City And County Of San Francisco Et Al Vs. Melvin Lee Et Al

DECLARATION OF OWAIS BARI IN SUPPORT OF EX PARTE APPLICATION TO SEEK LEAVE OF COURT TO FILE THIRD AMENDED ANSWER (TRANSACTION ID # 100097543) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

DECLARATION OF OWAIS BARI, ESQ IN SUPPORT OF DEFENDANTS EX PARTE APPLICATION TO SEEK LEAVE OF COURT TO FILE SECOND AMENDED CROSS COMPLAINT (TRANSACTION ID # 100103658) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

AMENDED ANSWER TO COMPLAINT (TRANSACTION ID # 100099284) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

NOTICE OF ENTRY OF ORDER/NOTICE OF RULING FILED GRANTING DEFENDANTS LEAVE OF COURT TO FILE THIRD AMENDED ANSWER (TRANSACTION ID # 100099284) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

CROSS COMPLAINT (TRANSACTION ID # 64320226) FILED PER ORDER BY CROSS COMPLAINANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC. AS TO CROSS DEFENDANT CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION

NOTICE OF ENTRY OF ORDER/NOTICE OF RULING FILED (TRANSACTION ID # 100103458) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

ORDER GRANTING DEFENDANTS LEAVE OF COURT TO FILE THIRD AMENDED ANSWER (SEE SCANNED ORDER FOR DETAILS)

MPA ISO DEFS LEAVE OF COURT TO FILE SECOND AMENDED VERIFIED ANSWER (TRANSACTION ID # 64230091) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

ORDER GRANTING DEFENDANTS LEAVE OF COURT TO FILE SECOND AMENDED CROSS-COMPLAINT (SEE SCANNED ORDER FOR DETAILS)

NOTICE OF ENTRY OF ORDER/NOTICE OF RULING FILED GRANTING CONTINUANCE OF TRIAL (TRANSACTION ID # 64113660) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL

ORDER GRANTING TRIAL CONTINUANCE

ORDER GRANTING CONTINUANCE OF TRIAL

1ST AMENDED CROSS COMPLAINT (TRANSACTION ID # 100097693) FILED BY CROSS COMPLAINANT VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. AS TO CROSS DEFENDANT CITY AND COUNTY OF SAN FRANCISCO, A MUNICIPAL CORPORATION, BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO ROE ONE THROUGH TWENTY, INCLUSIVE

ORDER GRANTING VAN NESS CARE CENTER INC.; SAN FRANCISCO CARE CENTER, L.P.; MELVIN LEE; TERESA WONG; AND MEL LEE MANAGEMENT, INC. LEAVE OF COURT TO FILE A CROSS-COMPLAINT (SEE SCANNED ORDER FOR DETAILS)

EX PARTE APPLICATION FOR ORDER TO SEEK LEAVE TO FILE SAC (TRANSACTION ID # 100103658) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

NOTICE OF ENTRY OF ORDER GRANTING DEFENDANTS LEAVE OF COURT TO FILE SECOND AMENDED CROSS-COMPLAINT (TRANSACTION ID # 100104287) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

REPLY MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION FOR LEAVE OF COURT TO FILE SECOND AMENDED VERIFIED ANSWER (TRANSACTION ID # 64320234) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF CONTINUANCE OF TRIAL DATE (TRANSACTION ID # 65637897) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

STIPULATION FOR FILING THIRD AMENDED ANSWER (TRANSACTION ID # 100097543) FILED BY LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

DECLARATION OF DAVID J. MILLSTEIN IN SUPPORT OF JOINT MOTION FOR TRIAL CONTINUANCE AND STAY ON PROCEEDINGS (TRANSACTION ID # 100088512) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

2ND AMENDED CROSS COMPLAINT (TRANSACTION ID # 100104287) FILED PER ORDER BY CROSS COMPLAINANT VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. DOE ONE THROUGH DOE FIFTY, INCLUSIVE AS TO CROSS DEFENDANT CITY AND COUNTY OF SAN FRANCISCO, A MUNICIPAL CORPORATION, BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO ROE ONE THROUGH TWENTY, INCLUSIVE

EX PARTE APPLICATION TO SEEK LEAVE OF COURT TO FILE THIRD AMENDED ANSWER (TRANSACTION ID # 100097543) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

DECLARATION OF JASON E. FELLNER IN SUPPORT OF DEFENDANTS JOINT REPLY IN SUPPORT OF MOTION FOR LEAVE OF COURT TO FILE SECOND AMENDED VERIFIED ANSWER (TRANSACTION ID # 64320234) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

REPLY MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION FOR LEAVE OF COURT TO FILE CROSS-COMPLAINT (TRANSACTION ID # 64320234) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

AMENDED ANSWER TO COMPLAINT (TRANSACTION ID # 64320226) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO MOTION FOR LEAVE OF COURT TO FILE CROSS-COMPLAINT (TRANSACTION ID # 64272270) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF JENNIFER E. CHOI IN OPPOSITION TO DEFENDANTS MOTION FOR LEAVE TO FILE CROSS-COMPLAINT; EXHIBITS A--E (TRANSACTION ID # 64272270) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

REQUEST FOR JUDICIAL NOTICE OF MELVIN LEE (TRANSACTION ID # 63134697) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

ORDER GRANTING CONTINUANCE OF TRIAL

ORDER GRANTING VAN NESS CARE CENTER, INC.; SAN FRANCISCO CARE CENTER, L.P.; MELVIN LEE; TERESA WONG; AND MEL LEE MANAGEMENT, INC. LEAVE OF COURT TO FILE SECOND AMENDED VERIFIED ANSWER (SEE SCANNED ORDER FOR DETAILS)

ORDER RE DEFENDANT TERESA WONG'S MOTION FOR PROTECTIVE ORDER AND FOR SANCTIONS

DECLARATION OF JENNIFER E. CHOI IN OPPOSITION TO DEFENDANTS MOTION FOR LEAVE TO FILE SECOND AMENDED VERIFIED ANSWER; EXHIBITS A-E (TRANSACTION ID # 64272933) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

NOTICE OF ENTRY OF ORDER/NOTICE OF RULING FILED (TRANSACTION ID # 64333133) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF JASON E. FELLNER IN SUPPORT OF DEFENDANTS JOINT REPLY IN SUPPORT OF MOTION FOR LEAVE OF COURT TO FILE CROSS-COMPLAINT (TRANSACTION ID # 64320234) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO MOTION FOR LEAVE OF COURT TO FILE SECOND AMENDED VERIFIED ANSWER (TRANSACTION ID # 64272933) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

REPLY OF MELVIN LEE TO OPPOSITION OF CCSF TO MOTION FOR PROTECTIVE ORDER AND FOR SANCTIONS (TRANSACTION ID # 63134697) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

DECLARATION OF JEF ISO DEFS JONT MTN FOR LEAVE OF COURT TO FILE SECOND AMENDED VERIFIED ANSWER (TRANSACTION ID # 64230091) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

PROPOSED ORDER RE WONG MOTION FOR PROTECTIVE ORDER AND FOR SANCTIONS (TRANSACTION ID # 63252972) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

DECLARATION OF GERALD RICHELSON ISO EX PARTE (TRANSACTION ID # 100072426) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

