On September 01, 2020 a
Hearing
was filed
involving a dispute between
281 Ellis Street Llc,
Watchful, Inc.,
and
Does 1 To 10,
Watchful Inc.,
Watchful, Inc.,
for CONTRACT/WARRANTY
in the District Court of San Francisco County.
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1 MARCO QUAZZO (SBN 142182)
mquazzo@bzbm.com
2 KIMIKO L. AKIYA (SBN 311991) ELECTRONICALLY
kakiya@bzbm.com
3 BARTKO ZANKEL BUNZEL & MILLER F I L E D
A Professional Law Corporation Superior Court of California,
County of San Francisco
4 One Embarcadero Center, Suite 800
San Francisco, California 94111 01/29/2021
Clerk of the Court
5 Telephone: (415) 956-1900 BY: JEFFREY LEE
Facsimile: (415) 956-1152 Deputy Clerk
6
Attorneys for Plaintiff and Cross-Defendant
7 281 ELLIS STREET, LLC
8
9 SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 COUNTY OF SAN FRANCISCO
11
12 281 ELLIS STREET, LLC, a California Case No. CGC-20-586340
Limited Liability Company,
13 PLAINTIFF’S OBJECTION TO
Plaintiff, NOTICE OF TRIAL DATE
14
v.
15 Hearing Date: February 3, 2021
WATCHFUL, INC., a Delaware corporation; Time: 10:30 a.m.
16 and DOES 1 to 10, Dept.: 610
17 Defendants. Action Filed: September 1, 2020
18 WATCHFUL, INC., a Delaware corporation,
19 Cross-Complainant,
20 v.
21 281 ELLIS STREET, LLC, a California
Limited Liability Company; and ROES 1 to
22 20,
23 Cross-Defendants.
24
25
26
27
28
2828.000/1590204.1 CGC-20-586340
OBJECTION TO NOTICE OF TRIAL DATE
1 Plaintiff and Cross-Defendant 281 Ellis Street, LLC (“Plaintiff”) hereby objects to the
2 setting of this action for trial on August 30, 2021, and the Court’s Notice of Time and Place of
3 Trial and Trial Order issued on January 20, 2021. Plaintiff’s counsel is scheduled to be in trial on
4 another matter in San Francisco Superior Court during the last two weeks of August. Plaintiff
5 requests the Court set this action to commence trial on a date between September 13 and
6 October 5, 2021. Plaintiff’s counsel has conferred with defense counsel and understands that a
7 trial date of October 5, 2021 is acceptable to both parties.
8 Plaintiff’s counsel will appear at the objection hearing scheduled for February 3, 2021.
9
10 DATED: January 29, 2021 BARTKO ZANKEL BUNZEL & MILLER
A Professional Law Corporation
11
12
13 By: /s/ Marco Quazzo
Marco Quazzo
14 Attorneys for Plaintiff and Cross-Defendant
281 ELLIS STREET, LLC
15
16
17
18
19
20
21
22
23
24
25
26
27
28
2828.000/1590204.1 2 CGC-20-586340
OBJECTION TO NOTICE OF TRIAL DATE
1 PROOF OF SERVICE
2 281 Ellis Street, LLC v. Watchful, Inc. and Related Cross-Action
Case No. CGC-20-586340
3
At the time of service, I was over 18 years of age and not a party to this action. My
4 business address is One Embarcadero Center, Suite 800, San Francisco, CA 94111.
5 On January 29, 2021, I served a true copy of the following document(s) described as
PLAINTIFF'S OBJECTION TO NOTICE OF TRIAL DATE on the interested parties in this
6 action as follows:
7 Matthew J. Gluck, Esq.
litigation@gluckdaniel.com
8 GLUCK DANIEL LLP
One Sansome Street, Suite 720
9 San Francisco, CA 94104
Tel: (415) 510-2114
10
Attorneys for Defendant and
11 Cross-Complainant WATCHFUL, INC.
12 BY ELECTRONIC SERVICE: I electronically served the document(s) described above
via File & ServeXpress, on the recipients designated on the Transaction Receipt located on the
13 File & ServeXpress website (https://secure.fileandservexpress.com) pursuant to the Court Order
establishing the case website and authorizing service of documents.
14
I declare under penalty of perjury under the laws of the State of California that the
15 foregoing is true and correct.
