"

Cllmi of Appeal. Third Appellate District Courl of Appeal. Third Appellate Di.-;trkl
Deenu C. l':twceU. ClerkJAdministrator Deena C. l'awcett, ClerkJAJ.ministmlor
Electrc:mically RECEIVED on 2/Z/ZO 16 by Workflow Service, Depuly Clerk Electronically FILED on Z/2/2016 by K. WoJnarowslti. Deputy Clerk

NO. C071887

IN THE COURT OF APPEAL

OF THE STATE OF CALIFORNIA
THIRD APPELLATE DISTRICT

SUSAN C. FERRIS,
Appellant,

v.

DAVID M. FERRIS,
Respondent.

Appeal From the Sacramento Superior Court

Case No. 98FL05615

Hon. Matthew Gary, Judge Presiding

MOTION TO DISMISS

R. PARKER WHITE, (SBN 95579)

POSW ALL, WHITE & BRELSFORD
1001 G Street, Suite 301
Sacramento, CA 95814
Tel: (916) 449-1300
Fax: (916) 449-1320

Attorney for Respondent

DAVID FERRIS
 MOTION TO DISMISS

INTRODUCTION

This matter was taken under submission by this court in November

20 13. The appellant, Susan Ferris is seeking the reversal of a court order

prohibiting any contact with her daughter. The sole base of the request is that

at the time of the order, the appellant was not represented by counsel.

This court was asked to determine that: 1) appellant asked for an

attorney and wanted to be represented by counsel; and 2) had an attorney

been appointed and had appellant been represented it would have made any

difference at all.

THE ISSUE IS NOW MOOT; CHIL.D IS NO LONGER A MINOR

The child at the center of this matter is no longer a minor. She turned

age eighteen ( 18) on September 19, 20 15. Therefore, respondent respectfully

requests that the court dismiss appellant's challenge to the lower court's order

as it is moot.

Dated: February 2, 20 16 Respectfully submitted,

POSWALL, WHITE & BRELSFORD

By R. Parker White
R. PARKER WHITE

CALIFORNIA JUDICIAL BRANCH NEWS SERVICE CJBNS.ORG

 DECLARATION OF R. PARKER WHITE

I, R. PARKER WHITE, declare as follows:

I was personally at the hospital immediately after the subject child's

birth. She turned eighteen (18) on September 19, 2015.

I declare under penalty of perjury under the laws of the State of

California that the foregoing is true and correct, and that this Declaration was

executed on February 2, 2016, in Sacramento, California.

R. Parker White
R. PARKER WHITE

3
FERRIS V. FERRIS
COURT OF APPEAL OF THE STATE OF CALIFORNIA
THIRD APPELLATE DISTRICT
CASE NO.: C071887

PROOF OF SERVICE

I am a citizen of the United States and a resident of the county of

Sacramento. I am over the age of 18 years and not a party to the within above
entitled action; my business address is 1001 G Street, Suite 301, Sacramento,
California 95814. I am readily familiar with the firm's practice for the collection and
processing of correspondence for mailing with the United States Postal Service.

On the below date, I served the MOTION TO DISMISS in said action as

addressed below by causing a true copy thereof to be:

Mailed
__ Personally Delivered
__ Federal Express
Faxed
See below

ADDRESSED AS FOLLOWS:

James J. Brosnahan William Kennedy

Kevin Calia
MORRISON & FOERSTER, LLP
425 Market Street
San Francisco, CA 94105-2482
via overnight delivery
Supreme Court of California
350 McAllister Street
San Francisco, CA 94102
Served Electronically via
Appellate District
Stephen E. Goldberg
LEGAL SERVICES OF NORTHERN
CALIFORNIA
512 121h Street
Sacramento, CA 95814
via overnight delivery
Clerk of the Court
Sacramento County Superior Court
Third 3314 Power Inn Road, Room 314
Sacramento, CA 95826
via overnight delivery

I declare under penalty of perj ury under the laws of the State of California
that the foregoing is true and correct. Executed February 2, 2016, at Sacramento,
California.

Kendra Clancy