ORDER RE DEFENDANT MELVIN LEE'S MOTION FOR PROTECTIVE ORDER AND SANCTIONS

NOTICE OF ENTRY OF ORDER/NOTICE OF RULING FILED (TRANSACTION ID # 100072652) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

OPPOSITION TO PLAINTIFFS? MOTION IN LIMINE NO. 5: MOTION TO EXCLUDE EVIDENCE OF SETTLEMENTS OF OTHER LITIGATION (TRANSACTION ID # 67009028) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

DEFENDANT'S DISPUTED DEPOSITION DESIGNATIONS: JEAN PIERRE LOMONACO AND COURT RULINGS

OPPOSITION TO PLAINTIFFS? MOTION IN LIMINE NO. 2: MOTION TO PRECLUDE DEFENDANTS FROM CALLING PLAINTIFFS? COUNSEL DCA KRISTEN JENSEN AS A TRIAL WITNESS (TRANSACTION ID # 67009028) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

ORDER STIPULATED ADMITTED EXHIBITS; AND ORDER

OPPOSITION TO DEFENDANTS REQUEST FOR JUDICIAL NOTICE (TRANSACTION ID # 67913488) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF PETER J. KEITH IN SUPPORT OF PLAINTIFFS OPPOSITION TO DEFENDANTS MOTIONS IN LIMINE NO. 1 RE CONTRACT INTERPRETATION; EXHIBIT A (TRANSACTION ID # 100144229) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

OPPOSITION PLAINTIFFS? MOTIONS IN LIMINE NO. 4: MOTIONS TO EXCLUDE DEFENDANTS? RETAINED EXPERT JOHN BOWBLIS, PH.D. (TRANSACTION ID # 67009028) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

MINUTES FOR AUG-09-2022 9:00 AM

PROOF OF SERVICE (TRANSACTION ID # 67912022) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL

OPPOSITION TO DEFENDANTS MOTION IN LIMINE NO. 1 RE CONTRACT INTERPRETATION (TRANSACTION ID # 100144229) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF JEAN-PIERRE LOMONACO IN SUPPORT OF PLAINTIFFS OPPOSITION TO DEFENDANTS MOTION IN LIMINE NO. 2-TO EXCLUDE THE TESTIMONY OF PLAINTIFFS EXPERT JP; OR IN THE ALTERNATIVE A MOTION FOR A HEARING UNDER EVIDENCE CODE SECTION 402; EXHIBIT A (TRANSACTION ID # 100144150) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF PETER WALROD IN SUPPORT OF DEFENDANTS? REQUEST FOR JUDICIAL NOTICE (TRANSACTION ID # 67912022) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL

PLAINTIFFS AND CROSS-DEFENDANTS OPPOSITION TO DEFENDANTS MOTION IN LIMINE NO. 8 RE MISCELLANEOUS TOPICS (TRANSACTION ID # 100144126) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

OPPOSITION TO DEFENDANTS MOTION IN LIMINE NO. 2: TO EXCLUDE THE TESTIMONY OF PLAINTIFFS EXPERT JEAN-PIERRE LOMONACO (TRANSACTION ID # 100144150) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

PLAINTIFFS AND CROSS-DEFENDANTS OPPOSITION TO DEFENDANTS MOTION IN LIMINE NO. 5 (TRANSACTION ID # 100144126) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

PLAINTIFFS AND CROSS-DEFENDANTS OPPOSITION TO DEFENDANTS MOTION IN LIMINE NO. 6 RE HOMELESSNESS AND HOUSING (TRANSACTION ID # 100144126) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF PETER J. KEITH IN SUPPORT OF PLAINTIFFS OPPOSITION O DEFENDANTS MOTION IN LIMINE NO. 7; EXHIBIT A (TRANSACTION ID # 100144126) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF PETER J. KEITH IN SUPPORT OF PLAINTIFFS OPPOSITION TO DEFENDANTS MOTIONS IN LIMINE NO. 3 AND NO. 4 RE NOTICE OF DEFAULT; EXHIBITS A--C (TRANSACTION ID # 100144126) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

PLAINTIFFS OPPOSITION TO DEFENDANTS MOTIONS IN LIMINE NO. 3 AND NO. 4 RE NOTICE OF DEFAULT (TRANSACTION ID # 100144126) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

REQUEST FOR JUDICIAL NOTICE (TRANSACTION ID # 67912022) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL

ORDER PRETRIAL CONFERENCE ORDER NO.4 (TRANSACTION #67827711)

JOINT STATEMENT FOR 7-15-22 PRETRIAL CONFERENCE (TRANSACTION ID # 67812717) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

DEFENDANTS TRIAL BRIEF (TRANSACTION ID # 100167605) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL

DECLARATION OF MEGAN RYAN IN SUPPORT OF PLAINTIFFS_CROSS-DEFENDANTS OPPOSITION TO DEFENDANTS_CROSS COMPLAINANTS MOTION TO CONTINUE TRIAL (TRANSACTION ID # 67310340) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

MINUTES FOR APR-22-2022 9:00 AM

OPPOSITION TO DEFENDANTS_CROSS COMPLAINANTS MOTION TO CONTINUE TRIAL (TRANSACTION ID # 67310340) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

PROOF OF SERVICE BY ELECTRONIC MAIL (TRANSACTION ID # 67310340) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

ORDER CONTINUING TRIAL [TRANSACTION NO. 67319119]

NOTICE OF ENTRY OF ORDER/NOTICE OF RULING FILED (TRANSACTION ID # 67319310) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P.

NOTICE OF APPEARANCE (TRANSACTION ID # 100155940) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

MINUTES FOR FEB-14-2022 9:00 AM

ORDER ON MOTIONS IN LIMINE (TRANSACTION #67501840)

JOINT STATEMENT FOR 4/22/22 PRETRIAL CONFERENCE (TRANSACTION ID # 100161633) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

NOTICE OF ENTRY OF ORDER/NOTICE OF RULING FILED (TRANSACTION ID # 67308237) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. MEL LEE MANAGEMENT, INC.

PROOF OF SERVICE (TRANSACTION ID # 67308237) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL

NOTICE OF ENTRY OF ORDER FOR ORDER GRANTING EX PARTE APPLICATION FOR AN ORDER SHORTENING TIME TO HEAR NOTICE OF DEFENDANTS MOTION TO CONTINUE TRIAL (TRANSACTION ID # 67308237) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL

ORDER GRANTING ATTORNEY'S MOTION TO BE RELIEVED AS COUNSEL, (SEE SCANNED DOCUMENT) [TRANS# 67308169]: PRO PER SUBSTITUTED FOR MILLSTEIN, DAVID J AS ATTORNEY FOR LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

ORDER GRANTING EX PARTE APPLICATION FOR AN ORDER SHORTENING TIME TO HEAR NOTICE OF DEFENDANTS MOTION TO CONTINUE TRIAL [TRANS# 67308156]

MINUTES FOR FEB-09-2022 3:30 PM

PROOF OF PERSONAL SERVICE AND SERVICE BY ELECTRONIC MAIL (TRANSACTION ID # 67301241) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P.

