Synergy Project Management, Inc. Vs. City And County Of San Francisco

1ST AMENDED COMPLAINT (TRANSACTION ID # 17290051) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC. AS TO DEFENDANT CITY AND COUNTY OF SAN FRANCISCO SAN FRANCISCO PUBLIC UTILITIES COMMISSION SAN FRANCISCO MUNICIPAL TRANSPORTATION AGENCY SAN FRANCISCO DEPARTMENT OF PUBLIC WORKS BREED, LONDON , IN HER INDIVIDUAL CAPACITY AND, ALTERNATIVELY, IN HER CAPACITY AS A MEMBER OF THE SAN FRANCISCO BOARD OF SUPERIVISORS NURU, MOHAMMED , IN HIS INDIVIDUAL CAPACITY AND, ALTERNATIVELY, IN HIS CAPACITY AS SAN FRANCISCO DIRECTOR OF PUBLIC WORKS DOES 1-100

REPLY IN SUPPORT OF DEMURRER (TRANSACTION ID # 67740571) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

OPPOSITION TO SYNERGY PROJECT MANAGEMENT, INC.S MOTION FOR LEAVE TO FILE FOURTH AMENDED COMPLAINT AND TO SUBSTITUTE HARLAN KELLY FOR DOE 1 (TRANSACTION ID # 67307513) FILED BY DEFENDANT GHILOTTI BROS., INC.

NOTICE OF ERRATA IN MOTION FOR LEAVE TO AMEND (TRANSACTION ID # 67296051) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

NOTICE OF ERRATA IN 6-14-22 OPPOSITION TO CITY DEFENDANTS DEMURRER (TRANSACTION ID # 67727564) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

OPPOSITION TO CITY DEFENDANTS' MOTION TO STRIKE PORTIONS OF FOURTH AMENDED COMPLAINT (TRANSACTION ID # 67726343) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

ORDER GRANTING MOTION FOR CONTINUANCE OF TRIAL

SUPPLEMENTAL DECL OF COUNSEL BEN ROSENFELD ISO PLAINTIFF SYNERGYS PENDING MOTION FOR LEAVE TO AMEND FILED ON 1-31-22 (TRANSACTION ID # 67282511) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

DECLARATION OF PLAINTIFF SYNERGYS COUNSEL BEN ROSENFELD CORRECTING CITY DEFENDANTS MISREPRESENTATION OF SYNERGYS POSITION IN DEFENDANTS MOTION TO CONTINUE TRIAL (TRANSACTION ID # 67279482) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

NOTICE OF ENTRY OF ORDER/NOTICE OF RULING FILED (TRANSACTION ID # 67290146) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF COUNSEL IN SUPPORT OF PLAINTIFF SYNERGY'S OPPOSITION TO CITY DEFENDANTS' DEMURRER, AND EXHIBITS THERETO (TRANSACTION ID # 67726271) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

DECLARATION OF OF BEN ROSENFELD AND CCP 1008B AFFIDAVIT OF COUNSEL BEN ROSENFELD ISO MO FOR LEAVE TO AMEND, WITH EXHIBITS (TRANSACTION ID # 67279048) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

OPPOSITION TO CITY DEFENDANTS' DEMURRER (TRANSACTION ID # 67726271) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF OPPOSITION TO SYNERGY PROJECT MANAGEMENT INCS MOTION TO REINSTATE DEFENDANTS LONDON BREED AND MOHAMMED NURU PURSUANT TO CCP 473, 474, AND 475 (TRANSACTION ID # 67726204) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO SYNERGY PROJECT MANAGEMENT INCS MOTION TO REINSTATE DEFENDANTS LONDON BREED AND MOHAMED NURU PURSUANT TO CCP 473, 474, AND 475 (TRANSACTION ID # 67726204) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

RE-NOTICE AND MOTION FOR LEAVE TO AMEND COMPLAINT, AND WITHDRAWAL OF PREVIOUS MOTION, PROOF OF SERVICE, POINTS AND AUTHORITIES (CRT RPT FEE) (TRANSACTION ID # 67279048) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC. HEARING SET FOR FEB-25-2022 AT 09:30 AM IN DEPT 302

DECLARATION OF JAIME M HULING-DELAYE IN SUPPORT OF OPPOSITION TO SYNERGY PROJECT MANAGEMENT INCS MOTION TO REINSTATE DEFENDANTS LONDON BREED AND MOHAMMED NURU PURSUANT TO CCP 473, 474, AND 475 (TRANSACTION ID # 67726204) (TRANSACTION ID # 67726204) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF PLAINTIFFS COUNSEL BEN ROSENFELD, AND EXHIBITS (TRANSACTION ID # 67697920) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

PROOF OF SERVICE BY ELECTRONIC MAIL (TRANSACTION ID # 67692418) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

EX PARTE APPLICATION FOR ORDER CONSOLIDATING PENDING PLEADINGS-RELATED MOTIONS ON SAME HEARING DATE, PROOF OF SERVICE, POINTS AND AUTHORITIES (TRANSACTION ID # 67697920) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

DECLARATION OF ARI A. BARUTH IN SUPPORT OF DEFENDANT CITY AND COUNTY OF SAN FRANCISCO?S REPLY IN SUPPORT OF ITS OBJECTION TO TRIAL SETTING ORDER AND MOTION TO CONTINUE TRIAL OR IN THE ALTERNATIVE, FOR SEPARATE TRIALS (TRANSACTION ID # 67271125) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF BEN ROSENFELD ISO PLAINTIFF SYNERGYS NOTICE AND MOTION TO REINSTATE DEFENDANTS BREED AND NURU PURSUANT TO CCP 474, 474, AND 475, AND EXHIBITS (TRANSACTION ID # 67686923) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

PROOF OF SERVICE (TRANSACTION ID # 67271125) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

REPLY IN SUPPORT OF ITS OBJECTION TO TRIAL SETTING ORDER AND MOTION TO CONTINUE TRIAL OR IN THE ALTERNATIVE, FOR SEPARATE TRIALS (TRANSACTION ID # 67271125) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

PLAINTIFF SYNERGYS NOTICE AND MOTION TO REINSTATE DEFENDANTS BREED AND NURU PURSUANT TO CCP 474, 474, AND 475, PROOF OF SERVICE, POINTS AND AUTHORITIES (TRANSACTION ID # 67686923) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC. HEARING SET FOR JUN-27-2022 AT 09:30 AM IN DEPT 302

REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF LIMITED OPPOSITION TO THE CITY AND COUNTY OF SAN FRANCISCO'S OBJECTION TO TRIAL SETTING ORDER AND MOTION TO CONTINUE TRIAL OR, IN THE ALTERNATIVE, FOR SEPARATE TRIALS (TRANSACTION ID # 67255596) FILED BY DEFENDANT GHILOTTI BROS., INC.

