On May 26, 2020 a
Motion-Secondary
was filed
involving a dispute between
Doordash, Inc.,
and
901 Market St Sf Llc,
Knotel, Inc.,
for civil
in the District Court of San Francisco County.
Preview
1 Lily A. North (CA 260709)
Whitney (Carlson) Johnson (CA 308024)
2 Benesch, Friedlander, Coplan & Aronoff LLP ELECTRONICALLY
One Montgomery, Suite 2700
3 San Francisco, CA 94104-4505 F I L E D
Superior Court of California,
Telephone: 628-600-2250 County of San Francisco
4 Email: lnorth@beneschlaw.com
wjohnson@beneschlaw.com 11/20/2020
Clerk of the Court
5 BY: SANDRA SCHIRO
J. Erik Connolly (IL 6269558) (admitted pro hac vice) Deputy Clerk
6 Kate Watson Moss (IL 6321176) (admitted pro hac vice)
Madhavi Seth (IL 6330420) (admitted pro hac vice)
7 Benesch, Friedlander, Coplan & Aronoff LLP
71 South Wacker Drive, Suite 1600
8 Chicago, IL 60606
Telephone: 312-212-4949
9 Email: econnolly@beneschlaw.com
kmoss@beneschlaw.com
10 mseth@beneschlaw.com
11
Attorneys for Plaintiff DoorDash, Inc.
12
SUPERIOR COURT OF THE STATE OF CALIFORNIA
13
COUNTY OF SAN FRANCISCO
14
DOORDASH, INC., Case No. CGC-20-584606
15
Plaintiff, DECLARATION OF LILY A. NORTH IN
16 SUPPORT OF PLAINTIFF DOORDASH,
v. INC.’S MOTION TO COMPEL FURTHER
17 RESPONSES TO DISCOVERY
901 MARKET ST SF LLC and KNOTEL,
18 INC., Action Filed: May 26, 2020
Trial Date: May 3, 2021
19 Defendants.
DISCOVERY
20
21 DATE: Tuesday, December 16, 2020
TIME: 9:00 a.m.
22 DEPT: 302
Judge: Hon. Ethan P. Schulman
23
24
25
26
27
28
1
DECLARATION OF LILY A. NORTH IN SUPPORT OF PLAINTIFF DOORDASH, INC.’S MOTION TO
COMPEL FURTHER RESPONSES TO DISCOVERY
Case No. CGC-20-584606
1 I, Lily A. North, declare as follows:
2 1. I am an attorney at law, duly admitted to practice in the State of California and before this
3 Court. I am an attorney with the law firm of Benesch, Friedlander, Coplan & Aronoff LLP, in San
4 Francisco, California, and counsel for Plaintiff DoorDash, Inc. (“DoorDash”) in this action. I make this
5 declaration based on my own personal knowledge and my representation of DoorDash in this action. If
6 called as a witness, I could testify competently to the facts set forth in this Declaration.
7 2. On November 2, 2020, I attended a telephonic meet and confer with Scott Klein, Alex
8 Otchy, Matthew Glucker, and Justin Sowa, counsel for Defendants 901 Market ST SF LLC and Knotel,
9 Inc. (collectively, “Defendants”) to discuss their responses to DoorDash’s discovery requests.
10 3. Regarding Defendants’ Responses to Form Interrogatory No. 15.1, counsel for Defendants
11 stated that they would review and consider further supplementing Defendants’ response in light of
12 DoorDash’s position that the current response provided few facts in support of Defendants’ affirmative
13 defenses.
14 4. Regarding Defendants’ Responses to Form Interrogatory No. 17.1, counsel for Defendants
15 stated that the terms they found objectionable were unclear and undefined and that they therefore were
16 not going to supplement their response as the Interrogatory was written. Counsel for DoorDash offered to
17 clarify any terms that counsel for Defendants found unclear. However, counsel for Defendants declined
18 to engage in such a discussion.
19 I declare under penalty of perjury under the laws of the State of California that the foregoing is
20 true and correct.