PROOF OF SERVICE (TRANSACTION ID # 67301143) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL

DECLARATION OF OWAIS M BARI IN SUPPORT OF DEFENDANTS CROSS COMPLAINANTS' EX PARTE APPLICATION FOR AN ORDER SHORTENING TIME TO HEAR DEFENDANTS MOTION TO CONTINUE (TRANSACTION ID # 67301143) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL

PROOF OF SERVICE OF NOTICE OF MOTION TO CONTINUE TRIAL; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION (TRANSACTION ID # 67300269) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P.

EX PARTE APPLICATION FOR ORDER SHORTENING TIME TO HEAR MOTION TO CONTINUE TRIAL (TRANSACTION ID # 67301143) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL

MINUTES FOR FEB-07-2022 4:00 PM

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO CONTINUE TRIAL (TRANSACTION ID # 67294043) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P.

DECLARATION OF OWAIS M. BARI IN SUPPORT OF MOTION TO CONTINUE TRIAL (TRANSACTION ID # 67294043) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P.

MOTION TO CONTINUE COURT TRIAL (TRANSACTION ID # 67294043) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. HEARING SET FOR MAR-02-2022 AT 09:30 AM IN DEPT 611

PROOF OF SERVICE BY ELECTRONIC MAIL AND BY PERSONAL SERVICE (TRANSACTION ID # 67293471) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P.

EX PARTE APPLICATION FOR AN ORDER SHORTENING TIME TO HEAR NOTICE OF MOTION TO WITHDRAW COUNSEL (TRANSACTION ID # 67293471) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P.

DECLARATION OF OWAIS M BARI IN SUPPORT OF EX PARTE APPLICATION FOR AN ORDER SHORTENING TIME TO HEAR NOTICE OF MOTION TO WITHDRAW AS COUNSEL (TRANSACTION ID # 67293471) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P.

PROOF OF SERVICE BY ELECTRONIC MAIL & PERSONAL SERVICE (TRANSACTION ID # 67292773) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. MEL LEE MANAGEMENT, INC.

NOTICE OF ERRATA TO AMENDED NOTICE OF MOTION AND MOTION TO BE RELIEVED AS COUNSEL - CIVIL (TRANSACTION ID # 67292773) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

NOTICE OF ENTRY OF ORDER/NOTICE OF RULING FILED DENYING EX PARTE APPLICATION FOR ORDER SHORTENING TIME (TRANSACTION ID # 67292773) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. MEL LEE MANAGEMENT, INC.

PROOF OF SERVICE (TRANSACTION ID # 100154413) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

NOTICE OF ERRATA TO AMENDED DECLARATION IN SUPPORT OF ATTORNEY?S MOTION TO BE RELIEVED AS COUNSEL - CIVIL (TRANSACTION ID # 67292773) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. MEL LEE MANAGEMENT, INC.

MINUTES FOR FEB-03-2022 9:00 AM

DECLARATION OF MEGAN RYAN IN SUPPORT OF PLAINTIFFS OPPOSITION TO DEFENDANTS MOTION IN LIMINE NO. 9 TO EXCLUDE WITNESSES SUBPOENAED FROM OTHER ASSISTED LIVING FACILITIES; EXHIBITS 1-6 (TRANSACTION ID # 100154413) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

ORDER DENYING EX PARTE APPLICATION FOR ORDER SHORTENING TIME (TRANSACTION #67288828)

NOTICE OF ENTRY OF ORDER/NOTICE OF RULING FILED (TRANSACTION ID # 67285201) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

SEPARATE STATEMENT OF FACTS IN SUPPORT OF MOTION TO COMPEL SUBPOENA FOR BUSINESS RECORDS FOR RJ STARLIGHT HOME CORPORATION (TRANSACTION ID # 100107656) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

ORDER GRANTING DEFENDANT'S MOTION TO COMPEL COMPLAINCE WITH DEPOSITION SUBPOENA FOR RECORDS FOR GONZALES HOME

NOTICE OF MOTION AND MOTION TO COMPEL SUBPOENA FOR BUSINESS RECORDS FOR RJ STARLIGHT HOME CORPORATION (TRANSACTION ID # 100107656) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC. HEARING SET FOR AUG-24-2020 AT 09:00 AM IN DEPT 302

NOTICE OF ENTRY OF ORDER/NOTICE OF RULING FILED GRANTING DEFENDANTS' MOTION TO COMPEL COMPLIANCE WITH DEPOSITION SUBPOENA FOR RECORDS FROM RJ STARLIGHT HOME CORPORATION (TRANSACTION ID # 100113628) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

ANSWER TO 2ND AMENDED CROSS COMPLAINT (TRANSACTION ID # 65773740) FILED BY CROSS DEFENDANT CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION

NOTICE OF ENTRY OF ORDER/NOTICE OF RULING FILED (TRANSACTION ID # 100110719) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

OBJECTION-SUR-REPLY TO MOVANTS REPLY (TRANSACTION ID # 100106178) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL

ORDER ; STIPULATION AND ORDER FOR MOTION TO BE HEARD BY A MEMBER OF THE CALIFORNIA BAR SERVING AS A TEMPORARY JUDGE (SEE SCANNED ORDER FOR DETAILS)

NOTICE OF ENTRY OF ORDER/NOTICE OF RULING FILED GRANTING TRIAL CONTINUANCE (TRANSACTION ID # 66513973) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF MEGAN E. RYAN IN SUPPORT OF MOTION TO CONTINUE TRIAL (TRANSACTION ID # 66435412) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

ORDER GRANTING TRIAL CONTINUANCE

ORDER GRANTING DEFENDANTS' MOTION TO COMPEL COMPLIANCE WITH DEPOSITION SUBPOENA FOR RECORDS FROM RJ STARLIGHT HOME CORPORATION

OPPOSITION TO PLAINTIFF'S MOTION TO BIFURCATE TRIAL (TRANSACTION ID # 100127354) (TRANSACTION ID # 100127354) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

PLAINTIFFS MOTION IN LIMINE NO 1: MOTION TO EXCLUDE EXTRINSIC EVIDENCE OFFERED BY DEFENDANTS TO SUPPORT OF THEIR UNREASONABLE INTERPRETATION OF THE CONTRACT (TRANSACTION ID # 66998595) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

ORDER GRANTING DEFENDANTS' MOTION TO CONTINUE TRIAL

MOTION TO CONTINUE COURT TRIAL, PROOF OF SERVICE (TRANSACTION ID # 66435412) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO HEARING SET FOR APR-13-2021 AT 09:30 AM IN DEPT 206

NOTICE OF SETTLEMENT CONFERENCE; SETTLEMENT CONFERENCE SET FOR SEP-21-2021 AT 8:30 AM WITH CONFERENCE OFFICER MARTIN F. TRIANO

JURY FEES (TRANSACTION ID # 100133658) DEPOSITED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF JOINT MOTION TO CONTINUE TRIAL (TRANSACTION ID # 66435412) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

PROOF OF SERVICE (TRANSACTION ID # 100126418) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

PROOF OF SERVICE BY ELECTRONIC MAIL ON MOTION TO CONTINUE TRIAL AND MOTION TO CONTINUE TRIAL, MEMO OF POINTS AND AUTHORITIES, DECLARATION AND PROPOSED ORDER (TRANSACTION ID # 66435412) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

PROOF OF SERVICE BY PERSONAL DELIVERY (TRANSACTION ID # 100107659) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

EX PARTE APPLICATION FOR ORDER SHORTENING TIME TO FILE MOTION TO CONTINUE TRIAL DATE (TRANSACTION ID # 100126418) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