DECLARATION OF JAIME M. HULING DELAYE IN SUPPORT OF DEFENDANT CITY AND COUNTY OF SAN FRANCISCO?S REPLY IN SUPPORT OF ITS OBJECTION TO TRIAL SETTING ORDER AND MOTION TO CONTINUE TRIAL OR, IN THE ALTERNATIVE FOR SEPARATE TRIALS (TRANSACTION ID # 67271125) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF COUNSEL BEN ROSENFELD IN SUPPORT OF MOTION TO REINSTATE DEFENDANTS BREED AND NURU, AND EXHIBITS (TRANSACTION ID # 67681914) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

PROOF OF SERVICE BY ELECTRONIC MAIL (TRANSACTION ID # 67670913) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF MOTION TO STRIKE PORTIONS OF SYNERGY PROJECT MANAGEMENT INC.'S FOURTH AMENDED COMPLAINT (TRANSACTION ID # 67670913) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

NOTICE AND MOTION TO REINSTATE DEFENDANTS LONDON BREED AND MOHAMMED NURU (TRANSACTION ID # 67681914) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC. GHLOTTI BROS., INC., A CALIFORNIA CORPORATION HEARING SET FOR JUN-23-2022 AT 09:30 AM IN DEPT 302

OPPOSITION TO THE CITY AND COUNTY OF SAN FRANCISCO'S OBJECTION TO TRIAL SETTING ORDER AND MOTION TO CONTINUE TRIAL OR, IN THE ALTERNATIVE, FOR SEPARATE TRIALS (TRANSACTION ID # 67255596) FILED BY DEFENDANT GHILOTTI BROS., INC.

DECLARATION OF KRISTINE POPLAWSKI IN SUPPORT OF DEFENDANT CITY AND COUNTY OF SAN FRANCISC'S MOTION TO STRIKE PORTIONS OF SYNERGY PROJECT MANAGEMENT INC.'S FOURTH AMENDED COMPLAINT (TRANSACTION ID # 67670913) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF JAIME M. HULING DELAYE IN SUPPORT OF DEFENDANT CITY AND COUNTY OF SAN FRANCISCO'S DEMURRER TO SYNERGY PROJECT MANAGEMENT INC.'S FOURTH AMENDED COMPLAINT (TRANSACTION ID # 67670870) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

MOTION TO STRIKE 4TH AMENDED COMPLAINT (TRANSACTION ID # 67670913) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO HEARING SET FOR JUN-23-2022 AT 09:30 AM IN DEPT 302

EXHIBIT 19 TO EXHIBIT 24 OF DEFENDANT CITY AND COUNTY OF SAN FRANCISCO'S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEMURRER TO SYNERGY PROJECT MANAGEMENT INC.'S FOURTH AMENDED COMPLAINT (TRANSACTION ID # 67670870) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF PLAINTIFFS COUNSEL BEN ROSENFELD (TRANSACTION ID # 67255420) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

OPPOSITION TO CITY DEFENDANTS MOTION TO CONTINUE TRIAL (TRANSACTION ID # 67255420) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC. GHLOTTI BROS., INC., A CALIFORNIA CORPORATION

DECLARATION OF PLAINTIFFS FORMER COUNSEL JOHNNY KNADLER (TRANSACTION ID # 67255420) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

EXHIBIT 13 TO EXHIBIT 18 OF DEFENDANT CITY AND COUNTY OF SAN FRANCISCO'S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEMURRER TO SYNERGY PROJECT MANAGEMENT INC.'S FOURTH AMENDED COMPLAINT (TRANSACTION ID # 67670870) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO STRIKE PORTIONS OF SYNERGY PROJECT MANAGEMENT, INC.'S FOURTH AMENDED COMPLAINT (TRANSACTION ID # 67670913) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF PLAINTIFFS COUNSEL BEN ROSENFELD ISO MOTION FOR LEAVE... (TRANSACTION ID # 67251790) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

PROOF OF SERVICE BY ELECTRONIC MAIL (TRANSACTION ID # 67670870) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

EXHIBIT 12 OF DEFENDANT CITY AND COUNTY OF SAN FRANCISCO'S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEMURRER TO SYNERGY PROJECT MANAGEMENT INC.'S FOURTH AMENDED COMPLAINT (TRANSACTION ID # 67670870) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

PROOF OF SERVICE BY ELECTRONIC MAIL ON RE-NOTICE OF CITY AND COUNTY OF SAN FRANCISCO'S OBJECTION TO TRIAL SETTING ORDER AND MOTION TO CONTINUE TRIAL OR, IN THE ALTERNATIVE, FOR SEPARATE TRIALS; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF; DECLARATION OF JAIME M. HULING-DELAYE IN SUPPORT OF; PROPOSED] ORDER SUSTAINING THE CITY AND COUNTY OF SAN FRANCISCO'S OBJECTION TO TRIAL SETTING ORDER OR, GRANTING MOTION FOR CONTINUANCE, OR IN THE ALTERNATIVE, FOR SEPARATE TRIALS(TRANSACTION ID # 67237975) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

MOTION FOR LEAVE TO FILE FOURTH AMENDED COMPLAINT AND TO SUBSTITUTE HARLAN KELLY FOR DOE #1 (TRANSACTION ID # 67251790) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC. HEARING SET FOR FEB-15-2022 AT 09:30 AM IN DEPT 302

EXHIBIT 11-3 OF DEFENDANT CITY AND COUNTY OF SAN FRANCISCO'S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEMURRER TO SYNERGY PROJECT MANAGEMENT INC.'S FOURTH AMENDED COMPLAINT (TRANSACTION ID # 67670870) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

PROOF OF ELECTRONIC SERVICE (TRANSACTION ID # 67219562) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

MOTION TO CONTINUE JURY TRIAL (TRANSACTION ID # 67219562) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO HEARING SET FOR FEB-01-2022 AT 09:30 AM IN DEPT 206

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF THE CITY AND COUNTY OF SAN FRANCISCOS OBJECTION TO TRIAL SETTING ORDER AND MOTION TO CONTINUE TRIAL OR IN THE ALTERNATIVE FOR SEPARATE TRIALS (TRANSACTION ID # 67237975) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

SUBSTITUTION OF ATTORNEY, (TRANSACTION ID # 67198303): DAAR, RANDOLPH ELLIOTT SUBSTITUTED FOR KNADLER, JOHNNY D. AS ATTORNEY FOR SYNERGY PROJECT MANAGEMENT, INC. SYNERGY PROJECT MANAGEMENT, INC. SYNERGY PROJECT MANAGEMENT, INC. SYNERGY PROJECT MANAGEMENT, INC., A CALIFORNIA CORPORATION

ASSOCIATION OF ATTORNEYS, (TRANSACTION ID # 67131783): BARUTH, ARI ADDED AS ATTORNEY FOR CITY AND COUNTY OF SAN FRANCISCO

SUBSTITUTION OF ATTORNEY, (TRANSACTION ID # 67131602): DELAYE, JAIME HULING SUBSTITUTED FOR FLYNN, RONALD AS ATTORNEY FOR CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF JAIME M HULING DELAYE IN SUPPORT OF OBJECTION TO TRIAL SETTING ORDER AND MOTION TO CONTINUE TRIAL OR IN THE ALTERNATIVE FOR SEPARATE TRIALS (TRANSACTION ID # 67219562) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF JAIME M HULING DELAYE IN SUPPORT OF THE CITY AND COUNTY OF SAN FRANCISCOS OBJECTION TO TRIAL SETTING ORDER AND MOTION TO CONTINUE TRIAL OR IN THE ALTERNATIVE FOR SEPARATE TRIALS (TRANSACTION ID # 67237975) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

RECORD REMANDED BACK TO SUPERIOR COURT

NOTICE OF JOINT EX PARTE APPLICATION AND JOINT EX PARTE APPLICATION FOR STIPULATED CONTINUANCE OF TRIAL DATE (TRANSACTION ID # 66791539) FILED BY DEFENDANT GHILOTTI BROS., INC.

