arrow left
arrow right
  • CHOI NGOR LI VS. CITY AND COUNTY OF SAN FRANCISCO ET AL PERSONAL INJURY/PROPERTY DAMAGE - NON-VEHICLE RELATED document preview
  • CHOI NGOR LI VS. CITY AND COUNTY OF SAN FRANCISCO ET AL PERSONAL INJURY/PROPERTY DAMAGE - NON-VEHICLE RELATED document preview
  • CHOI NGOR LI VS. CITY AND COUNTY OF SAN FRANCISCO ET AL PERSONAL INJURY/PROPERTY DAMAGE - NON-VEHICLE RELATED document preview
  • CHOI NGOR LI VS. CITY AND COUNTY OF SAN FRANCISCO ET AL PERSONAL INJURY/PROPERTY DAMAGE - NON-VEHICLE RELATED document preview
  • CHOI NGOR LI VS. CITY AND COUNTY OF SAN FRANCISCO ET AL PERSONAL INJURY/PROPERTY DAMAGE - NON-VEHICLE RELATED document preview
  • CHOI NGOR LI VS. CITY AND COUNTY OF SAN FRANCISCO ET AL PERSONAL INJURY/PROPERTY DAMAGE - NON-VEHICLE RELATED document preview
  • CHOI NGOR LI VS. CITY AND COUNTY OF SAN FRANCISCO ET AL PERSONAL INJURY/PROPERTY DAMAGE - NON-VEHICLE RELATED document preview
  • CHOI NGOR LI VS. CITY AND COUNTY OF SAN FRANCISCO ET AL PERSONAL INJURY/PROPERTY DAMAGE - NON-VEHICLE RELATED document preview
						
                                

Preview

1 LITTLETON PARK JOYCE UGHETTA & KELLY LLP Keith A. Sipprelle, Of Counsel (State Bar No. 143358) 2 2945 Townsgate Road, Suite 200 ELECTRONICALLY Westlake Village, CA 91361 F I L E D 3 Telephone: (213) 599-8200 Superior Court of California, County of San Francisco 4 Facsimile: (213) 228-1980 keith.sipprelle@littletonpark.com 08/14/2019 Clerk of the Court 5 BY: VANESSA WU Attorneys for Defendant/Cross-Complainant SIEMENS INDUSTRY, INC. Deputy Clerk 6 (erroneously named and served as “Siemens Corporation”) 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF SAN FRANCISCO 10 11 CHOI NGOR LI, CASE NO.: CGC-19-576285 12 Plaintiff, DEFENDANT/CROSS-COMPLAINANT SIEMENS INDUSTRY, INC.’S NOTICE 13 vs. OF APPLICATION AND APPLICATION FOR ADMISSION OF KRISTEN 14 CITY AND COUNTY OF SAN DENNISON TO THE BAR OF THIS 15 FRANCISCO, SIEMENS CORPORATION, COURT PRO HAC VICE; and DOES ONE through ONE-HUNDRED, MEMORANDUM OF POINTS AND 16 AUTHORITIES IN SUPPORT THEREOF Defendants. 17 [Concurrently filed with: (a) Verified 18 Application for Admission of Kristen Dennison to the Bar of this Court Pro Hac 19 Vice; (b) Declaration of Keith A. Sipprelle in Support; (c) [Proposed] Order] 20 21 Date: September 10, 2019 22 Time: 9:30 a.m. Dept: 302 23 RESERVATION NO.: 08090910-01 24 25 Complaint Filed: May 28, 2019 26 Trial Date: None 27 AND RELATED CROSS-ACTION. 28 1 SIEMENS INDUSTRY, INC.’S NOTICE OF APPLICATION AND APPLICATION FOR ADMISSION OF KRISTEN DENNISON TO THE BAR OF THIS COURT PRO HAC VICE 1 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD, AND TO THE STATE 2 BAR OF CALIFORNIA: 3 PLEASE TAKE NOTICE that on September 10, 2019, at 9:30 a.m. or as soon thereafter as 4 the matter may be heard, in Department 302 of the above-entitled Court, located at 400 McAllister 5 Street, San Francisco California 94102, Keith A. Sipprelle, a member in good standing of the State 6 Bar of California, will present the verified application of Kristen Dennison to appear as counsel 7 pro hac vice on behalf of Defendant/Cross-Complainant Siemens Industry, Inc. (hereinafter 8 “Siemens”) in this action. Mr. Sipprelle and Siemens will and hereby do respectfully apply for an 9 Order authorizing Kristen Dennison to appear as counsel pro hac vice for Siemens in this matter. 