16 Executed on January 29, 2021, at Martinez, California.
17
18
19 Barbara Sage
20
21
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28
2828.000/1590204.1 3 CGC-20-586340
OBJECTION TO NOTICE OF TRIAL DATE
Document Filed Date
January 29, 2021
Case Filing Date
September 01, 2020
Category
CONTRACT/WARRANTY
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1 MARCO QUAZZO (SBN 142182) mquazzo@bzbm.com 2 KIMIKO L. AKIYA (SBN 311991) ELECTRONICALLY kakiya@bzbm.com 3 BARTKO ZANKEL BUNZEL & MILLER F I L E D A Professional Law Corporation Superior Court of California, County of San Francisco 4 One Embarcadero Center, Suite 800 San Francisco, California 94111 01/29/2021 Clerk of the Court 5 Telephone: (415) 956-1900 BY: JEFFREY LEE Facsimile: (415) 956-1152 Deputy Clerk 6 Attorneys for Plaintiff and Cross-Defendant 7 281 ELLIS STREET, LLC 8 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF SAN FRANCISCO 11 12 281 ELLIS STREET, LLC, a California Case No. CGC-20-586340 Limited Liability Company, 13 PLAINTIFF’S OBJECTION TO Plaintiff, NOTICE OF TRIAL DATE 14 v. 15 Hearing Date: February 3, 2021 WATCHFUL, INC., a Delaware corporation; Time: 10:30 a.m. 16 and DOES 1 to 10, Dept.: 610 17 Defendants. Action Filed: September 1, 2020 18 WATCHFUL, INC., a Delaware corporation, 19 Cross-Complainant, 20 v. 21 281 ELLIS STREET, LLC, a California Limited Liability Company; and ROES 1 to 22 20, 23 Cross-Defendants. 24 25 26 27 28 2828.000/1590204.1 CGC-20-586340 OBJECTION TO NOTICE OF TRIAL DATE 1 Plaintiff and Cross-Defendant 281 Ellis Street, LLC (“Plaintiff”) hereby objects to the 2 setting of this action for trial on August 30, 2021, and the Court’s Notice of Time and Place of 3 Trial and Trial Order issued on January 20, 2021. Plaintiff’s counsel is scheduled to be in trial on 4 another matter in San Francisco Superior Court during the last two weeks of August. Plaintiff 5 requests the Court set this action to commence trial on a date between September 13 and 6 October 5, 2021. Plaintiff’s counsel has conferred with defense counsel and understands that a 7 trial date of October 5, 2021 is acceptable to both parties. 8 Plaintiff’s counsel will appear at the objection hearing scheduled for February 3, 2021. 9 10 DATED: January 29, 2021 BARTKO ZANKEL BUNZEL & MILLER A Professional Law Corporation 11 12 13 By: /s/ Marco Quazzo Marco Quazzo 14 Attorneys for Plaintiff and Cross-Defendant 281 ELLIS STREET, LLC 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2828.000/1590204.1 2 CGC-20-586340 OBJECTION TO NOTICE OF TRIAL DATE 1 PROOF OF SERVICE 2 281 Ellis Street, LLC v. Watchful, Inc. and Related Cross-Action Case No. CGC-20-586340 3 At the time of service, I was over 18 years of age and not a party to this action. My 4 business address is One Embarcadero Center, Suite 800, San Francisco, CA 94111. 5 On January 29, 2021, I served a true copy of the following document(s) described as PLAINTIFF'S OBJECTION TO NOTICE OF TRIAL DATE on the interested parties in this 6 action as follows: 7 Matthew J. Gluck, Esq. litigation@gluckdaniel.com 8 GLUCK DANIEL LLP One Sansome Street, Suite 720 9 San Francisco, CA 94104 Tel: (415) 510-2114 10 Attorneys for Defendant and 11 Cross-Complainant WATCHFUL, INC. 12 BY ELECTRONIC SERVICE: I electronically served the document(s) described above via File & ServeXpress, on the recipients designated on the Transaction Receipt located on the 13 File & ServeXpress website (https://secure.fileandservexpress.com) pursuant to the Court Order establishing the case website and authorizing service of documents. 14 I declare under penalty of perjury under the laws of the State of California that the 15 foregoing is true and correct. 16 Executed on January 29, 2021, at Martinez, California. 17 18 19 Barbara Sage 20 21 22 23 24 25 26 27 28 2828.000/1590204.1 3 CGC-20-586340 OBJECTION TO NOTICE OF TRIAL DATE