NOTICE OF MODIFICATION AND RELOCATION OF DANCING ON THE BRINK OF THE WORLD BY TONY BERLANT– OPPORTUNITY FOR ARTIST OR REPRESENTATIVE TO REMOVE PURSUANT TO CIVIL CODE § 989 Please take notice that the City and County of San Francisco intends to modify and relocate Tony Berlant's Dancing on the Brink of the World (1987), currently in fine art storage, in preparation for its reinstallation as part of the SFO Terminal 3 West Modernization Project. The artist or their representative, as defined by Civil Code § 989(1)(b), may remove the Work from storage or pay for its removal. Agreement to remove the Work must be received by the City within 30 days of this Notice and removal and payment must occur within 90 days of this Notice. If the work does not undergo modification and relocation, it will remain in fine arts storage. Future relocation is not guaranteed.
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SUMMONS
(CITACION JUDICIAL)
CASE NUMBER (NUMERO DE CASO): 25CV114162
NOTICE! You have been sued. The court may decide against you without your being heard unless you respond within 30 days. Read the information below.
You have 30 CALENDAR DAYS after this summons and legal papers are served on you to file a written response at this court and have a copy served on the plaintiff. A letter or phone call will not protect you. Your written response must be in proper legal form if you want the court to hear your case. There may be a court form that you can use for your response. You can find these court forms and more information at the California Courts Online Self-Help Center (www.courtinfo.ca.gov/selfhelp), your county law library, or the courthouse nearest you. If you cannot pay the filing fee, ask the court clerk for a fee waiver form. If you do not file your response on time, you may lose the case by default, and your wages, money, and property may be taken without further warning from the court.
There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may want to call an attorney referral service. If you cannot afford an attorney, you may be eligible for free legal services from a nonprofit legal services program. You can locate these nonprofit groups at the California Legal Services Web site (www.lawhelpcalifornia.org), the California Courts Online Self-Help Center (www.courtinfo.ca.gov/selfhelp), or by contacting your local court or county bar association. NOTE: The court has a statutory lien for waived fees and costs on any settlement or arbitration award of $10,000 or more in a civil case. The court's lien must be paid before the court will dismiss the case.
¡AVISO! Lo han demandado. Si no responde dentro de 30 días, la corte puede decidir en su contra sin escuchar su versión. Lea la información a
continuación.
Tiene 30 DÍAS DE CALENDARIO después de que le entreguen esta citación y papeles legales para presentar una respuesta por escrito en esta corte y hacer que se entregue una copia al demandante. Una carta o una llamada telefónica no lo protegen. Su respuesta por escrito tiene que estar en formato legal correcto si desea que procesen su caso en la corte. Es posible que haya un formulario que usted pueda usar para su respuesta. Puede encontrar estos formularios de la corte y más información en el Centro de Ayuda de las Cortes de California (www.sucorte.ca.gov), en la biblioteca de leyes de su condado o en la corte que le quede más cerca. Si no puede pagar la cuota de presentación, pida al secretario de la corte que le dé un formulario de exención de pago de cuotas. Si no presenta su respuesta a tiempo, puede perder el caso por incumplimiento y la corte le podrá quitar su sueldo, dinero y bienes sin más advertencia.
Hay otros requisitos legales. Es recomendable que llame a un abogado inmediatamente. Si no conoce a un abogado, puede llamar a un servicio de remisión a abogados. Si no puede pagar a un abogado, es posible que cumpla con los requisitos para obtener servicios legales gratuitos de un programa de servicios legales sin fines de lucro. Puede encontrar estos grupos sin fines de lucro en el sitio web de California Legal Services,
(www.lawhelpcalifornia.org), en el Centro de Ayuda de las Cortes de California, (www.sucorte.ca.gov) o poniéndose en contacto con la corte o el colegio de abogados locales. AVISO: Por ley, la corte tiene derecho a reclamar las cuotas y los costos exentos por imponer un gravamen sobre cualquier recuperación de $10,000 ó más de valor recibida mediante un acuerdo o una concesión de arbitraje en un caso de derecho civil. Tiene que
pagar el gravamen de la corte antes de que la corte pueda desechar el caso.