ORDER GRANTING IN PART, DENYING IN PARTY SYNERGY PROJECT MANAGEMENT, INC.'S MOTION TO CONTINUE THE TRIAL DATE

DECLARATION OF JOHNNY D KNADLER IN SUPPORT OF PLAINTIFFDEFENDANTCROSSCOMPLAINANT SYNERGY PROJECT MANAGEMENT INCS EX PARTE APPLICATION TO REQUEST A SIGNED ORDER (TRANSACTION ID # 100131663) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF THE OBJECTION TO TRIAL SETTING ORDER AND MOTION TO CONTINUE TRIAL OR IN THE ALTERNATIVE FOR SEPARATE TRIALS (TRANSACTION ID # 67219562) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

MOTION TO CONTINUE JURY TRIAL (TRANSACTION ID # 67237975) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO HEARING SET FOR FEB-03-2022 AT 09:30 AM IN DEPT 206

EX PARTE APPLICATION FOR ORDER TO REQUEST A SIGNED ORDER (TRANSACTION ID # 100131663) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

DEFENDANT PLAINTIFF CROSS-DEFENDANT GHILOTTI BROS., INC.?S OBJECTION TO SYNERGY PROJECT MANAGEMENT, INC.?S REPLY DECLARATIONS AND EVIDENCE (TRANSACTION ID # 66580205) FILED BY DEFENDANT GHILOTTI BROS., INC.

EXHIBIT 5 TO EXHIBIT 11-1 OF DEFENDANT CITY AND COUNTY OF SAN FRANCISCO'S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEMURRER TO SYNERGY PROJECT MANAGEMENT INC.'S FOURTH AMENDED COMPLAINT (TRANSACTION ID # 67670870) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

PROOF OF SERVICE BY ELECTRONIC MAIL ON SYNERGY PROJECT MANAGEMENT, INC.'S RESPONSE TO DEFENDANT'S OBJECTIONS (TRANSACTION ID # 100130580) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

ORDER GRANTING JOINT EX PARTE APPLICATION FOR STIPULATED TRIAL CONTINUANCE OF TRIAL DATE

PROOF OF SERVICE (TRANSACTION ID # 100130317) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

REPLY TO DEFENDANTS OBJECTIONS (TRANSACTION ID # 100130580) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

DECLARATION OF RYAN A. LEWIS IN SUPPORT OF JOINT EX PARTE APPLICATION FOR STIPULATED CONTINUANCE OF TRIAL DATE (TRANSACTION ID # 66791539) FILED BY DEFENDANT GHILOTTI BROS., INC.

DECLARATION OF CHIP OSSMAN (TRANSACTION ID # 100130317) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

DECLARATION OF JOHNNY D KNADLER IN SUPPORT OF REPLY IN SUPPORT OF SYNERGY PROJECT MANAGEMENT INCS MOTION TO COMPEL PRODUCTION OF DOCUMENTS COMPLIANCE AND SANCTIONS (TRANSACTION ID # 100130317) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEMURRER TO SYNERGY PROJECT MANAGEMENT INC.'S FOURTH AMENDED COMPLAINT (TRANSACTION ID # 67670870) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

EXHIBIT 11-2 OF DEFENDANT CITY AND COUNTY OF SAN FRANCISCO'S REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF DEMURRER TO SYNERGY PROJECT MANAGEMENT INC.'S FOURTH AMENDED COMPLAINT (TRANSACTION ID # 67670870) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

SEPARATE STATEMENT OF FACTS IN OPPOSITION TO PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.?S MOTION TO COMPEL PRODUCTION OF DOCUMENTS, COMPLIANCE AND SANCTIONS (TRANSACTION ID # 66550029) FILED BY DEFENDANT GHILOTTI BROS., INC.

PROOF OF SERVICE BY ELECTRONIC MAIL ON SYNERGY PROJECT MANAGEMENT, INC.'S EX PARTE APPLICATION FOR SIGNED ORDER; KNADLER DECLARATION IS SUPPORT OF EX PARTE APPLICATION; PROPOSED ORDER (TRANSACTION ID # 100131663) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

DECLARATION OF JAIME M. HULING DELAYE IN SUPPORT OF CODE OF CIVIL PROCEDURE SECTION 430.41(A)(2) AND 435.5(A)(2) AUTOMATIC 30 DAY EXTENSION TO RESPOND TO PLAINTIFF'S FOURTH AMENDED COMPLAINT (TRANSACTION ID # 67650541) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

DEMURRER TO 4TH AMENDED COMPLAINT (TRANSACTION ID # 67670870) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO HEARING SET FOR JUN-23-2022 AT 09:30 AM IN DEPT 302

ANSWER TO 4TH AMENDED COMPLAINT (TRANSACTION ID # 67656528) FILED BY DEFENDANT GHILOTTI BROS., INC.

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF DEFENDANT CITY AND COUNTY OF SAN FRANCISCO'S DEMURRER TO SYNERGY PROJECT MANAGEMENT INC.'S FOURTH AMENDED COMPLAINT (TRANSACTION ID # 67670870) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF BEN ROSENFELD AND EXHIBITS IN OPPOSITION TO DEF CITYS DEADLINE TO EXTEND DISPOSITIVE MOTION DEADLINES (TRANSACTION ID # 67647907) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

NOTICE OF APPEARANCE OF COUNSEL (TRANSACTION ID # 67645313) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF JAIME M. HULING-DELAYE IN SUPPORT OF DEFENDANT CITY AND COUNTY OF SAN FRANCISCO'S EX PARTE APPLICATION FOR AN ORDER CONTINUING THE DEADLINE TO FILE CERTAIN DISPOSITIVE MOTIONS TO RUN FROM THE NEW FEBRUARY 6 2023 TRIAL DATE (TRANSACTION ID # 67645626) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

EX PARTE APPLICATION FOR ORDER CONTINUING THE DEADLINE TO FILE CERTAIN DISPOSITIVE MOTIONS TO RUN FROM THE NEW FEBRUARY 6 2023 TRIAL DATE (TRANSACTION ID # 67645626) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

NOTICE OF ENTRY OF ORDER/NOTICE OF RULING FILED GRANTING THE CITY AND COUNTY OF SAN FRANCISCO MOTION FOR CONTINUANCE (TRANSACTION ID # 67635746) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF DEFENDANT CITY AND COUNTY OF SAN FRANCISCO?S EX PARTE APPLICATION FOR AN ORDER CONTINUING THE DEADLINE TO FILE CERTAIN DISPOSITIVE MOTIONS TO RUN FROM THE NEW FEBRUARY 6 2023 TRIAL DATE (TRANSACTION ID # 67645626) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

ORDER GRANTING THE CITY AND COUNTY OF SAN FRANCISCO MOTION FOR CONTINUANCE

REPLY IN SUPPORT OF MOTION TO CONTINUE TRIAL OR IN THE ALTERNATIVE, FOR SEPARATE TRIALS (TRANSACTION ID # 67607225) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF OPPOSITION TO PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.S MOTION TO COMPEL PRODUCTION OF DOCUMENTS, COMPLIANCE AND SANCTIONS (TRANSACTION ID # 66550029) FILED BY DEFENDANT GHILOTTI BROS., INC.

