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ERIN E. HOLBROOK, Chief Counsel
1 G. MICHAEL HARRINGTON, Deputy Chief Counsel
SAMUEL C. LAW, Assistant Chief Counsel
2 JOSE A. GONZALEZ, Deputy Attorney (SBN: 248922)
111 Grand Avenue, Suite 11-100, Oakland, CA 94612
3 MAIL TO: PO BOX 24325, Oakland, CA 94623-1325
Telephone: (510) 433-9100
4 Facsimile: (510) 433-9167 (NO FEE PURSUANT TO GOV. CODE, § 6103)
5 Attorneys for Defendant STATE OF CALIFORNIA,
acting by and through the Department of Transportation,
6 sued herein as STATE OF CALIFORNIA DEPARTMENT OF TRANSPORTATION
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8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
4/11/2022
9 FOR THE COUNTY OF SAN MATEO
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DEBORAH SKUCAS, Case No. 20-CIV-05519
CALIFORNIA DEPARTMENT OF TRANSPORTATION - LEGAL DIVISION
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111 Grand Avenue, Suite 11-100, Oakland, California 94612
Plaintiff,
Telephone: (510) 433-9100, Facsimile: (510) 433-9167
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vs. [PROPOSED] ORDER TO CONTINUE
13 TRIAL AND RELATED DEADLINES
COUNTY OF SAN MATEO; STATE OF
14 CALIFORNIA DEPARTMENT OF Trial Date: September 12, 2022
TRANSPORTATION; and DOES 1 TO 100, Dept. 21
15 inclusive, Judge: Hon. Robert D. Foiles
16 Defendants.
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19 ORDER TO CONTINUE TRIAL AND RELATED DEADLINES
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Based on the STIPULATION TO CONTINUE TRIAL AND RELATED DEADLINES the
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Court finds:
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GOOD CAUSE appearing, the trial in this matter is continued from September 12, 2022 to:
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__________________________________________________________________________ and all
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25 deadlines based on the trial date, including without limitation discovery and motion cut-off dates,
26 shall be based on the new trial date.
27 GOOD CAUSE appearing, the pre-trial conference in this matter is continued from August
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______________________________________________________________________________________________
[PROPOSED] ORDER TO CONTINUE TRIAL AND RELATED DEADLINES
29, 2022 to:___________________________________________________________.
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2 GOOD CAUSE appearing, the mandatory settlement conference in this matter is continued
3 from August 19, 2022 to:______________________________________________________.
4 Defendant STATE OF CALIFORNIA shall give notice of this Order to all parties.
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IT IS SO ORDERED.
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7 DATED: ________________ _______________________________________
JUDGE OF THE SUPERIOR COURT
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CALIFORNIA DEPARTMENT OF TRANSPORTATION - LEGAL DIVISION
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111 Grand Avenue, Suite 11-100, Oakland, California 94612
Telephone: (510) 433-9100, Facsimile: (510) 433-9167
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______________________________________________________________________________________________
[PROPOSED] ORDER TO CONTINUE TRIAL AND RELATED DEADLINES
Case Name: Deborah Skucas v. County of San Mateo et al.
Case No.: San Mateo County Superior Court Case No. 20-CIV-05519
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PROOF OF ELECTRONIC SERVICE
2 I am employed in the City of Oakland, State of California. I am over the age of 18 years and
not a party to the within action. My business address is 111 Grand Avenue, Oakland, California
3 94612; MAIL: P.O. BOX 24325, Oakland, CA 94623-1325. On the date set forth below, I served a
true copy of the following document(s):
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5 [PROPOSED] ORDER TO CONTINUE TRIAL AND RELATED DEADLINES
on the interested party to said action by the following means:
6 [XX] (BY ELECTRONIC-MAIL ONLY) by attaching a copy of the document(s) in PDF
format sent from Rosalie.H.Nguyen@dot.ca.gov to the email addresses of the parties
7 listed below, pursuant to Code of Civil Procedure section 1010.6, subd. (a) and (e),
permitting electronic service of notices or documents that may be served by mail, express
8 mail, overnight delivery, or facsimile transmission. No hard copies will follow.
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COUNSEL OF RECORD EMAIL ADDRESSES
10 Mirali Vazirinejad, Esq.
Grace Carpio
11 THE BARNES FIRM L.C. ali.vazirinejad@thebarnesfirm.com
555 12th Street, Suite 1470
12 Oakland, CA 94607
Attorneys for Plaintiff, Grace.Carpio@thebarnesfirm.com
13 Deborah Skucas
14 With cc to:
Jose A. Gonzalez JoseA.Gonzalez@dot.ca.gov
15 CALIFORNIA DEPT OF TRANSPORTATION
– LEGAL DIVISION
maria.cordonero@dot.ca.gov
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Attorney for Defendant,
17 State of California
18 I declare under penalty of perjury under the laws of the State of California that the foregoing
is true and correct. Executed on April 11, 2022, at Fremont, California.
