December 10, 2003
To: Kelly Angell
From: Maura Larkins by FAX only to 619 232 3264
The date on the attached proof of service is incorrect. Some but not all of
these items were faxed on December 9, 2003. Also, the proof of service
which was faxed on December 9, 2003 was incorrect in that it stated that the
transmission was complete, when it fact it was not. Also, no transmission
report was sent with either the December 9th or 10th proofs of FAX service.
In the future, please comply with the rules for service by FAX by sending me a
copy of the transmission report as required by Cal. Rules of Court, Rule 2008
(e). YOU HAVE NEVER SENT ME A TRANSMISSION REPORT REGARDING
ANY FAX SERVICE.
You spoke falsely to the court on August 22, 2003 when you said that you
had FAX served on me your Opposition to my Motion to File a 5AC. You did
not FAX serve it.
I would think that you would want to apologize to me for your suggestion in
open court that I perjured myself when I stated in court that I received your
Opposition papers two days after they were filed. How will you maintain
anyone’s respect for your professional ethics if you fail to withdraw such an
indefensible insult to your opposing “counsel” (to use your own words)?
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