EBERHARD
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Request |
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| 42 |
Filed: 7/16/2009, Entered: None |
Request For Judicial Notice |
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RJN: REQUEST FOR JUDICIAL NOTICE OF SEE LIST FILED BY MARTIN EBERHARD.
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| 41 |
Filed: 7/16/2009, Entered: None |
Memorandum of Points & Authorities |
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MPA: MEMORANDUM OF POINTS AND AUTHORITIES FILED BY MARTIN EBERHARD IN SUPPORT OF PLTF OPP TO DEFTS DEMURRER & MOT TO STRIKE PORTIONS OF COMPLAINT
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| 40 |
Filed: 6/29/2009, Entered: None |
Conversion Minute |
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*FEE: 090629-0227-CK 036/ 40.00 PAYMT
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Request |
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| 39 |
Filed: 6/29/2009, Entered: None |
First Paper Fee Paid |
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FFP4: MOTION FEE PAID BY TESLA MOTORS, INC.
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Request |
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| 38 |
Filed: 6/29/2009, Entered: None |
Conversion Minute |
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*FEE: 090629-0225-CK 036/ 40.00 036/ 40.00 PAYMT
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Request |
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| 37 |
Filed: 6/29/2009, Entered: None |
First Paper Fee Paid |
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FFP4: MOTION FEE PAID BY ELON MUSK, TESLA MOTORS, INC.
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Request |
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| 36 |
Filed: 6/29/2009, Entered: None |
Proof of Service |
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PSN3: PROOF OF SERVICE (BY MAIL) OF (FAX) EX PARTE APPLIC FOR EXTENDING PAGE LIMIT & SUPPORTING DOCS SERVED ON SEE LIST WITH A SERVICE DATE OF 06/26/09 FILED.
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Request |
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| 35 |
Filed: 6/29/2009, Entered: None |
Proof of Service |
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PSN3: PROOF OF SERVICE (BY MAIL) OF DEFTS SPEC MOT TO STRIKE PORTIONS OF COMPL AS SLAPP & SUPPORT DOCS SERVED ON SEE LIST (BYHAND) WITH A SERVICE DATE OF 06/29/09 FILED.
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Request |
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| 34 |
Filed: 6/29/2009, Entered: None |
Order Received |
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POR: PROPOSED ORDER RECEIVED.
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| 33 |
Filed: 6/29/2009, Entered: None |
Conversion Action |
|
APPEND: APPENDIX OF NON-CALIF AUTHOR IN MEMO P&A TO SUPPORT DEFTS SPEC MOT TO STRIKE PORTIONS OF COMPL FILED BY ELON MUSK, TESLA MOTORS, INC
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| 32 |
Filed: 6/29/2009, Entered: None |
Document |
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FILED: DEFTS INDEX TO EXHIBITS IN SUPPORT OF SPEC MOT TO STRIKE PORTIONS OF COMPL, BY DEFTS, FILED.
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| 31 |
Filed: 6/29/2009, Entered: None |
Declaration |
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DECL: DECLARATION OF NICOLE H LYON IN SUPPORT OF DEFTS SPEC MOT TO STRIKE PORTIONS OF COMPL AS SLAPP FILED BY ELON MUSK, TESLA MOTORS, INC
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| 30 |
Filed: 6/29/2009, Entered: None |
Declaration |
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DECL: DECLARATION OF COLETTE R NIAZMAND IN SUPPORT OF DEFTS SPEC MOT TO STRIKE PORTIONS OF COMPL AS SLAPP FILED BY ELON MUSK, TESLA MOTORS, INC
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| 29 |
Filed: 6/29/2009, Entered: None |
Declaration |
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DECL: DECLARATION OF RACHEL KONRAD IN SUPPORT OF DEFTS SPEC MOT TO STRIKE PORTIONS OF COMPL AS SLAPP FILED BY ELON MUSK, TESLA MOTORS, INC
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| 28 |
Filed: 6/29/2009, Entered: None |
Declaration |
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DECL: DECLARATION OF EVELYN P CHIANG IN SUPPORT OF DEFTS SPEC MOT TO STRIKE PORTIONS OF COMPL AS SLAPP FILED BY ELON MUSK, TESLA MOTORS, INC
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| 27 |
Filed: 6/29/2009, Entered: None |
Declaration |
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DECL: DECLARATION OF RYAN C POPPLE IN SUPPORT OF DEFTS SPEC MOT TO STRIKE PORTIONS OF COMPL AS SLAPP FILED BY ELON MUSK, TESLA MOTORS, INC
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| 26 |
Filed: 6/29/2009, Entered: None |
Declaration |
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DECL: DECLARATION OF ELON MUSK IN SUPPORT OF DEFTS SPEC MOT TO STRIKE PORTIONS OF COMPL AS SLAPP FILED BY ELON MUSK, TESLA MOTORS, INC
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| 25 |
Filed: 6/29/2009, Entered: None |
Declaration |
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DECL: DECLARATION OF TIMOTHY M WATKINS IN SUPPORT OF DEFTS SPEC MOT TO STRIKE PORTIONS OF COMPL AS SLAPP FILED BY ELON MUSK, TESLA MOTORS, INC
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| 24 |
Filed: 6/29/2009, Entered: None |
Memorandum of Points & Authorities |
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MPA: MEMORANDUM OF POINTS AND AUTHORITIES FILED BY ELON MUSK, TESLA MOTORS, INC IN SUPPORT OF DEFTS SPEC MOT TO STRIKE PORTIONS OF COMPLAINT AS SLAPP (CCP 425.16)
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| 23 |
Filed: 6/29/2009, Entered: None |
Motion |
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NM: NOTICE OF MOTION SPEC MOT TO STRIKE PORTIONS OF COMPLAINT AS SLAPP (CCP 425.16) FILED BY ELON MUSK, TESLA MOTORS, INC
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| 22 |
Filed: 6/29/2009, Entered: None |
Proof of Service |
|
PSN3: PROOF OF SERVICE (BY MAIL) OF DEMURRER & MOT TO STRIKE PORTIONS OF COMPLAINT & SUPPORTING DOCS SERVED ON SEE LIST (BYHAND) WITH A SERVICE DATE OF 06/29/09 FILED.
