MEMO

 

TO:       Superior Court of California

          Attention: Doreen, Department 71

          P.O. Box 122724

          San Diego 92112-2724

          CALIFORNIA, USA

 

FROM:     Paul Andrew Mitchell, Plaintiff

          Mitchell v. AOL Time Warner, Inc. et al.

          Case Number: GIC807057

 

DATE:     May 7, 2003 A.D.

 

SUBJECT:  Telephonic Hearing, June 13, 2003, 2:00 p.m.

 

 

Dear Doreen,

 

Your assistance yesterday morning was most kind, professional, and most appreciated.  Thank you again for understanding my extraordinary situation for not having a private telephone in my hotel room.

 

Due to your fine directions, by the time you receive this letter our FIRST AMENDED NOTICE OF HEARING ON MOTION TO BAR REMOVAL will be completed, and hopefully ready for mailing.

 

The Reference Librarians at the County Law Library provided us with the caption language recommended by Superior Court Rule 2.19 (“tentative ruling, no appearance required”).

 

Our task this time was made unusually complicated by the many different situations that arose after mailing round one of the SUMMONS and Initial COMPLAINT.

 

Our PROOF OF SERVICE will show the mailing addresses we are using for round two, if round one did not perfect service on any named Defendant (no green card if out-of-State, or no acknowledgment if in-State).

 

Other special situations also developed after round one, e.g. some Defendants are reported to be incarcerated;  others refused round one.

 

At the very end of our PROOF OF SERVICE, we are adding two summary tables giving reasons why certain California Defendants and certain out-of-State (foreign) Defendants will not be served by mail with this AMENDED NOTICE.

 

Lastly, if named Defendants are also defendants in the federal case, we plan to send a Courtesy Copy to their attorney(s) of record.

 

All pertinent details, and instructions for ordering hard copies of SUPPLEMENT’s, will be set out in the body of this AMENDED NOTICE.

 

Kay Rowland, Notary Public, will follow shortly with batch one of her PROOF OF SERVICE of SUMMONS and Initial COMPLAINT.

 

 

We anxiously look forward to litigating this entire case before the Superior Court of California, Hon. Janis Sammartino presiding.

 

By the way, our PETITION FOR WRIT OF CERTIORARI to the Supreme Court of the United States is almost finished too.  We plan to file a copy of that Petition as another Exhibit in the case before your Court.

 

Each time we approach the subject, our understanding of the complex Act of June 25, 1948, improves like a fine wine.

 

Thank you again for your kind and professional assistance.

 

 

Sincerely yours,

 

/s/ Paul Andrew Mitchell

 

Paul Andrew Mitchell, B.S., M.S.

Private Attorney General and Plaintiff

 

copy:  Kay Rowland, Notary Public and Agent for PROOF OF SERVICE