SEPARATE STATEMENT OF FACTS IN SUPPORT OF MOTION TO COMPEL SUBPOENA FOR PRODUCTION OF DOCUMENTS FOR FOOK HONG SF CARE HOME, INC. (TRANSACTION ID # 100107659) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

MOTION TO COMPEL SUBPOENA FOR BUSINESS RECORDS FOR GONZALES HOME (TRANSACTION ID # 100107660) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC. HEARING SET FOR AUG-25-2020 AT 09:00 AM IN DEPT 302

DECLARATION OF MEGAN E. RYAN IN SUPPORT OF EX PARTE REQUEST FOR AN ORDER SHORTENING TIME TO FILE MOTION TO CONTINUE TRIAL; EXHIBIT A (TRANSACTION ID # 100126418) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF JENNIFER E. CHOI OF SUBSEQUENTLY OBTAINED FACTS IN SUPPORT OF MOTION TO CONTINUE TRIAL (TRANSACTION ID # 100127492) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

STIPULATION IN SUPPORT OF EX PARTE APPLICATION FOR ORDER SHORTENING TIME FOR MOTION TO CONTINUE TRIAL AND MOTION TO CONTINUE TRIAL (TRANSACTION ID # 100126418) FILED BY CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

PROOF OF SERVICE BY PERSONAL DELIVERY (TRANSACTION ID # 100107656) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

MOTION TO COMPEL SUBPOENA FOR BUSINESS RECORDS FOR FOOK HONG SF CARE HOME, INC. (TRANSACTION ID # 100107659) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC. HEARING SET FOR AUG-24-2020 AT 09:00 AM IN DEPT 302

SUPPLEMENTAL INTERROGATORIES TO DEFENDANT VAN NESS CARE CENTER, INC., SET ONE (TRANSACTION ID # 66371255) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF OWAIS BARI IN SUPPORT OF MOTION TO COMPEL SUBPOENA FOR PRODUCTION OF DOCUMENTS FOR FOOK HONG SF CARE HOME, INC. (TRANSACTION ID # 100107659) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO BIFURCATE TRIAL; **COURT REPORTER FEES PAID*** (TRANSACTION ID # 100126292) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

MOTION TO BIFURCATE/SEVER TRIAL (TRANSACTION ID # 100126292) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO HEARING SET FOR APR-08-2021 AT 09:30 AM IN DEPT 302

DECLARATION OF PETER J. KEITH IN SUPPORT OF PLAINTIFFS MOTION IN LIMINE NO. 1: MOTION TO EXCLUDE EXTRINSIC EVIDENCE OFFERED BY DEFENDANTS TO SUPPORT THEIR UNREASONABLE INTERPRETATION OF THE CONTRACT; EXHIBITS A--G (TRANSACTION ID # 66998595) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF OWAIS BARI IN SUPPORT OF MOTION TO COMPEL SUBPOENA FOR BUSINESS RECORDS FOR RJ STARLIGHT HOME CORPORATION (TRANSACTION ID # 100107656) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

ORDER GRANTING DEFENDANTS' MOTION TO COMPEL COMPLIANCE WITH DEPOSITION SUBPOENA FOR RECORDS FROM FOOK HONG SF CARE HOME, INC.

NOTICE OF ENTRY OF ORDER/NOTICE OF RULING FILED GRANTING DEFENDANT'S MOTION TO COMPEL COMPLAINCE WITH DEPOSITION SUBPOENA FOR RECORDS FOR GONZALES HOME (TRANSACTION ID # 100113628) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

SUPPLEMENTAL INTERROGATORIES TO DEFENDANT MELVIN LEE, SET ONE (TRANSACTION ID # 66371255) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

NOTICE RE MOTION TO COMPEL TAKEN OFF CALENDAR (TRANSACTION ID # 100113821) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

REPLY IN SUPPORT OF THEIR MOTION TO QUASH DEPOSITION SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS DECLARATION OF KEVIN ENG AND EXHIBIT (TRANSACTION ID # 65751710) FILED BY THIRD PARTY GOLDEN GATE SUBTENANT LP SRG PACIFIC MANAGEMENT LLC

SUPPLEMENTAL INTERROGATORIES TO DEFENDANT SAN FRANCISCO CARE CENTER, L.P., SET ONE (TRANSACTION ID # 66371255) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

SUPPLEMENTAL INTERROGATORIES TO DEFENDANT TERESA WONG, SET ONE (TRANSACTION ID # 66371255) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

PROOF OF SERVICE BY ELECTRONIC MAIL (TRANSACTION ID # 100108657) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

SUBSTITUTION OF ATTORNEY, (TRANSACTION ID # 100116857): MILLSTEIN, DAVID J SUBSTITUTED FOR FELLNER, JASON E. AS ATTORNEY FOR LEE, MELVIN AN INDIVIDUAL

DECLARATION OF OWAIS M. BARI, ESQ. IN SUPPORT OF MOTION TO CONTINUE TRIAL (TRANSACTION ID # 100108657) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

PROOF OF SERVICE BY ELECTRONIC MAIL (TRANSACTION ID # 100126292) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

NOTICE OF ENTRY OF ORDER/NOTICE OF RULING FILED DENYING MTN TO QUASH (TRANSACTION ID # 100108733) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

DECLARATION OF TERESA WONG IN SUPPORT OF MOTION TO CONTINUE TRIAL (TRANSACTION ID # 100108657) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

SUPPLEMENTAL INTERROGATORIES TO CROSS-COMPLAINANT VAN NESS CARE CENTER, INC., SET ONE (TRANSACTION ID # 66371255) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO CONTINUE TRIAL (TRANSACTION ID # 100108657) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

PROOF OF SERVICE (TRANSACTION ID # 100107726) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

PLAINTIFFS CITY AND COUNTY OF SAN FRANCISCO AND PEOPLE OF THE STATE OF CALIFORNIAS STATEMENT OF CONDITIONAL NON-OPPOSITION TO DEFENDANTS MOTION TO CONTINUE NOVEMBER 9, 2020 TRIAL (TRANSACTION ID # 100109356) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

ORDER ; DISCOVERY ORDER DENYING MOTION TO QUASH (SEE SCANNED ORDER FOR DETAILS)

MOTION TO CONTINUE COURT TRIAL (TRANSACTION ID # 100108657) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC. HEARING SET FOR SEP-01-2020 AT 09:30 AM IN DEPT 206

MOTION / NOTICE & MOTION; MEMORANDUM OF POINTS & AUTHORITIES IN SUPPORT OF MOTION TO COMPEL SUBPOENA FOR BUSINESS RECORDS FOR SELF HELP FOR THE ELDERLY (TRANSACTION ID # 100107726) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC. HEARING SET FOR AUG-20-2020 AT 09:00 AM IN DEPT 302

RESPONSE TO SEPARATE STATEMENT (TRANSACTION ID # 100105527) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL SUBPOENA FOR PRODUCTION OF DOCUMENTS FROM SELF-HELP FOR THE ELDERLY (TRANSACTION ID # 100107726) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

SEPARATE STATEMENT OF FACTS IN SUPPORT OF MOTION TO COMPEL SUBPOENA FOR PRODUCTION OF DOCUMENTS FOR GONZALES HOME(TRANSACTION ID # 100107660) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