10 This Application will be based upon this Notice of Application and Application, the 11 attached Memorandum of Points and Authorities, the Verified Application of Kristen Dennison 12 filed concurrently herewith, the supporting Declaration of Keith A. Sipprelle filed concurrently 13 herewith, all of papers and records on file with the Court in this action, on such matters as the 14 Court may judicially notice, and upon such other and further matters as the Court may consider in 15 connection with this Application. 16 DATED: August 13, 2019 Respectfully Submitted, 17 LITTLETON PARK JOYCE UGHETTA 18 & KELLY LLP 19 20 By: 21 Keith A. Sipprelle, Of Counsel Attorneys for Defendant/Cross-Complainant 22 SIEMENS INDUSTRY, INC. (erroneously named and served as “Siemens 23 Corporation”) 24 25 26 27 28 2 SIEMENS INDUSTRY, INC.’S NOTICE OF APPLICATION AND APPLICATION FOR ADMISSION OF KRISTEN DENNISON TO THE BAR OF THIS COURT PRO HAC VICE 1 MEMORANDUM OF POINTS AND AUTHORITIES 2 I. INTRODUCTION. 3 Plaintiff’s Complaint in this action asserts that Plaintiff Choi Ngor Li (“Plaintiff”) attempted 4 to board a San Francisco Municipal Transportation Agency train at the MUNI Metro Embarcadero 5 Station on April 12, 2019. Plaintiff’s Complaint alleges that “the train door suddenly and 6 unexpectedly closed on her hand, causing her to become trapped within the door,” causing her to 7 8 sustain personal injuries. Plaintiff brings claims for (1) Negligence; (2) Dangerous Condition of 9 Public Property; (3) Strict Liability – Manufacturing Defect; (4) Strict Liability – Design Defect; 10 and (5) Failure to Warn. 11 Siemens has retained attorney Kristen E. Dennison of Littleton Park Joyce Ughetta & Kelly 12 LLP to represent its interest in this case. Siemens respectfully requests that Ms. Dennison be granted 13 admission pro hac vice in order to assist Siemens in the defense of this action. If admitted pro hac 14 15 vice, Ms. Dennison will be associated and work closely with attorney Keith A. Sipprelle, a member 16 in good standing of the California Bar since 1989. (See verified application of Kristen E. Dennison 17 and Declaration of Keith A. Sipprelle submitted concurrently herewith.). 18 II. CALIFORNIA RULE OF COURT 9.40 AUTHORIZES THIS COURT TO 19 EXERCISE ITS DISCRETION TO PERMIT PRO HAC VICE ADMISSION. 20 In pertinent part, Rule 9.40(a) of the California Rules of Court states that: 21 A person who is not a member of the State Bar of California 22 but who is a member in good standing of and eligible to 23 practice before the bar of any United States court ..., and who has been retained to appear in a particular case 24 pending in a court of this state, may in the discretion of such court be permitted upon written application to appear as 25 counsel pro hac vice, provided that an active member of the State Bar of California is associated as attorney of record. 26 27 In turn, subparts (c) – (d) of Rule 9.40 sets forth the requirements that must be met by such 28 out-of-state counsel when making the application: 3 SIEMENS INDUSTRY, INC.’S NOTICE OF APPLICATION AND APPLICATION FOR ADMISSION OF KRISTEN DENNISON TO THE BAR OF THIS COURT PRO HAC VICE 1 A person desiring to appear as counsel pro hac vice in a 2 superior court must file with the court a verified application together with proof of service . . . of a copy of the 3 application and of the notice of hearing of the application on 4 all parties who have appeared in the cause and on the State Bar of California at its San Francisco office. The notice of 5 hearing must be given at the time prescribed in Code of Civil Procedure section 1005 . . .. 