The name and address of the court is (El nombre y direccion de la corte es): Superior Court of California County of Alameda – Rene C. Davidson Courthouse, 1225 Fallon Street, Oakland, CA 94612
The name, address, and telephone nuber of the plaintiff's attorney, or plaintiff without an attorney, is (El nombre, la direccion y el numero del abogado del demandante, o del demandante que no tiene abogado, es): Christopher K. Roberts, Esq. (SBN 232791) | Nicholas I. Myers, Esq. (SBN 322661), 9100 Wilshire Blvd, Suite 465E, Beverly Hills, CA 90212. TEL: 310-777-7877 FAX: 310-777-7855
Date (Fecha) 3/11/2025 Chad Finke, Executive Officer / Clerk of the Court Clerk, by (Secretario) D. Franklin, Deputy (Adjunto) (Seal)
Plaintiff's Complaint for Damages and Personal Injuries
1. Negligence
2. Negligent Entrustment
Demand for a Jury Trial
Plaintiff ROMEO TEJADA MANCIA ("Plaintiff") alleges as follows:
PARTIES
1. Plaintiff ROMEO TEJADA MANCIA is, and at all times relevant hereto was, an individual residing in the County of Contra Costa, State of California.
2. Defendant NOEMIE AVIVA SERFATY ("Defendant SERFATY") is, and at all times relevant hereto was, an individual residing in the County of San Francisco, State of California.
3. Defendant JEREMY ADAM MILLER ("Defendant MILLER") is, and at all times relevant hereto was, an individual residing in the County of San Francisco, State of California, and the registered owner of the vehicle driven by Defendant SERFATY at the time of the collision.
4. Plaintiff is ignorant of the true names and capacities of Defendants sued herein as DOES 1 through 20, inclusive, and therefore sues these Defendants by such fictitious names. Plaintiff will amend this Complaint to allege their true names and capacities when ascertained. Plaintiff is informed and believes, and thereon alleges, that each of the fictitiously named Defendants is responsible in some manner for the occurrences herein alleged, and that Plaintiff's injuries as herein alleged were proximately caused by such Defendants.
5. Plaintiff is informed and believes, and thereon alleges, that at all times herein mentioned, all Defendants, including DOES 1 through 20, inclusive, (individually, and togther, referred to herein as "Defendants") and each of them, were the agents, servants, employees, joint venturers, and/or partners of the remaining Defendants, and were, as such, acting within the course and scope of said agency, employment, joint venture, and/or partnership, and that each and every Defendant, as aforesaid, when acting as a principal, was negligent in the selection, hiring, and supervision of each and every other Defendant as an agent, servant, employee, joint venturer, and/or partner.
JURISDICTION AND VENUE
6. Venue is proper in this Court because the accident which forms the basis of this action occurred in the County of Alameda, State of California.
FACTS COMMON TO ALL CAUSES OF ACTION
7. On or about April 30, 2023, at approximately 7:13 p.m., Plaintiff was lawfully operating a 2022 Ram Tow Truck while traveling southbound on Interstate 580 between Oakland and San Leandro in lane #2.
8. At the same time, Defendant SERFATY was operating a 2001 Toyota Tacoma owned by Defendant MILLER while traveling southbound on Interstate 580 in lane #3, to the right of Plaintiff.
9. Defendant SERFATY was traveling at an unsafe speed, lost control of her vehicle, and abruptly turned the steering wheel to the left, causing her to merge into Plaintiff's lane of travel, in direct violation of California Vehicle Code § 21658(a).
10. As a direct result of Defendant SERFATY's unsafe and unlawful lane change, the left front side of the Toyota Tacoma she was driving collided with the right front side of Plaintiff's vehicle.
11. As stated in the California Highway Patrol Traffic Collision Report (Report No. 9370-2023-01334), Defendant SERFATY admitted she was "going too fast" and "lost control" of her vehicle. Defendant SERFATY turned her vehicle from a direct course of travel into lane #2, an area already occupied by Plaintiff's vehicle, causing the collision.
12. The California Highway Patrol determined that Defendant SERFATY violated California Vehicle Code § 21658(a) by making an unsafe lane change, which was the primary cause of the collision.
FIRST CAUSE OF ACTION NEGLIGENCE
(Against All Defendants)
13. Plaintiff incorporates by reference all preceding paragraphs as though fully set forth herein.
14. At all times herein mentioned, Defendants, and each of them, owed a duty of reasonable care to Plaintiff in the operation of their motor vehicles on public roadways.
15. Defendant SERFATY breached said duty of care by: a. Operating a motor vehicle at an excessive speed; b. Failing to maintain proper control of her vehicle; c. Making an unsafe lane change in violation of
California Vehicle Code § 21658(a); d. Failing to keep a proper lookout for other vehicles; e. Failing to operate her vehicle in a safe and reasonable manner; and f. Otherwise failing to exercise the care and caution that a reasonably prudent person would exercise under similar circumstances.