DECLARATION OF OWAIS BARI IN SUPPORT OF MOTION TO COMPEL SUBPOENA FOR PRODUCTION OF DOCUMENTS FOR GONZALES HOME (TRANSACTION ID # 100107660) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

PROOF OF SERVICE BY PERSONAL DELIVERY (TRANSACTION ID # 100107660) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

DECLARATION OF OWAIS M. BARI, ESQ. IN SUPPORT OF MOTION TO COMPEL SUBPOENA FOR PRODUCTION OF DOCUMENTS FROM SELF-HELP FOR THE ELDERLY (TRANSACTION ID # 100107726) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

PROOF OF SERVICE (TRANSACTION ID # 100105527) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

PROOF OF SERVICE BY ELECTRONIC MAIL ON MEMO OF POINTS AND AUTHORITIES IN SUPPORT OF DEFENDANTS OPPOSITION TO PLAINTIFF'S MOTION TO BIFURCATE TRIAL (TRANSACTION ID # 100127354) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

PROOF OF SERVICE OF NOTICE OF ENTRY OF ORDER GRANTING DEFENDANTS LEAVE OF COURT TO FILE SECOND AMENDED CROSS-COMPLAINT (TRANSACTION ID # 100104287) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

DECLARATION OF OWAIS BARI (TRANSACTION ID # 100105527) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

OPPOSITION TO MOTION TO QUASH (TRANSACTION ID # 100105527) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

ORDER - STIPULATION AND ORDER TO CONTINUE HEARING AND BRIEFING DATES ON THIRD PARTIES GOLDEN GATE SUBTENANT LP AND SRG PACIFIC MANAGEMENT LLC'S MOTION TO QUASH DEPOSITION SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS

PROOF OF SERVICE FOR PLAINTIFF CITY AND COUNTY OF SAN FRANCICO'S SUPPLEMENTAL INTERROGATORIES (6) (TRANSACTION ID # 66371255) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

NOTICE OF ENTRY OF ORDER/NOTICE OF RULING FILED - STIPULATION AND ORDER TO CONTINUE HEARING AND BRIEFING DATES ON THIRD PARTIES GOLDEN GATE SUBTENANT LP AND SRG PACIFIC MANAGEMENT LLC'S MOTION TO QUASH DEPOSITION SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS (TRANSACTION ID # 100105150) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

PROOF OF SERVICE (TRANSACTION ID # 100103658) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

SEPARATE STATEMENT OF FACTS IN SUPPORT OF THEIR MOTION TO QUASH DEPOSITION SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS OR ALTERNATIVELY FOR A PROTECTIVE ORDER (TRANSACTION ID # 65678645) FILED BY THIRD PARTY GOLDEN GATE SUBTENANT LP SRG PACIFIC MANAGEMENT LLC

THIRD PARTIES GOLDEN GATE SUBTENANT LP AND SRG PACIFIC MANAGEMENT LLC MOTION TO QUASH DEPOSITION SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS; MEMORANDUM OF POINTS AND AUTHORITIES;SUPPORTING DECLARATION OF KEVIN ENG AND EXHIBITS, PROOF OF SERVICE, POINTS AND AUTHORITIES, DECLARATION (TRANSACTION ID # 65678645) FILED BY THIRD PARTY GOLDEN GATE SUBTENANT LP SRG PACIFIC MANAGEMENT LLC HEARING SET FOR JUL-07-2020 AT 09:30 AM IN DEPT 302

STIPULATION IN SUPPORT OF EX PARTE REQUEST FOR AN ORDER SHORTENING TIME TO FILE MOTION TO CONTINUE TRIAL DATE AND TO CONTINUE TRIAL DATE (TRANSACTION ID # 65634991) FILED BY CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

PROOF OF SERVICE BY ELECTRONIC MAIL (TRANSACTION ID # 65629489) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

STIPULATION IN SUPPORT OF EX PARTE REQUEST FOR AN ORDER SHORTENING TIME TO FILE MOTION TO CONTINUE TRIAL DATE AND TO CONTINUE TRIAL DATE (TRANSACTION ID # 65637897) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO AS TO DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

PROOF OF SERVICE (TRANSACTION ID # 65637897) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF JENNIFER E. CHOI IN SUPPORT OF NOTICE OF MOTION TO CONTINUE TRIAL DATE (TRANSACTION ID # 65637897) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

MOTION TO CONTINUE COURT TRIAL (TRANSACTION ID # 65637897) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO HEARING SET FOR MAY-28-2020 AT 09:30 AM IN DEPT 206

NOTICE OF ERRATA TO OWAIS DECLARATION (TRANSACTION ID # 100105634) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL

DECLARATION OF JENNIFER E. CHOI IN SUPPORT OF EX PARTE APPLICATION FOR ORDER SHORTENING TIME TO FILE MOTION TO CONTINUE TRIAL DATE (TRANSACTION ID # 65634991) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

EX PARTE APPLICATION FOR ORDER SHORTENING TIME TO FILE MOTION TO CONTINUE TRIAL DATE, PROOF OF SERVICE (TRANSACTION ID # 65634991) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

STIPULATION IN SUPPORT OF EX PARTE APPLICATION TO CONTINUE TRIAL DATE (TRANSACTION ID # 65629489) FILED BY CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF JENNIFER E. CHOI IN SUPPORT OF EX PARTE APPLICATION TO CONTINUE TRIAL DATE (TRANSACTION ID # 65629489) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

EX PARTE APPLICATION FOR ORDER TO CONTINUE TRIAL (TRANSACTION ID # 65629489) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

PROOF OF SERVICE OF EX PARTE APPLICATION TO SEEK LEAVE OF COURT TO FILE THIRD AMENDED ANSWER; DECLARATION; STIPULATION (TRANSACTION ID # 100097543) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

NOTICE OF CHANGE OF ADDRESS (TRANSACTION ID # 64737349) FILED BY ATTORNEY FELLNER, JASON E.

PROOF OF SERVICE OF NOTICE OF JOINT MOTION TO CONTINUE TRIAL AND STAY PROCEEDINGS; JOINT MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION (TRANSACTION ID # 100088512) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

JOINT EX PARTE FOR AN ORDER SHORTENING TIME TO HEAR NOTICE OF JOINT MOTION TO CONTINUE TRIAL AND STAY PROCEEDINGS (TRANSACTION ID # 100088705) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

ORDER GRANTING EX PARTE APPLICATION FOR ORDER TO CONTINUE TRIAL AND STAY PROCEEDINGS. DEFENDANTS' NOTICE OF JOINT MOTION TO CONTINUE TRIAL AND STAY PROCEEDINGS SET FOR DECEMBER 5, 2019 IS TAKEN OF CALENDER. TRIAL DATE OF MARCH 9, 2020 IS CONTINUED TO JUNE 8, 2020.