6 The application must state: (1) The applicant’s residence and 7 office address; (2) The courts to which the applicant has 8 been admitted to practice and the dates of admission; 9 (3) That the applicant is a member in good standing in those courts; (4) That the applicant is not currently suspended or 10 disbarred in any court; (5) The title of court and cause in 11 which the applicant has filed an application to appear as counsel pro hac vice in this state in the preceding two years, 12 the date of each application, and whether or not it was granted; and (6) The name, address, and telephone number 13 of the active member of the State Bar of California who is attorney of record. 14 15 The moving papers herein satisfy all of the requirements of Rule 9.40, and no sound reason 16 exists to refuse Kristen E. Dennison’s application. (See Verified Application of Kristen E. 17 Dennison and supporting Declaration of Keith A. Sipprelle filed concurrently herewith.) 18 III. CONCLUSION 19 Siemens respectfully requests that this Application be granted, and that Kristen E. 20 Dennison be granted permission to appear as counsel pro hac vice on behalf of Siemens for all 21 // 22 23 // 24 // 25 // 26 // 27 28 4 SIEMENS INDUSTRY, INC.’S NOTICE OF APPLICATION AND APPLICATION FOR ADMISSION OF KRISTEN DENNISON TO THE BAR OF THIS COURT PRO HAC VICE 1 purposes in this matter. 2 DATED: August 13, 2019 Respectfully Submitted, 3 LITTLETON PARK JOYCE UGHETTA & KELLY 4 LLP 5 6 By: Keith A. Sipprelle, Of Counsel 7 Attorneys for Defendant/Cross-Complainant 8 SIEMENS INDUSTRY, INC. (erroneously named and served as “Siemens 9 Corporation”) 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 5 SIEMENS INDUSTRY, INC.’S NOTICE OF APPLICATION AND APPLICATION FOR ADMISSION OF KRISTEN DENNISON TO THE BAR OF THIS COURT PRO HAC VICE 1 SERVICE LIST 2 Richard H. Schoenberger, Esq. Attys. for Plaintiff Choi Ngor Li 3 Matthew D. Davis, Esq. 4 Jeffrey A. Clause, Esq. Walkup, Melodia, Kelly & Schoenberger 5 650 California Street, 26th Floor San Francisco, CA 94108-2615 6 Phone: (415) 981-7210 Fax: (415) 391-6965 7 rschoenberger@walkuplawoffice.com 8 mdavis@walkuplawoffice.com jclause@walkuplawoffice.com 9 10 Karen E. Kirby, Esq. Attys. for Def. City/Cty. of San Francisco David A. Delbon, Esq. 11 Office of the San Francisco City Attorney 12 Fox Plaza 1390 Market Street, 6th Floor 13 San Francisco, CA 94102 Phone: 415-554-3891 (main) 14 Phone (Direct): (415) 554-3891 (Kirby) 15 Phone (Direct): (415) 554-3962 (Delbon) Fax: (415) 554-3837 16 karen.kirby@sfcityatty.org david.delbon@sfcityatty.org 17 18 Elise M. Balgley, Esq. Attys. for X-Ds Ultimate Transport./Ultimate Rail 19 Bernard, Balgley & Bonaccorsi, LLP 3900 NewPark Mall Road, Third Floor 20 Newark, California 94560-5242 Tel.: (510) 791-1888 21 Fax:(510) 791-8008 22 ebalgley@3blawfirm.com 23 State Bar of California 24 180 Howard St. San Francisco, CA 94105 25 26 27 28 7 SIEMENS INDUSTRY, INC.’S NOTICE OF APPLICATION AND APPLICATION FOR ADMISSION OF KRISTEN DENNISON TO THE BAR OF THIS COURT PRO HAC VICE