LIMITED OPPOSITION TO TO CITY DEFENDANTS' MOTION TO CONTINUE THE TRIAL AGAIN (TRANSACTION ID # 67588500) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

DECLARATION OF BEN ROSENFELD IN SUPPORT OF PLAINTIFF SYNERGYS CORRECTED OPPOSITION TO CITY DEFENDANTS MOTION TO CONTINUE THE TRIAL AGAIN, AND EXHIBITS (TRANSACTION ID # 67588500) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

OPPOSITION TO DEFENDANT CITY AND COUNTY OF SAN FRANCISCO'S MOTION TO CONTINUE TRIAL, OR, IN THE ALTERNATIVE, FOR SEPARATE TRIALS (TRANSACTION ID # 67588405) FILED BY DEFENDANT GHILOTTI BROS., INC.

DECLARATION OF PLAINTIFF'S COUNSEL BEN ROSENFELD ISO PLAINTIFF'S LIMITED OPPOSITION TO CITY DEFENDANTS' MOTION TO CONTINUE TRIAL AGAIN (TRANSACTION ID # 67576643) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

OPPOSITION TO DEFENDANT CITYS MOTION TO CONTINUE THE TRIAL AGAIN (TRANSACTION ID # 67576643) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

PROOF OF ELECTRONIC SERVICE (TRANSACTION ID # 67498467) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO CONTINUE TRIAL OR IN THE ALTERNATIVE, FOR SEPARATE TRIALS (TRANSACTION ID # 67498467) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

REPLY IN SUPPORT OF MOTION TO COMPEL PRODUCTION OF DOCUMENTS COMPLIANCE AND SANCTIONS (TRANSACTION ID # 100130317) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

MOTION TO CONTINUE JURY TRIAL (TRANSACTION ID # 67498467) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO HEARING SET FOR MAY-17-2022 AT 09:30 AM IN DEPT 206

4TH AMENDED COMPLAINT (TRANSACTION ID # 67495547) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC. AS TO DEFENDANT CITY AND COUNTY OF SAN FRANCISCO GHILOTTI BROS., INC. DOES 2-100, ET AL.

OPPOSITION TO DEFENDANT CITYS EX PARTE APPLICATION TO EXTEND DEADLINES FOR DISPOSITIVE MOTIONS (TRANSACTION ID # 67647907) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

PROOF OF SERVICE (TRANSACTION ID # 67645626) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF JOHNNY KNADLER RE SYNERGYS CONSOLIDATED REPLY ISO MOTION TO REOPEN DISCOVERY (DATE CORRECTED) (TRANSACTION ID # 67480203) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

REPLY ISO MOTION TO REOPEN DISCOVERY (TRANSACTION ID # 67480203) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

DECLARATION OF RYAN A. LEWIS IN SUPPORT OF OPPOSITION TO PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.S MOTION TO COMPEL PRODUCTION OF DOCUMENTS, COMPLIANCE AND SANCTIONS (TRANSACTION ID # 66550029) FILED BY DEFENDANT GHILOTTI BROS., INC.

DECLARATION OF JAIME M. HULING DELAYE IN SUPPORT OF MOTION TO CONTINUE TRIAL OR IN THE ALTERNATIVE, FOR SEPARATE TRIALS (TRANSACTION ID # 67498467) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

MINUTES FOR APR-12-2021 9:30 AM

DECLARATION OF BEN ROSENFELD RE SYNERGYS CONSOLIDATED REPLY ISO MOTION TO REOPEN DISCOVERY (TRANSACTION ID # 67480203) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

DECLARATION OF JOHNNY KNADLER RE SYNERGYS REPLY ISO MOTION TO REOPEN DISCOVERY (TRANSACTION ID # 67478134) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

ORDER DENYING PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.'S MOTION FOR LEAVE TO FILE FOURTH AMENDED COMPLAINT AND FIRST AMENDED CROSS-COMPLAINT

DECLARATION OF BEN ROSENFELD RE SYNERGYS REPLY ISO MOTION TO REOPEN DISCOVERY, AND EXHIBITS (TRANSACTION ID # 67478134) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

OPPOSITION TO PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.S MOTION TO COMPEL PRODUCTION OF DOCUMENTS, COMPLIANCE AND SANCTIONS (TRANSACTION ID # 66550029) (TRANSACTION ID # 66550029) FILED BY DEFENDANT GHILOTTI BROS., INC.

PROOF OF SERVICE BY ELECTRONIC FILING (TRANSACTION ID # 100128561) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

PLAINTIFF SYNERGYS CONSOLIDATED REPLY ISO MOTION TO REOPEN DISCOVERY (TRANSACTION ID # 67478134) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

DECLARATION OF JOHNNY D KNADLER IN SUPPORT OF REPLY IN SUPPORT OF SYNERGY PROJECT MANAGEMENT, INCS NOTICE OF MOTION AND MOTION TO COMPEL PRODUCTION OF DOCUMENTS COMPLIANCE AND SANCTIONS (TRANSACTION ID # 100128561) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

SEPARATE STATEMENT OF FACTS IN SUPPORT OF MOTION TO COMPEL RESPONSES TO DEFENDANT SYNERGY PROJECT MANAGEMENT INCS THIRD SET OF REQUESTS FOR PRODUCTION OF DOCUMENTS TO PLAINTIFF GHILOTTI BROS INC AND SANCTIONS (TRANSACTION ID # 100128561) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

NOTICE OF MOTION AND MOTION TO COMPEL PRODUCTION OF DOCUMENTS COMPLIANCE AND SANCTIONS (TRANSACTION ID # 100128561) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC. HEARING SET FOR MAY-07-2021 AT 09:00 AM IN DEPT 302

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO COMPEL PRODUCTION OF DOCUMENTS COMPLIANCE AND SANCTIONS (TRANSACTION ID # 100128561) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

OBJECTION TO SYNERGY PROJECT MANAGEMENT, INC.S REPLY AND DECLARATIONS IN SUPPORT OF MOTION FOR LEAVE TO FILE FOURTH AMENDED COMPLAINT AND FIRST AMENDED CROSS-COMPLAINT [C.C.P. SECTION 1005(B); CRC 3.1300(D)] (TRANSACTION ID # 66444833) FILED BY DEFENDANT GHILOTTI BROS., INC.