DECLARATION OF GERALD RICHELSON IN SUPPORT OF EX PARTE FOR AN ORDER SHORTENING TIME TO HEAR NOTICE OF JOINT MOTION TO CONTINUE TRIAL AND STAY PROCEEDINGS (TRANSACTION ID # 100088705) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

PROOF OF SERVICE OF JOINT EX PARTE FOR AN ORDER SHORTENING TIME TO HEAR NOTICE OF JOINT MOTION TO CONTINUE TRIAL AND STAY PROCEEDINGS; DECLARATION (TRANSACTION ID # 100088705) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

NOTICE OF JOINT MOTION TO CONTINUE TRIAL AND STAY PROCEEDINGS (TRANSACTION ID # 100088512) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC. HEARING SET FOR DEC-05-2019 AT 09:30 AM IN DEPT 302

JOINT MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF JOINT MOTION TO CONTINUE TRIAL AND STAY PROCEEDINGS (TRANSACTION ID # 100088512) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

DECLARATION OF JEF ISO MTN FOR LEAVE OF COURT TO FILE X-CPLT (TRANSACTION ID # 64230091) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

PROOF OF SERVICE FOR OPPOSITIOM FOR MOTION FOR LEAVE OF COURT TO FILE SECOND AMENDED VERIFIED ANSWER (TRANSACTION ID # 64272933) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

CONSENT TO ELECTRONIC SERVICE AND NOTICE OF ELECTRONIC SERVICE ADDRESS (TRANSACTION ID # 64237736) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL

PROOF OF SERVICE IN OPPOSITION TO MOTION FOR LEAVE OF COURT TO FILE CROSS-COMPLAINT (TRANSACTION ID # 64272270) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

MPA ISO JOINT MTN FOR LEAVE OF COURT TO FILE X-CPLT (TRANSACTION ID # 64230091) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

NTC OF JOINT MTN AND JOINT MTN FOR LEAVE OF COURT TO FILE X-CPLT (TRANSACTION ID # 64230091) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC. HEARING SET FOR OCT-17-2019 AT 09:30 AM IN DEPT 302

MOTION TO CONTINUE COURT TRIAL, PROOF OF SERVICE (TRANSACTION ID # 63624045) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL HEARING SET FOR AUG-15-2019 AT 09:30 AM IN DEPT 206

NOTICE OF JOINT MOTION AND JOINT MOTION FOR LEAVE OF COURT TO FILE SECOND AMENDED VERIFIED ANSWER (TRANSACTION ID # 64230091) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC. HEARING SET FOR OCT-17-2019 AT 09:30 AM IN DEPT 302

SUBSTITUTION OF ATTORNEY, (TRANSACTION ID # 63387941): FELLNER, JASON E. SUBSTITUTED FOR MILLSTEIN, DAVID J AS ATTORNEY FOR LEE, MELVIN AN INDIVIDUAL

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO CONTINUE TRIAL (TRANSACTION ID # 63624045) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL

DECLARATION OF JASON E. FELLNER IN SUPPORT OF DEFENDANT MELVIN LEE MOTION TO CONTINUE TRIAL (TRANSACTION ID # 63624045) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL

CONSENT TO ELECTRONIC SERVICE (TRANSACTION ID # 100073273) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

EX PARTE APPLICATION FOR ORDER TO CONTINUE TRIAL, POINTS AND AUTHORITIES (TRANSACTION ID # 100072426) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

CONSENT TO ELECTRONIC SERVICE AND NOTICE OF ELECTRONIC SERVICE ADDRESS (TRANSACTION ID # 63310671) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

SUBSTITUTION OF ATTORNEY, (TRANSACTION ID # 63248257): MILLSTEIN, DAVID J SUBSTITUTED FOR GRUBER, AARON R. AS ATTORNEY FOR WONG, TERESA AN INDIVIDUAL

PROOF OF SERVICE RE: EX PARTE APPLICATION TO CONTINUE TRIAL; DEC; STIPULATION AND PROPOSED ORDER (TRANSACTION ID # 100072426) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

STIPULATION TO CONTINUE TRIAL (TRANSACTION ID # 100072426) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

SUBSTITUTION OF ATTORNEY, (TRANSACTION ID # 63248236): MILLSTEIN, DAVID J SUBSTITUTED FOR GRUBER, AARON R. AS ATTORNEY FOR MEL LEE MANAGEMENT, INC.

SUBSTITUTION OF ATTORNEY, (TRANSACTION ID # 63246950): MILLSTEIN, DAVID J SUBSTITUTED FOR GRUBER, AARON R. AS ATTORNEY FOR LEE, MELVIN AN INDIVIDUAL

PROPOSED ORDER COVER SHEET RE LEE MOTION FOR PROTECTIVE ORDER AND FOR SANCTIONS (TRANSACTION ID # 63252937) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

SUBSTITUTION OF ATTORNEY, (TRANSACTION ID # 63249624): MILLSTEIN, DAVID J SUBSTITUTED FOR GRUBER, AARON R. AS ATTORNEY FOR SAN FRANCISCO CARE CENTER, L.P.

SUBSTITUTION OF ATTORNEY, (TRANSACTION ID # 63248249): MILLSTEIN, DAVID J SUBSTITUTED FOR GRUBER, AARON R. AS ATTORNEY FOR VAN NESS CARE CENTER, INC.

ASSOCIATION OF ATTORNEYS, (TRANSACTION ID # 63225445): RYAN, MEGAN E. ADDED AS ATTORNEY FOR CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

REPLY OF TERESA WONG TO OPPOSITION OF CCSF TO MOTION FOR PROTECTIVE ORDER AND FOR SANCTIONS (TRANSACTION ID # 63134655) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL

REQUEST FOR JUDICIAL NOTICE OF TERESA WONG (TRANSACTION ID # 63134655) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL

DECLARATION OF JENNIFER E. CHOI IN OPPOSITION TO DEFENDANT TERESA WONGS MOTION FOR PROTECTIVE ORDER AND SANCTIONS; EXHIBITS A--H [PART ONE OF TWO] (TRANSACTION ID # 63106118) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF JENNIFER E. CHOI IN OPPOSITION TO DEFENDANT MELVIN LEES MOTION FOR PROTECTIVE ORDER AND SANCTIONS; EXHIBITS A--G [PART ONE OF TWO] (TRANSACTION ID # 63106118) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

EXHIBITS I--R TO DECLARATION OF JENNIFER E. CHOI IN OPPOSITION TO DEFENDANT TERESA WONGS MOTION FOR PROTECTIVE ORDER AND SANCTIONS; [PART TWO OF TWO] (TRANSACTION ID # 63106118) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

PROOF OF SERVICE OF [PROPOSED] ORDERS (TRANSACTION ID # 63106118) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

PLAINTIFF CITY AND COUNTY OF SAN FRANCISCOS MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO DEFENDANT TERESA WONGS MOTION FOR PROTECTIVE ORDER; REQUEST FOR SANCTIONS (TRANSACTION ID # 63106118) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

EXHIBITS H--Q TO DECLARATION OF JENNIFER E. CHOI IN OPPOSITION TO DEFENDANT MELVIN LEES MOTION FOR PROTECTIVE ORDER AND SANCTIONS; [PART TWO OF TWO] (TRANSACTION ID # 63106118) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF AARON R. GRUBER IN SUPPORT OF MOTION FOR PROTECTIVE ORDER (TRANSACTION ID # 63069270) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL

NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER AND FOR SANCTIONS (TRANSACTION ID # 63069270) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL HEARING SET FOR APR-11-2019 AT 09:00 AM IN DEPT 302

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION FOR PROTECTIVE ORDER (TRANSACTION ID # 63069270) FILED BY DEFENDANT WONG, TERESA AN INDIVIDUAL