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21 ROSALIE NGUYEN, Declarant
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PROOF OF ELECTRONIC SERVICE
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ERIN E. HOLBROOK, Chief Counsel 1 G. MICHAEL HARRINGTON, Deputy Chief Counsel SAMUEL C. LAW, Assistant Chief Counsel 2 JOSE A. GONZALEZ, Deputy Attorney (SBN: 248922) 111 Grand Avenue, Suite 11-100, Oakland, CA 94612 3 MAIL TO: PO BOX 24325, Oakland, CA 94623-1325 Telephone: (510) 433-9100 4 Facsimile: (510) 433-9167 (NO FEE PURSUANT TO GOV. CODE, § 6103) 5 Attorneys for Defendant STATE OF CALIFORNIA, acting by and through the Department of Transportation, 6 sued herein as STATE OF CALIFORNIA DEPARTMENT OF TRANSPORTATION 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 4/11/2022 9 FOR THE COUNTY OF SAN MATEO 10 DEBORAH SKUCAS, Case No. 20-CIV-05519 CALIFORNIA DEPARTMENT OF TRANSPORTATION - LEGAL DIVISION 11 111 Grand Avenue, Suite 11-100, Oakland, California 94612 Plaintiff, Telephone: (510) 433-9100, Facsimile: (510) 433-9167 12 vs. [PROPOSED] ORDER TO CONTINUE 13 TRIAL AND RELATED DEADLINES COUNTY OF SAN MATEO; STATE OF 14 CALIFORNIA DEPARTMENT OF Trial Date: September 12, 2022 TRANSPORTATION; and DOES 1 TO 100, Dept. 21 15 inclusive, Judge: Hon. Robert D. Foiles 16 Defendants. 17 18 19 ORDER TO CONTINUE TRIAL AND RELATED DEADLINES 20 Based on the STIPULATION TO CONTINUE TRIAL AND RELATED DEADLINES the 21 Court finds: 22 GOOD CAUSE appearing, the trial in this matter is continued from September 12, 2022 to: 23 __________________________________________________________________________ and all 24 25 deadlines based on the trial date, including without limitation discovery and motion cut-off dates, 26 shall be based on the new trial date. 27 GOOD CAUSE appearing, the pre-trial conference in this matter is continued from August 28 1 ______________________________________________________________________________________________ [PROPOSED] ORDER TO CONTINUE TRIAL AND RELATED DEADLINES 29, 2022 to:___________________________________________________________. 1 2 GOOD CAUSE appearing, the mandatory settlement conference in this matter is continued 3 from August 19, 2022 to:______________________________________________________. 4 Defendant STATE OF CALIFORNIA shall give notice of this Order to all parties. 5 IT IS SO ORDERED. 6 7 DATED: ________________ _______________________________________ JUDGE OF THE SUPERIOR COURT 8 9 10 CALIFORNIA DEPARTMENT OF TRANSPORTATION - LEGAL DIVISION 11 111 Grand Avenue, Suite 11-100, Oakland, California 94612 Telephone: (510) 433-9100, Facsimile: (510) 433-9167 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 ______________________________________________________________________________________________ [PROPOSED] ORDER TO CONTINUE TRIAL AND RELATED DEADLINES Case Name: Deborah Skucas v. County of San Mateo et al. Case No.: San Mateo County Superior Court Case No. 20-CIV-05519 1 PROOF OF ELECTRONIC SERVICE 2 I am employed in the City of Oakland, State of California. I am over the age of 18 years and not a party to the within action. My business address is 111 Grand Avenue, Oakland, California 3 94612; MAIL: P.O. BOX 24325, Oakland, CA 94623-1325. On the date set forth below, I served a true copy of the following document(s): 4 5 [PROPOSED] ORDER TO CONTINUE TRIAL AND RELATED DEADLINES on the interested party to said action by the following means: 6 [XX] (BY ELECTRONIC-MAIL ONLY) by attaching a copy of the document(s) in PDF format sent from Rosalie.H.Nguyen@dot.ca.gov to the email addresses of the parties 7 listed below, pursuant to Code of Civil Procedure section 1010.6, subd. (a) and (e), permitting electronic service of notices or documents that may be served by mail, express 8 mail, overnight delivery, or facsimile transmission. No hard copies will follow. 9 COUNSEL OF RECORD EMAIL ADDRESSES 10 Mirali Vazirinejad, Esq. Grace Carpio 11 THE BARNES FIRM L.C. ali.vazirinejad@thebarnesfirm.com 555 12th Street, Suite 1470 12 Oakland, CA 94607 Attorneys for Plaintiff, Grace.Carpio@thebarnesfirm.com 13 Deborah Skucas 14 With cc to: Jose A. Gonzalez JoseA.Gonzalez@dot.ca.gov 15 CALIFORNIA DEPT OF TRANSPORTATION – LEGAL DIVISION maria.cordonero@dot.ca.gov 16 Attorney for Defendant, 17 State of California 18 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on April 11, 2022, at Fremont, California. 19 20 _________________________________ 21 ROSALIE NGUYEN, Declarant 22 23 24 25 26 27 1 ______________________________________________________________________________________________________________________ PROOF OF ELECTRONIC SERVICE