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| 21 |
Filed: 6/29/2009, Entered: None |
Order Received |
|
POR: PROPOSED ORDER RECEIVED.
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| 20 |
Filed: 6/29/2009, Entered: None |
Conversion Action |
|
APPEND: APPENDIX OF NON-CALIF AUTHOR REF IN MEMO P&A TO SUPPORT DEFTS DEMURRER & MOT TO STRIKE PORTIONS OF COMPL FILED BY ELON MUSK, TESLA MOTORS, INC
|
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| 19 |
Filed: 6/29/2009, Entered: None |
Memorandum of Points & Authorities |
|
MPA: MEMORANDUM OF POINTS AND AUTHORITIES FILED BY ELON MUSK, TESLA MOTORS, INC IN SUPPORT OF DEFTS DEMURRER & MOT TO STRIKE PORTIONS OF COMPLAINT
|
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|
| 18 |
Filed: 6/29/2009, Entered: None |
Motion |
|
NM: NOTICE OF MOTION TO STRIKE PORTIONS OF COMPLAINT FILED BY ELON MUSK, TESLA MOTORS, INC
|
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Request |
|
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| 17 |
Filed: 6/29/2009, Entered: None |
Conversion Action |
|
DEM: (S) DEMURRER TO COMPLAINT OF EBERHARD FILED BY ELON MUSK, TESLA MOTORS, INC REPRESENTED BY GARY M. GANSLE
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Request |
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| 16 |
Filed: 6/26/2009, Entered: None |
Conversion Action |
|
SO2: STIPULATION AND ORDER EXTENDING PAGE LIMIT ON MEMO P&A SIGNED BY JOHN L. GRANDSAERT ON 06/26/09.
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|
| Save 25% on a pre-paid one year subscription. |
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| 15 |
Filed: 6/26/2009, Entered: None |
Declaration |
|
DECL: DECLARATION OF STEPHEN TAEUSCH IN SUPPORT OF DEFTS APPLIC FOR ORDER EXTENDING PAGE LIMIT FILED BY ELON MUSK, TESLA MOTORS, INC
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| 14 |
Filed: 6/26/2009, Entered: None |
Memorandum of Points & Authorities |
|
MPA: MEMORANDUM OF POINTS AND AUTHORITIES FILED BY ELON MUSK, TESLA MOTORS, INC IN SUPPORT OF APPLIC FOR ORDER EXTENDING PAGE LIMIT ON MEMO P&A
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| 13 |
Filed: 6/26/2009, Entered: None |
Ex Parte |
|
EPA: EX-PARTE APPLICATION FOR ORDER EXTENDING PAGE LIMIT ON DEFT MEMO P&A FILED BY ELON MUSK, TESLA MOTORS, INC
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| 12 |
Filed: 6/26/2009, Entered: None |
Conversion Action |
|
AAD: ATTORNEY ADDED FOR THE DEFENDANT(S)/RESPONDENT(S) ELON MUSK, TESLA MOTORS, INC. ATTORNEY: STEPHAN L TAEUSCH.
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|
Request |
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| 11 |
Filed: 6/26/2009, Entered: None |
Conversion Minute |
|
*FEE: 090626-0225-CC 027/ 700.00 PAYMT
|
|
Request |
|
|
|
| 10 |
Filed: 6/26/2009, Entered: None |
First Paper Fee Paid |
|
FFP: FIRST PAPER FEE PAID BY ELON MUSK, TESLA MOTORS, INC.
|
|
Request |
|
|
|
| 9 |
Filed: 6/16/2009, Entered: None |
Document |
|
FILED: DECLARATION OF BERG IN SUPPORT OF PLNT'S EBERHARD' EX PARTE APPLICATION REDACTING SS# FROM EXHIBIT 3, FILED.
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| 8 |
Filed: 6/16/2009, Entered: None |
Document |
|
FILED: ORDER GRANTING PLNT'S EBERHARD'S ION FOR ORDER REDACTING SS# FROM EXHIBIT #3, FILED.
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| 7 |
Filed: 6/16/2009, Entered: None |
Document |
|
FILED: MEMORANDUM OF P&A'S OF PLNT EBERHARD EXPARTE ORDER REDACTING SS# FROM EXHIBIT #3, FILED.
|
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| 6 |
Filed: 6/16/2009, Entered: None |
Document |
|
FILED: PLNTF EBERHARD'S EX PARTE APPLICATION FOR ORDER REDACTING SS# FROM EXHIBIT #3, FILED.
|
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| 5 |
Filed: 5/26/2009, Entered: None |
Affidavit |
|
AFFIDAVIT OF PERSONAL DELIVERY BY R. LOPEZ FILED
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|
| 4 |
Filed: 5/26/2009, Entered: None |
Summons |
|
30 DAY SUMMONS, ISSUED AND FILED.
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|
| 3 |
Filed: 5/26/2009, Entered: None |
Civil Case Cover Sheet |
|
CIVIL CASE COVERSHEET RECEIVED
|
|
|
|
|
|
| 2 |
Filed: 5/26/2009, Entered: None |
Conversion Minute |
|
*FEE: 090527-0198-CK 026/ 350.00 PAYMT
|
|
Request |
|
|
|
| 1 |
Filed: 5/26/2009, Entered: None |
Complaint |
|
COMPLAINT
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