DECLARATION OF AARON R. GRUBER IN SUPPORT OF MOTION FOR PROTECTIVE ORDER (TRANSACTION ID # 63069270) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL

PLAINTIFF CITY AND COUNTY OF SAN FRANCISCOS MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO DEFENDANT MELVIN LEES MOTION FOR PROTECTIVE ORDER; REQUEST FOR SANCTIONS (TRANSACTION ID # 63106118) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

MELVIN LEE NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER AND FOR SANCTIONS (TRANSACTION ID # 63069270) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL HEARING SET FOR APR-11-2019 AT 09:00 AM IN DEPT 302

ORDER GRANTING CONTINUANCE OF TRIAL

NOTICE OF ENTRY OF ORDER/NOTICE OF RULING FILED (TRANSACTION ID # 63013307) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

STIPULATION FOR CONTINUANCE OF TRIAL (TRANSACTION ID # 63007388) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

SUMMONS ON COMPLAINT (TRANSACTION ID # 61893609), PROOF OF SERVICE ONLY, FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO SERVED MAR-28-2018, PERSONAL SERVICE AS TO DEFENDANT MEL LEE MANAGEMENT, INC.

PROOF OF SERVICE RE: EXPARTE APPLICATION FOR TRIAL CONTINUANCE; ETC (TRANSACTION ID # 63007388) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

ORDER GRANTING EX PARTE APPLICATION FOR ENTRY OF STIPULATED PROTECTIVE ORDER.

NOTICE OF ENTRY OF ORDER GRANTING PLAINTIFFS EX PARTE APPLICATION FOR ENTRY OF STIPULATED PROTECTIVE ORDER; EXHIBIT A (TRANSACTION ID # 62914727) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

EX PARTE APPLICATION FOR ORDER SETTING SPECIALLY SET SETTLEMENT CONFERENCE; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF AARON R. GRUBER (TRANSACTION ID # 62942175) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

SUMMONS ON COMPLAINT (TRANSACTION ID # 61893609), PROOF OF SERVICE ONLY, FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO SERVED MAR-28-2018, PERSONAL SERVICE AS TO DEFENDANT WONG, TERESA AN INDIVIDUAL

CASE MANAGEMENT STATEMENT (JOINTLY) (TRANSACTION ID # 62249525) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO JURY DEMANDED, ESTIMATED TIME FOR TRIAL: 4.0 DAYS

NOTICE OF TIME AND PLACE OF TRIAL, COURT TRIAL SET FOR MAY-20-2019 AT 9:30 AM IN DEPT. 206. CASE MANAGEMENT CONFERENCE ON AUG-22-2018 IS OFF CALENDAR. NOTICE SENT BY COURT.

ORDER GRANTING EX PARTE APPLICATION FOR ORDER SETTING SPECIALLY SET SETTLEMENT CONFERENCE

EX PARTE APPLICATION FOR ORDER FOR ENTRY OF PROTECTIVE ORDER (TRANSACTION ID # 62908047) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

SUMMONS ON COMPLAINT (TRANSACTION ID # 61893609), PROOF OF SERVICE ONLY, FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO SERVED MAR-28-2018, SUBSTITUTE SERVICE ON NATURAL PERSON, MAILING DATE MAR-29-2018 AS TO DEFENDANT LEE, MELVIN AN INDIVIDUAL

ORDER AND STIPULATION FOR PROTECTIVE ORDER

NOTICE OF SETTLEMENT CONFERENCE; SETTLEMENT CONFERENCE SET FOR MAR-26-2019 AT 8:30 AM IN DEPT. 212 WITH CONFERENCE OFFICER MARTIN F. TRIANO

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION FOR PROTECTIVE ORDER (TRANSACTION ID # 63069270) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL

ANSWER TO COMPLAINT (TRANSACTION ID # 62029659) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

EX PARTE APPLICATION FOR ORDER FOR CONTINUANCE OF TRIAL (TRANSACTION ID # 63007388) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

NOTICE OF ENTRY OF STIPULATION AND ORDER FOR PROTECTIVE ORDER; EXHIBIT A (TRANSACTION ID # 62914727) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF JENNIFER E. CHOI IN SUPPORT OF PLAINTIFFS EX PARTE APPLICATION FOR ENTRY OF PROTECTIVE ORDER; EXHIBITS A AND B (TRANSACTION ID # 62908047) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF JENNIFER E. CHOI IN SUPPORT OF EX PARTE APPLICATION FOR CONTINUANCE OF TRIAL (TRANSACTION ID # 63007388) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

NOTICE TO PLAINTIFF

AMENDED ANSWER TO COMPLAINT (TRANSACTION ID # 62066686) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

SUMMONS ON COMPLAINT (TRANSACTION ID # 61893609), PROOF OF SERVICE ONLY, FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO SERVED MAR-28-2018, SUBSTITUTE SERVICE ON NATURAL PERSON, MAILING DATE MAR-29-2018 AS TO DEFENDANT SAN FRANCISCO CARE CENTER, L.P.

OTHER NON EXEMPT COMPLAINTS, COMPLAINT FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO AS TO DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC. DOES 1 TO 50, INCLUSIVE SUMMONS ISSUED, JUDICIAL COUNCIL CIVIL CASE COVER SHEET FILED CASE MANAGEMENT CONFERENCE SCHEDULED FOR AUG-22-2018 PROOF OF SERVICE DUE ON MAY-22-2018 CASE MANAGEMENT STATEMENT DUE ON JUL-30-2018

NOTICE OF UNAVAILABILITY OF CHOI, JENNIFER ON DEC-24-2018 THROUGH JAN-07-2019 (TRANSACTION ID # 62724848) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

ORDER RE DEFENSE COUNSEL MOTION TO WITHDRAW (TRANSACTION #67284897)

DECLARATION OF OWAIS M. BARI IN SUPPORT OF DEFENDANTS EX PARTE APPLICATION FOR AN ORDER SHORTENING TIME TO HEAR NOTICE OF MOTION TO WITHDRAW AS COUNSEL (TRANSACTION ID # 67283077) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P.

OPPOSITION TO DEFENDANTS MOTION IN LIMINE NO. 9 TO EXCLUDE WITNESSES SUBPOENAED FROM OTHER ASSISTED LIVING FACILITIES (TRANSACTION ID # 100154413) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

NOTICE OF CONTINUANCE OF PRETRIAL HEARING (TRANSACTION #67284897)

MOTION IN LIMINE NO. 9 TO EXCLUDE WITNESSES SUBPOENAED FROM OTHER ASSISTED LIVING FACILITIES (TRANSACTION ID # 67243113) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P.

EX PARTE APPLICATION FOR ORDER SHORTENING TIME TO HEAR NOTICE OF MOTION TO WITHDRAW COUNSEL (TRANSACTION ID # 67283077) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P.

PROOF OF SERVICE (TRANSACTION ID # 67283077) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P.

PROOF OF SERVICE FOR DEFENDANTS' MOTION IN LIMINE NO 9 TO EXCLUDE WITNE3SSES SUBPOENAED FROM OTHER ASSISTED LIVING FACILITES, ETC. (TRANSACTION ID # 67243113) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P.