PROOF OF SERVICE (TRANSACTION ID # 100126983) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

REPLY SYNERGY PROJECT MANAGEMENT, INCS REPLY MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION FOR LEAVE TO FILE FOURTH AMENDED COMPLAINT AND FIRST AMENDED CROSS-COMPLAINT (TRANSACTION ID # 100126853) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

DECLARATION OF JAVAD MIRSAIDI IN SUPPORT OF MOTION FOR LEAVE TO FILE FOURTH AMENDED COMPLAIN AND FIRST AMENDED CROSS-COMPLAINT (TRANSACTION ID # 100126983) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

REPLY OF JOHNNY D KNADLER IN SUPPORT OF MOTION FOR LEAVE TO FILE FOURTH AMENDED COMPLAIN AND FIRST AMENDED CROSS-COMPLAINT (TRANSACTION ID # 100126983) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

PROOF OF SERVICE BY ELECTRONIC MAIL OF RESPONSE TO GBI'S OBJECTION TO SYNERGY'S REPLY BRIEF (TRANSACTION ID # 100126499) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

RESPONSE TO GBIS OBJECTION TO SYNERGYS REPLY BRIEF (TRANSACTION ID # 100126499) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

DEFENDANT PLAINTIFF CROSS-DEFENDANT GHILOTTI BROS., INC.S OBJECTION TO SYNERGY PROJECT MANAGEMENT, INC.S REPLY AND DECLARATION IN SUPPORT OF MOTION TO CONTINUE TRIAL [C.C.P. 1005(B); CRC 3.1300(D)] (TRANSACTION ID # 66425702) FILED BY DEFENDANT GHILOTTI BROS., INC.

DECLARATION OF RYAN A. LEWIS IN SUPPORT OF OPPOSITION TO PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC'S MOTION FOR LEAVE TO FILED FOURTH AMENDED CROSS-COMPLAINT (TRANSACTION ID # 66424514) FILED BY DEFENDANT GHILOTTI BROS., INC.

REQUEST FOR JUDICIAL NOTICE ISO GHILOTTI BROS., INC.?S OPPOSITION TO MOTION FOR LEAVE TO FILE 4TH AMENDED COMPLAINT AND 1ST AMEND. CROSS-COMPLAINT (TRANSACTION ID # 66424514) FILED BY DEFENDANT GHILOTTI BROS., INC.

ORDER SETTING CASE MANAGEMENT CONFERENCE SENT BY COURT

RECORD REMANDED BACK TO SUPERIOR COURT

ORDER GRANTING DEFENDANT/PLAINTIFF/CROSS-DEFENDANT GHILOTTI BROS., INC.'S MOTION TO COMPEL DEPOSITION OF SYNERGY PROJECT MANAGEMENT, INC.'S PERSON MOST QUALIFIED AND PRODUCTION OF DOCUMENTS

PROOF OF SERVICE BY ELECTRONIC MAIL IN SUPPORT OF MOTION TO CONTINUE TRIAL AND REPLY DECLARATION OF JOHNNY D. KNADLER IN SUPPORT OF MOTION TO CONTINUE TRIAL DATE (TRANSACTION ID # 100126280) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

CASE MANAGEMENT CONFERENCE OF JAN-24-2018 IS OFF CALENDAR. NOTICE OF REMOVAL FILED. NOTICE SENT BY COURT.

OPPOSITION TO PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.?S MOTION FOR LEAVE TO FILE FOURTH AMENDED COMPLAINT AND FIRST AMENDED CROSS-COMPLAINT (TRANSACTION ID # 66424514) FILED BY DEFENDANT GHILOTTI BROS., INC.

REPLY DECLARATION OF JOHNNY D KNADLER IN SUPPORT OF MOTION TO CONTINUE THE TRIAL DATE (TRANSACTION ID # 100126280) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

REPLY IN SUPPORT OF MOTION TO CONINTUE TRIAL (TRANSACTION ID # 100126280) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

DEFENDANT GHILOTTI BROS. INCS REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF LIMITED OPPOSITION TO PLAINTIFF SYNERGY PROJECT MANAGEMENT, INCS MOTION TO CONTINUE THE TRIAL DATE (TRANSACTION ID # 66396788) FILED BY DEFENDANT GHILOTTI BROS., INC.

NOTICE OF REMOVAL / NOTICE TO STATE SUPERIOR COURT OF REMOVAL OF ACTION TO FEDERAL DISTRICT COURT (TRANSACTION ID # 61394803) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF RYAN A. LEWIS IN SUPPORT OF DEFENDANT PLAINTIFF CROSS-DEFENDANT GHILOTTI BROS. INCS LIMITED OPPOSITION TO PLAINTIFF SYNERGY PROJECT MANAGEMENT INCS MOTION TO CONTINUE THE TRIAL DATE (TRANSACTION ID # 66396788) FILED BY DEFENDANT GHILOTTI BROS., INC.

CASE MANAGEMENT CONFERENCE OF DEC-13-2017 CONTINUED TO JAN-24-2018 AT 10:30 AM IN DEPARTMENT 610. NOTICE SENT BY COURT.

DEFENDANT PLAINTIFF CROSS-DEFENDANT GHILOTTI BROS., INC.'S LIMITED OPPOSITION TO PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.'S MOTION TO CONTINUE THE TRIAL DATE (TRANSACTION ID # 66396788) FILED BY DEFENDANT GHILOTTI BROS., INC.

NOTICE OF MOTION AND MOTION FOR LEAVE TO FILE FOURTH AMENDED COMPLAINT AND FIRST AMENDED CROSSCOMPLAINT (TRANSACTION ID # 100125647) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC. HEARING SET FOR MAR-26-2021 AT 09:30 AM IN DEPT 302

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION FOR LEAVE TO FILE FOURTH AMENDED COMPLAINT AND FIRST AMENDED CROSSCOMPLAINT (TRANSACTION ID # 100125647) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

PROOF OF SERVICE (TRANSACTION ID # 100125647) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

DECLARATION OF JOHNNY D KNADLER IN SUPPORT OF MOTION FOR LEAVE TO FILE FOURTH AMENDED COMPLAINT AND FIRST AMENDED CROSSCOMPLAINT (TRANSACTION ID # 100125647) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

PLAINTIFF SYNERGY PROJECT MANAGEMENT INCS OBJECTIONS AND MOTION TO STRIKE UNTIMELY SUPPLEMENTAL DECLARATION OF RYAN A LEWIS IN SUPPORT OF DEFENDANT PLAINTIFF CROSSDEFENDANT GHILOTTI BROS INCS MOTION TO COMPEL DEPOSITION OF SYNERGY PROJECT MANAGEMENT INCS PERSON MOST QUALIFIED AND PRODUCTION OF DOCUMENTS (TRANSACTION ID # 100125233) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

REPLY IN SUPPORT OF MOTION TO COMPEL DEPOSITION OF SYNERGY PROJECT MANAGEMENT, INC.'S PERSON MOST QUALIFIED AND PRODUCTION OF DOCUMENTS (TRANSACTION ID # 66376601) FILED BY DEFENDANT GHILOTTI BROS., INC.