21
22 Dated: November 20, 2020
Lily A. North
23
24
25
26
27
28
2
DECLARATION OF LILY A. NORTH IN SUPPORT OF PLAINTIFF DOORDASH, INC.’S MOTION TO
COMPEL FURTHER RESPONSES TO DISCOVERY
Case No. CGC-20-584606
Document Filed Date
November 20, 2020
Case Filing Date
May 26, 2020
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
1 Lily A. North (CA 260709) Whitney (Carlson) Johnson (CA 308024) 2 Benesch, Friedlander, Coplan & Aronoff LLP ELECTRONICALLY One Montgomery, Suite 2700 3 San Francisco, CA 94104-4505 F I L E D Superior Court of California, Telephone: 628-600-2250 County of San Francisco 4 Email: lnorth@beneschlaw.com wjohnson@beneschlaw.com 11/20/2020 Clerk of the Court 5 BY: SANDRA SCHIRO J. Erik Connolly (IL 6269558) (admitted pro hac vice) Deputy Clerk 6 Kate Watson Moss (IL 6321176) (admitted pro hac vice) Madhavi Seth (IL 6330420) (admitted pro hac vice) 7 Benesch, Friedlander, Coplan & Aronoff LLP 71 South Wacker Drive, Suite 1600 8 Chicago, IL 60606 Telephone: 312-212-4949 9 Email: econnolly@beneschlaw.com kmoss@beneschlaw.com 10 mseth@beneschlaw.com 11 Attorneys for Plaintiff DoorDash, Inc. 12 SUPERIOR COURT OF THE STATE OF CALIFORNIA 13 COUNTY OF SAN FRANCISCO 14 DOORDASH, INC., Case No. CGC-20-584606 15 Plaintiff, DECLARATION OF LILY A. NORTH IN 16 SUPPORT OF PLAINTIFF DOORDASH, v. INC.’S MOTION TO COMPEL FURTHER 17 RESPONSES TO DISCOVERY 901 MARKET ST SF LLC and KNOTEL, 18 INC., Action Filed: May 26, 2020 Trial Date: May 3, 2021 19 Defendants. DISCOVERY 20 21 DATE: Tuesday, December 16, 2020 TIME: 9:00 a.m. 22 DEPT: 302 Judge: Hon. Ethan P. Schulman 23 24 25 26 27 28 1 DECLARATION OF LILY A. NORTH IN SUPPORT OF PLAINTIFF DOORDASH, INC.’S MOTION TO COMPEL FURTHER RESPONSES TO DISCOVERY Case No. CGC-20-584606 1 I, Lily A. North, declare as follows: 2 1. I am an attorney at law, duly admitted to practice in the State of California and before this 3 Court. I am an attorney with the law firm of Benesch, Friedlander, Coplan & Aronoff LLP, in San 4 Francisco, California, and counsel for Plaintiff DoorDash, Inc. (“DoorDash”) in this action. I make this 5 declaration based on my own personal knowledge and my representation of DoorDash in this action. If 6 called as a witness, I could testify competently to the facts set forth in this Declaration. 7 2. On November 2, 2020, I attended a telephonic meet and confer with Scott Klein, Alex 8 Otchy, Matthew Glucker, and Justin Sowa, counsel for Defendants 901 Market ST SF LLC and Knotel, 9 Inc. (collectively, “Defendants”) to discuss their responses to DoorDash’s discovery requests. 10 3. Regarding Defendants’ Responses to Form Interrogatory No. 15.1, counsel for Defendants 11 stated that they would review and consider further supplementing Defendants’ response in light of 12 DoorDash’s position that the current response provided few facts in support of Defendants’ affirmative 13 defenses. 14 4. Regarding Defendants’ Responses to Form Interrogatory No. 17.1, counsel for Defendants 15 stated that the terms they found objectionable were unclear and undefined and that they therefore were 16 not going to supplement their response as the Interrogatory was written. Counsel for DoorDash offered to 17 clarify any terms that counsel for Defendants found unclear. However, counsel for Defendants declined 18 to engage in such a discussion. 19 I declare under penalty of perjury under the laws of the State of California that the foregoing is 20 true and correct. 21 22 Dated: November 20, 2020 Lily A. North 23 24 25 26 27 28 2 DECLARATION OF LILY A. NORTH IN SUPPORT OF PLAINTIFF DOORDASH, INC.’S MOTION TO COMPEL FURTHER RESPONSES TO DISCOVERY Case No. CGC-20-584606