MOTION IN LIMINE NO. 1 REGARDING DUTY (TRANSACTION ID # 66998777) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

MINUTES FOR NOV-17-2021 1:30 PM

DECLARATION OF OWAIS M. BARI, ESQ IN SUPPORT OF DEFENDANTS? MOTION IN LIMINE NO. 9 TO EXCLUDE WITNESSES SUBPOENAED FROM OTHER ASSISTED LIVING FACILITIES (TRANSACTION ID # 67243113) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P.

OPPOSITION TO PLAINTIFFS? MOTIONS IN LIMINE NOS. 3: MOTIONS TO EXCLUDE DEFENDANTS? RETAINED EXPERT JOHN BOWBLIS, PH.D. (TRANSACTION ID # 67053657) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

NOTICE OF ENTRY OF ORDER/NOTICE OF RULING FILED (TRANSACTION ID # 67027567) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

ORDER SETTING PRETRIAL CONFERENCE (TRANSACTION #67023979)

JOINT STATEMENT FOR 12/13/21 PRETRIAL CONFERENCE (TRANSACTION ID # 100149446) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

MINUTES FOR DEC-13-2021 2:00 PM

PROOF OF SERVICE FOR OPPOSITION TO PLAINTIFFS MOTION IN LIMINE NO.2, NO. 3, NO. 4 AND NO. 5, ETC. (TRANSACTION ID # 67009028) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

JOINT STATEMENT FOR 11-17-21 PRETRIAL CONFERENCE (TRANSACTION ID # 67090772) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

ORDER RE: PRETRIAL CONFERENCE ORDER #2

ORDER PRETRIAL CONFERENCE ORDER NO.3 (TRANSACTION #67168119)

DISMISSAL WITHOUT PREJUDICE OF COMPLAINT (TRANSACTION ID # 67107085) AS TO DEFENDANT MEL LEE MANAGEMENT, INC.

DECLARATION OF OWAIS BARI IN SUPPORT OF DEFENDANTS EX PARTE APPLICATION TO SEEK LEAVE OF COURT TO WITHDRAW FILED OPPOSITION TO PLAINTIFF'S MIL # 3 AND FILE AN AMENDED OPPOSITION SUBJECT TO PARTIES STIPULATION (TRANSACTION ID # 100144583) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

ORDER GRANTING EX PARTE APPLICATION TO REMOVE OPPOSITION TO PLAINTIFF'S MOTION IN LIMINE #3 AND TO RE-FILE A NEW VERSION; MEMORANDUM OF POINTS AND AUTHORITIES

EX PARTE APPLICATION FOR ORDER EX PARTE APPLICATION AND MEMORANDUM OF POINTS AND AUTHORITIES, POINTS AND AUTHORITIES (TRANSACTION ID # 100144583) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

OPPOSITION TO PLAINTIFFS? MOTION IN LIMINE NO. 1: MOTION TO EXCLUDE EXTRINSIC EVIDENCE OFFERED BY DEFENDANTS TO SUPPORT THEIR UNREASONABLE INTERPRETATION OF THE CONTRACT (TRANSACTION ID # 67009051) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

TRIAL BRIEF (TRANSACTION ID # 100144244) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

PROOF OF SERVICE BY ELECTRONIC MAIL ON DEFENDANT'S EX PARTE APPLICATION TO REMOVE OPPOSITION TO PLAINTIFF'S MOTION IN LIMINE # 3 AND TO RE-FILE A NEW VERSION; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF; DECLARATION OF OWAIS M. BARI, ESQ IN SUPPORT OF; [PROPOSED] ORDER GRANTING EX PARTE APPLICATION TO REMOVE OPPOSITION TO PLAINTIFF'S MOTION IN LIMINE # 3 AND TO RE-FILE A NEW VERSION; MEMORANDUM OF POINTS AND AUTHORITIES (TRANSACTION ID # 100144583) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

MOTION IN LIMINE NO. 8 MISCELLANEOUS TOPICS (TRANSACTION ID # 66998772) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

PROOF OF SERVICE BY ELECTRONIC MAIL (TRANSACTION ID # 66998772) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

MOTION IN LIMINE NO. 7 - TO EXCLUDE UNALLEGED CLAIMS OR THEORIES (TRANSACTION ID # 66998772) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

MOTION IN LIMINE NO. 5 - TO EXCLUDE REFERENCE OR ARGUMENT SUGGESTING THE CITY IS ACTING IN A LAW ENFORCEMENT AGENCY FOR THE PEOPLE (TRANSACTION ID # 66998772) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

PROOF OF SERVICE RE: MOTIONS IN LIMINE (TRANSACTION ID # 66998725) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

MOTION IN LIMINE NO. 4 - TO EXCLUDE EVIDENCE RELATED TO PLAINTIFFS' RECOVERY OF DAMAGES PRIOR TO ISSUANCE OF NOTICE OF DEFAULT (TRANSACTION ID # 66998725) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

MOTION IN LIMINE NO. 3 - TO EXCLUDE LIMIT EVIDENCE OF CONDUCT NOT LISTED IN THE NOTICE OF BREACH (TRANSACTION ID # 66998725) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

PROOF OF SERVICE BY ELECTRONIC MAIL (TRANSACTION ID # 66998641) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

PLAINTIFFS MOTION IN LIMINE NO. 5: MOTION TO EXCLUDE EVIDENCE OF SETTLEMENTS OF OTHER LITIGATION (TRANSACTION ID # 66998625) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

PROOF OF SERVICE (TRANSACTION ID # 66998595) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

DECLARATION OF MEGAN RYAN IN SUPPORT OF PLAINTIFFS MOTIONS IN LIMINE NO. 3-4: MOTIONS TO EXCLUDE DEFENDANTS EXPERT JOHN BOWBLIS, PH.D; EXHIBITS A--M (TRANSACTION ID # 66998641) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

MOTION IN LIMINE NOS. 3 AND 4: MOTIONS TO EXCLUDE DEFENDANTS RETAINED EXPERT JOHN BOWBLIS, PH.D. (TRANSACTION ID # 66998641) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

PLAINTIFFS MOTION IN LIMINE NO. 2: MOTION TO PRECLUDE DEFENDANTS FROM CALLING PLAINTIFFS COUNSEL DCA KRISTEN JENSEN AS A TRIAL WITNESS (TRANSACTION ID # 66998625) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO

MOTION IN LIMINE NO. 2 - TO EXCLUDE THE TESTIMONY OF PLAINTIFF'S EXPERT JP; OR IN THE ALTERNATIVE A MOTION FOR A HEARING UNDER EVIDENCE CODE SECTION 402 (TRANSACTION ID # 66998725) FILED BY DEFENDANT LEE, MELVIN AN INDIVIDUAL WONG, TERESA AN INDIVIDUAL VAN NESS CARE CENTER, INC. SAN FRANCISCO CARE CENTER, L.P. MEL LEE MANAGEMENT, INC.

SUPPLEMENTAL INTERROGATORIES TO CROSS-COMPLAINANT SAN FRANCISCO CARE CENTER, L.P.,, SET ONE (TRANSACTION ID # 66371255) FILED BY PLAINTIFF CITY AND COUNTY OF SAN FRANCISCO A MUNICIPAL CORPORATION THE PEOPLE OF THE STATE OF CALIFORNIA BY AND THROUGH DENNIS J. HERRERA, CITY ATTORNEY FOR THE CITY AND COUNTY OF SAN FRANCISCO