DECLARATION OF JOHNNY D KNADLER IN SUPPORT OF MOTION TO CONTINUE THE TRIAL DATE (TRANSACTION ID # 100124850) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

PROOF OF PERSONAL SERVICE (TRANSACTION ID # 100124850) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

MEMORANDUM OF POINTS AND AUTHORITIES OF MOTION TO CONTINUE THE TRIAL DATE (TRANSACTION ID # 100124850) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

SUMMONS ISSUED TO PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

SUBSTITUTION OF ATTORNEY, (TRANSACTION ID # 100024891): LEIGH, GILBERT WHITNEY SUBSTITUTED FOR YAN, MATTHEW AS ATTORNEY FOR SYNERGY PROJECT MANAGEMENT, INC.

MOTION TO CONTINUE JURY TRIAL (TRANSACTION ID # 100124850) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC. HEARING SET FOR MAR-18-2021 AT 09:30 AM IN DEPT 206

NOTICE OF INSUFFICIENT SERVICE OF PROCESS AND OBJECTION TO HEARING DATE RE SYNERGY PROJECT MANAGEMENT, INC.'S MOTION TO CONTINUE THE TRIAL DATE [C.C.P. 1005(B), 1010.6] (TRANSACTION ID # 66364774) FILED BY DEFENDANT GHILOTTI BROS., INC.

PROOF OF SERVICE (TRANSACTION ID # 100124664) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

PROOF OF SERVICE BY ELECTRONIC MAIL ON OBJECTIONS AND MOTION TO STRIKE UNTIMELY SUPPLEMENTAL DECLARATION OF RYAN A. LEWIS IN SUPPORT OF DEFENDANT/PLAINTIFF/CROSS-DEFENDANT'S MOTION TO COMPEL DEPOSITION (TRANSACTION ID # 100125233) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

DECLARATION OF JOHNNY D KNADLER IN SUPPORT OF PLAINTIFF DEFENDANT CROSSCOMPLAINANT SYNERGY PROJECT MANAGEMENT INCS EX PARTE APPLICATION FOR ORDER SHORTENING TIME TO HEAR SYNERGY PROJECT MANAGEMENT INCS MOTION TO CONTINUE THE TRIAL DATE (TRANSACTION ID # 100124664) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

DECLARATION OF JOHNNY D KNADLER IN SUPPORT OF OPPOSITION TO MOTION TO COMPEL (TRANSACTION ID # 100124647) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

EX PARTE APPLICATION FOR ORDER SHORTENING TIME TO HEAR SYNERGY PROJECT MANAGEMENT INCS MOTION TO CONTINUE THE TRIAL DATE (TRANSACTION ID # 100124664) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

PROOF OF SERVICE (TRANSACTION ID # 100124647) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

SUPPLEMENTAL DECLARATION OF RYAN A. LEWIS IN SUPPORT OF DEFENDANT PLAINTIFF CROSS-DEFENDANT GHILOTTI BROS., INC.?S MOTION TO COMPEL DEPOSITION OF SYNERGY PROJECT MANAGEMENT, INC.?S PERSON MOST QUALIFIED AND PRODUCTION OF DOCUMENTS (TRANSACTION ID # 66356971) FILED BY PLAINTIFF GHLOTTI BROS., INC., A CALIFORNIA CORPORATION

OPPOSITION TO MOTION TO COMPEL (TRANSACTION ID # 100124647) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

DECLARATION OF JOHNNY D KNADLER IN SUPPORT OF MOTION TO CONTINUE TRIAL DATE (TRANSACTION ID # 100124106) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

MOTION TO CONTINUE JURY TRIAL (TRANSACTION ID # 100124106) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC. HEARING SET FOR MAR-11-2021 AT 09:30 AM IN DEPT 206

PROOF OF ELECTRONIC SERVICE (TRANSACTION ID # 100124106) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

PROOF OF SERVICE FOR REPLY IN SUPPORT OF MOTION FOR LEAVE TO AMEND, ETC. (TRANSACTION ID # 100123734) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

PROOF SERVICE ON MOTION TO COMPEL DEPOSITION OF SYNERGY PROJECT MANAGEMENT, DECLARATION, SEPARATE STATEMENT, (TRANSACTION ID # 66331676) FILED BY DEFENDANT GHILOTTI BROS., INC.

DECLARATION OF JOHNNY D KNADLER IN SUPPORT OF MOTION FOR LEAVE TO AMEND (TRANSACTION ID # 100123734) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO CONTINUE TRIAL (TRANSACTION ID # 100124106) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

SEPARATE STATEMENT OF FACTS IN SUPPORT OF MOTION TO COMPEL DEPOSITION OF SYNERGY PROJECT MANAGEMENT, INC.S PERSON MOST QUALIFIED AND PRODUCTION OF DOCUMENTS (TRANSACTION ID # 66324284) FILED BY DEFENDANT GHILOTTI BROS., INC.

REPLY IN SUPPORT OF MOTION FOR LEAVE TO AMEND (TRANSACTION ID # 100123734) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

NOTICE TO PLAINTIFF

DECLARATION OF RYAN A. LEWIS IN SUPPORT OF MOTION TO COMPEL DEPOSITION OF SYNERGY PROJECT MANAGEMENT, INC.S PERSON MOST QUALIFIED AND PRODUCTION OF DOCUMENTS (TRANSACTION ID # 66324284) FILED BY DEFENDANT GHILOTTI BROS., INC.

DEFENDANT PLAINTIFF CROSS-DEFENDANT GHILOTTI BROS., INC.?S NOTICE OF MOTION AND MOTION TO COMPEL DEPOSITION OF SYNERGY PROJECT MANAGEMENT, INC.S PERSON MOST QUALIFIED AND PRODUCTION OF DOCUMENTS (TRANSACTION ID # 66324284) FILED BY DEFENDANT GHILOTTI BROS., INC. HEARING SET FOR MAR-05-2021 AT 09:00 AM IN DEPT 302

OTHER NON EXEMPT COMPLAINTS, COMPLAINT FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC. AS TO DEFENDANT CITY AND COUNTY OF SAN FRANCISCO SUMMONS ISSUED, JUDICIAL COUNCIL CIVIL CASE COVER SHEET FILED CASE MANAGEMENT CONFERENCE SCHEDULED FOR DEC-13-2017 PROOF OF SERVICE DUE ON SEP-08-2017 CASE MANAGEMENT STATEMENT DUE ON NOV-20-2017

DECLARATION OF RYAN A. LEWIS IN SUPPORT OF DEFENDANT PLAINTIFF CROSS-DEFENDANT GHILOTTI BROS., INC.S EX PARTE APPLICATION FOR ORDER SHORTENING NOTICE RE MOTION TO COMPEL DEPOSITION OF SYNERGY PROJECT MANAGEMENT, INC. PERSON MOST QUALIFIED AND PRODUCTION OF DOCUMENTS (TRANSACTION ID # 66317377) FILED BY DEFENDANT GHILOTTI BROS., INC.