16. Defendant MILLER, as the owner of the vehicle driven by Defendant SERFATY, is vicariously liable for Defendant SERFATY's negligence pursuant to California Vehicle Code § 17150.
17. At all relevant times here Defendants, and each of them, negligently owned, leased, repaired, maintained, and operated said vehicle.
18. As a direct and proximate result of the aforementioned negligence of Defendants, and each of them, Plaintiff suffered severe bodily injuries causing past and future physical pain, suffering, and loss of enjoyment of life.
19. As a further direct and proximate result of the aforementioned negligence of Defendants, and each of them, Plaintiff has incurred, and will continue to incur, medical and related expenses.
20. As a further direct and proximate result of the aforementioned negligence of Defendants, and each of them, Plaintiff has suffered, and will continue to suffer, lost wages and loss of earning capacity.
SECOND CAUSE OF ACTION
NEGLIGENT ENTRUSTMENT
(Against Defendant MILLER and DOES 1-20)
21. Plaintiff incorporates by reference all preceding paragraphs as though fully set forth herein.
22. Plaintiff is informed and believes, and thereon alleges, that Defendant MILLER was the owner of the 2001 Toyota Tacoma being operated by Defendant SERFATY at the time of the collision.
23. Plaintiff is informed and believes, and thereon alleges, that Defendant MILLER entrusted his vehicle to Defendant SERFATY.
24. Defendants, while engaged as employees and agents of each, the other, did so negligently hire, train, supervise & retain Defendant SERFATY, and the remaining Defendants.
25. Plaintiff is informed and believes, and thereon alleges, that Defendant MILLER knew, or should have known, that Defendant SERFATY was an incompetent or unfit driver and that entrusting his vehicle to her created an unreasonable risk of harm to others.
26. Defendant SERFATY's negligent operation of the entrusted vehicle was a foreseeable result of Defendant MILLER's negligent entrustment.
27. As a direct and proximate result of Defendant MILLER's negligent entrustment, Plaintiff sustained severe and permanent injuries, as set forth above.
28. Plaintiff has been unable to work since the date of the accident, resulting in substantial lost wages and loss of earning capacity.
29. As a further direct and proximate result of the aforementioned acts of Defendants, and each of them, Plaintiff has suffered, and will continue to suffer, general damages including physical pain, mental suffering, loss of enjoyment of life, inconvenience, emotional distress, and other damages in an amount to be proven at trial.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff prays for judgment against the Defendants, and each of them, as follows:
(1) For economic damages, including lost wages, lost employee benefits, medical expenses and other economic obligations incurred according to proof at trial;
(2) For non-economic damages, including physical pain and suffering, loss of enjoyment of life and anxiety associated with his injuries;
(3) For pre-judgment interest at the maximum legal rate;
(4) For post-judgment interest at the maximum legal rate;
(5) For costs of suit herein incurred;
(6) For such other relief that at the Court may deem just and proper.
DEMAND FOR JURY TRIAL
Plaintiff requests that the present matter be set for jury trial.
DATED: March 11, 2025
RAFII & ASSOCITES, P.C.
CHRISTOPHER K. ROBERTS, ESQ.
NICHOLAS I. MYERS, ESQ.
Attorneys for Plaintiff,
ROMEO TEJEDA MANCIA Show more »
Refcode: #IPLSFC01353140
NOTICE OF LIEN SALE
IStorage SELF STORAGE
Notice is hereby given pursuant to California Business and Professional Codes # 21700-21716, Section 2328 of the UCC of the Penal Code Section 535 the Under-Signed, IStorage, will sell at public sale on or after said date with bidding to take place on Storage Treasures.com the following misc. goods: Thursday the 14th day of May, 2026 at 10:00AM-
IStorage, 4050 19th Ave, San Francisco, CA 94132-Bonnie Levy, Vandigriff Mary, Adam Shelton I, Cristino Castillo, Aiyana Homans
Goods must be paid by credit card, debit card, or money order only and removed within 48 hours of sale. Sale is subject to cancellation in the event of settlement between owner and obligated party. Show more »
Refcode: #IPLSFC01363170
Notice is hereby given that Timothy Daniel Godley has filed a petition with the San Francisco County Superior Court requesting a change of name to Timothy Daniel Rosewall-Godley. Any person who objects to the proposed change must file a written objection with the court before the scheduled hearing date of May 14, 2026. Show more »
Refcode: #IPLSFC01345410
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