STIPULATED PROTECTIVE ORDER

EX PARTE APPLICATION FOR ORDER SHORTENING NOTICE RE MOTION TO COMPEL DEPOSITION OF SYNERGY PROJECT MANAGEMENT. INC.S. PERSON MOST QUALIFIED AND PRODUCTION OF DOCUMENTS; MEMORANDUM OF POINTS AND AUTHORITIES, PROOF OF SERVICE (TRANSACTION ID # 66317377) FILED BY DEFENDANT GHILOTTI BROS., INC.

OPPOSITION TO PLAINTIFF SYNERGY PROJECT MANAGEMENT'S MOTION FOR LEAVE TO FILE FOURTH AMENDED COMPLAINT (TRANSACTION ID # 66303294) FILED BY DEFENDANT GHILOTTI BROS., INC.

PROOF OF ELECTRONIC SERVICE (TRANSACTION ID # 100121849) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF OPPOSITION TO PLAINTIFF SYNERGY PROJECT MANAGEMENT'S MOTION FOR LEAVE TO FILE FOURTH AMENDED COMPLAINT (TRANSACTION ID # 66303294) FILED BY DEFENDANT GHILOTTI BROS., INC.

DECLARATION OF JOHNNY D. KNADLER IN SUPPORT OF MOTION FOR LEAVE TO FILE FOURTH AMENDED COMPLAINT (TRANSACTION ID # 100121849) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

ANSWER TO 3RD AMENDED COMPLAINT FILED BY DEFENDANT GHILOTTI BROS., INC.

NOTICE OF CHANGE OF FIRM NAME (TRANSACTION ID # 65849582) FILED BY ATTORNEY DIWIK, JAMES P

LIMITED OBJECTION TO A REQUEST FOR CLARIFICATION OF CASE MANAGEMENT DEPARTMENT 610S SEPTEMBER 16, 2020 TRIAL ORDER (TRANSACTION ID # 65949899) FILED BY DEFENDANT GHILOTTI BROS., INC.

NOTICE OF TIME AND PLACE OF TRIAL, JURY TRIAL SET FOR MAR-29-2021 AT 9:30 AM IN DEPT. 206. CASE MANAGEMENT CONFERENCE ON SEP-30-2020 IS OFF CALENDAR. NOTICE SENT BY COURT.

CASE MANAGEMENT STATEMENT (TRANSACTION ID # 65935518) FILED BY DEFENDANT GHILOTTI BROS., INC. ESTIMATED TIME FOR TRIAL: 5.0 DAYS

NOTICE OF MOTION MOTION AND MEMORANDUM IN SUPPORT OF MOTION FOR LEAVE TO FILE FOURTH AMENDED COMPLAINT (TRANSACTION ID # 100121849) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC. HEARING SET FOR FEB-17-2021 AT 09:30 AM IN DEPT 302

CASE MANAGEMENT CONFERENCE OF AUG-26-2020 CONTINUED TO SEP-30-2020 AT 10:30 AM IN DEPARTMENT 610. NOTICE SENT BY COURT.

ORDER TO CONSOLIDATE ACTIONS OF CASE(S) CGC-19-576488 WITH CASE CGC-17-560034 [FOR ALL PURPOSES - CGC-17-560034 IS THE LEAD CASE]

NOTICE OF LIEN / (CPF-19-516886) (TRANSACTION ID # 65943001) FILED BY CLAIMANT CITY AND COUNTY OF SAN FRANCISCO

NOTICE OF LIEN / (CPF-19-516755) (TRANSACTION ID # 65942995) FILED BY CLAIMANT CITY AND COUNTY OF SAN FRANCISCO

CASE MANAGEMENT CONFERENCE OF JUN-24-2020 CONTINUED TO AUG-26-2020 AT 10:30 AM IN DEPARTMENT 610 FOR STATUS OF CONSOLIDATION OR FOR TRIAL SETTING. NOTICE SENT BY COURT.

NOTICE OF LIEN (TRANSACTION ID # 65637744) FILED BY CLAIMANT CITY AND COUNTY OF SAN FRANCISCO

CASE MANAGEMENT CONFERENCE OF FEB-19-2020 CONTINUED TO APR-22-2020 AT 10:30 AM IN DEPARTMENT 610 FOR STATUS OF AMENDED COMPLAINT. NOTICE SENT BY COURT.

CASE MANAGEMENT CONFERENCE OF APR-22-2020 CONTINUED TO JUN-24-2020 AT 10:30 AM IN DEPARTMENT 610. NOTICE SENT BY COURT.

NOTICE OF LIEN (CPF-19-516886) FILED BY CLAIMANT CITY AND COUNTY OF SAN FRANCISCO

PROOF OF SERVICE (TRANSACTION ID # 100095441) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

ATTACHMENT TO CMC PT 3 (TRANSACTION ID # 100095441) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

CASE MANAGEMENT STATEMENT (TRANSACTION ID # 65841419) FILED BY DEFENDANT GHILOTTI BROS., INC. ESTIMATED TIME FOR TRIAL: 5.0 DAYS

PROOF OF SERVICE (RE CASE MANAGEMENT STATEMENT) (TRANSACTION ID # 100100710) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

NOTICE OF LIEN (TRANSACTION ID # 65635578) FILED BY CLAIMANT CITY AND COUNTY OF SAN FRANCISCO

CASE MANAGEMENT STATEMENT (TRANSACTION ID # 100100710) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC. JURY DEMANDED, ESTIMATED TIME FOR TRIAL: 10.0 DAYS

NOTICE OF LIEN (CPF-19-516755) FILED BY CLAIMANT CITY AND COUNTY OF SAN FRANCISCO

ATTACHMENT TO CMC PT 2 (TRANSACTION ID # 100095441) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

ATTACHMENT TO CMC PT 1 (TRANSACTION ID # 100095441) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

CASE MANAGEMENT STATEMENT (TRANSACTION ID # 100092665) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC. JURY DEMANDED, ESTIMATED TIME FOR TRIAL: 10.0 DAYS

CASE MANAGEMENT STATEMENT (TRANSACTION ID # 100095441) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC. JURY DEMANDED, ESTIMATED TIME FOR TRIAL: 10.0 DAYS

PROOF OF SERVICE BY MAIL OF CASE MANAGEMENT STATEMENT (TRANSACTION ID # 100092665) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

CASE MANAGEMENT CONFERENCE OF JAN-15-2020 CONTINUED TO FEB-19-2020 AT 10:30 AM IN DEPARTMENT 610 FOR THE SUBMISSION OF CASE MANAGEMENT STATEMENTS. ***NOTE: PLAINTIFF SHOULD FILE THE OPERATIVE 3RD AMENDED COMPLAINT WITH THIS COURT.*** NOTICE SENT BY COURT.

NOTICE OF MOTION TO CONSOLIDATE [C.C.P. SECTION 1048] (TRANSACTION ID # 64784741) FILED BY DEFENDANT GHILOTTI BROS., INC.

OPPOSITION TO MOTION TO CONSOLIDATE (TRANSACTION ID # 100100110) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

DECLARATION OF JOHNNY D. KNADLER IN SUPPORT OF SYNERGY PROJECT MANAGEMENT INCS OPPOSITION TO MOTION TO CONSOLIDATE (TRANSACTION ID # 100100110) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

OPPOSITION TO SYNERGY PROJECT MANAGEMENT, INC.?S MOTION TO REOPEN DISCOVERY (TRANSACTION ID # 67462088) FILED BY DEFENDANT GHILOTTI BROS., INC.

DECLARATION OF RYAN A. LEWIS IN SUPPORT OF GHILOTTI BROS., INC.'S LIMITED OPPOSITION TO SYNERGY PROJECT MANAGEMENT, INC.'S MOTION TO REOPEN DISCOVERY (TRANSACTION ID # 67462088) FILED BY DEFENDANT GHILOTTI BROS., INC.

PROOF OF SERVICE (TRANSACTION ID # 67462014) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF JAIME M. HULING-DELAYE IN SUPPORT OF DEFENDANT CITY AND COUNTY OF SAN FRANCISCO'S OPPOSITION TO PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.'S MOTION TO REOPEN DISCOVERY (TRANSACTION ID # 67462014) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

ORDER ON STIPULATION WITHDRAWING DEFENDANT CITY AND COUNTY OF SAN FRANCISCO'S MEMORANDUM OF COSTS IN EXCHANGE FOR PLAINTIFF FOREGOING APPEAL

MEMORANDUM OF COSTS AND DISBURSEMENTS, $1,486.00 TOTAL COSTS, (TRANSACTION ID # 67849347) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF OPPOSITION TO PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.'S MOTION TO REOPEN DISCOVERY (TRANSACTION ID # 67462014) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

ORDER GRANTING IN PART PLAINTIFF'S MOTION FOR LEAVE TO FILE FOURTH AMENDED COMPLAINT.

OPPOSITION TO PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.'S MOTION TO REOPEN DISCOVERY (TRANSACTION ID # 67462014) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

PLAINTIFFS AMENDED NOTICE OF HEARING DATE AND TIME OF MOTION TO REOPEN DISCOVERY, PROOF OF SERVICE (TRANSACTION ID # 67436451) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC. HEARING SET FOR APR-20-2022 AT 09:30 AM IN DEPT 302

NOTICE OF ENTRY OF JUDGMENT (TRANSACTION ID # 67814023)

NOTICE OF ENTRY OF ORDER/NOTICE OF RULING FILED (TRANSACTION ID # 67773707) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF PLAINTIFFS COUNSEL BEN ROSENFELD WITH EXHIBITS ISO MOTION TO REOPEN DISCOVERY (TRANSACTION ID # 67413062) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

DECLARATION OF PLAINTIFFS COUNSEL RANDOLPH E DAAR ISO MOTION TO REOPEN DISCOVERY (TRANSACTION ID # 67413062) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

NOTICE AND MOTION TO REOPEN DISCOVERY, PROOF OF SERVICE (TRANSACTION ID # 67413062) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC. HEARING SET FOR APR-13-2022 AT 09:30 AM IN DEPT 302

ORDER DENYING MOTION TO REOPEN DISCOVERY

THE COURT ORDERED THE FOLLOWING JUDGMENT ENTERED: IT IS ADJUDGED THAT PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC. TAKE NOTHING FROM DEFENDANT CITY AND COUNTY OF SAN FRANCISCO SEE SCANNED DOCUMENT

NOTICE OF ENTRY OF ORDER/NOTICE OF RULING FILED (TRANSACTION ID # 67773722) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

NOTICE OF ERRATUM IN REPLY ISO MOTION FOR LEAVE TO AMEND (TRANSACTION ID # 67328377) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

ORDER DENYING SYNERGY PROJECT MANAGEMENT, INC.'S MOTION TO REINSTATE DEFENDANTS LONDON BREED AND MOHAMMED NURU PURSUANT TO CCP SECTION 473, 474 AND 475.

DECLARATION OF PLAINTIFF SYNERGY COUNSEL BEN ROSENFELD RE REPLY ISO MOTION FOR LEAVE TO AMEND, WITH EXHIBITS (TRANSACTION ID # 67326491) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

NOTICE OF ENTRY OF ORDER/NOTICE OF RULING FILED (TRANSACTION ID # 67773680) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

ORDER SUSTAINING DEFENDANT CITY AND COUNTY OF SAN FRANCISCO'S DEMURRER TO SYENERGY PROJECT MANAGEMENT INC.'S FOURTH AMENDED COMPLAINT.

REPLY ISO MOTION FOR LEAVE TO AMEND (TRANSACTION ID # 67326491) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

ORDER AS TO DEFENDANT CITY AND COUNTY OF SAN FRANCISCO'S MOTION TO STRIKE SYENERGY PROJECT MANAGEMENT INC.'S FOURTH AMENDED COMPLAINT.

DECLARATION OF COUNSEL BEN ROSENFELD RE PLAINTIFF SYNERGY'S REPLY IN SUPPORT OF MOTION TO REINSTATE DEFENDANTS BREED AND NURU PURSUANT TO CCP 473 ET SEQ., AND EXHIBITS (TRANSACTION ID # 67742445) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

REPLY IN SUPPORT OF MOTION TO REINSTATE DEFENDANTS BREED AND NURU PURSUANT TO CCP 473 ET SEQ. (TRANSACTION ID # 67742445) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

DECLARATION OF JAIME M. HULING DELAYE IN SUPPORT OF THE CITY AND COUNTY OF SAN FRANCISCOS OBJECTION TO SYNERGY PROJECT MANAGEMENT INCS MOTION FOR LEAVE TO FILE FOURTH AMENDED COMPLAINT AND TO SUBSTITUTE HARLAN KELLY FOR DOE #1 (TRANSACTION ID # 67308301) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

REPLY IN SUPPORT OF MOTION TO STRIKE PORTIONS OF SYNERGY PROJECT MANAGEMENT, INC.'S FOURTH AMENDED COMPLAINT (TRANSACTION ID # 67740488) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF COUNSEL BEN ROSENFELD IN SUPPORT OF PLAINTIFF SYNERGY'S OPPOSITION TO CITY DEFENDANTS' MOTION TO STRIKE PORTIONS OF FOURTH AMENDED COMPLAINT (TRANSACTION ID # 67726343) FILED BY PLAINTIFF SYNERGY PROJECT MANAGEMENT, INC.

OPPOSITION TO PLAINTIFF SYNERGY PROJECT MANAGEMENT INCS MOTION FOR LEAVE TO FILE FOURTH AMENDED COMPLAINT AND TO SUBSTITUTE HARLAN KELLY FOR DOE #1 (TRANSACTION ID # 67308301) FILED BY DEFENDANT CITY AND COUNTY OF SAN FRANCISCO