On March 14, 2019 a
Motion-Secondary
was filed
involving a dispute between
Quant,,
Quant, Armando,
and
Colliers International Real Estate Management,
Does 1 To 100,
for WRONGFUL DISCHARGE
in the District Court of San Francisco County.
Preview
1 Mitchell F. Boomer (State Bar No. 121441)
Janelle J. Sahouria (State Bar No. 253699)
2 Julie Y. Zong (State Bar No. 309804)
JACKSON LEWIS P.C. ELECTRONICALLY
3 50 California Street, 9th Floor
San Francisco, CA 94111 F I L E D
Superior Court of California,
4 Telephone: (415) 394-9400 County of San Francisco
Facsimile: (415) 394-9401
5 Mitchell.Boomer@jacksonlewis.com 12/19/2019
Clerk of the Court
Janelle.Sahouria@jacksonlewis.com BY: DAVID YUEN
6 Deputy Clerk
Attorneys for Defendant
7 COLLIERS INTERNATIONAL REAL ESTATE
MANAGEMENT SERVICES (CA), INC.
8
9 SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 COUNTY OF SAN FRANCISCO
11 ARMANDO QUANT, an individual, Case No. CGC-19-574527
12 Plaintiff, DECLARATION OF JULIE Y. ZONG IN
SUPPORT OF DEFENDANT’S
13 v. OPPOSITION TO PLAINTIFF’S
MOTION TO REINSTATE A JURY
14 COLLIERS INTERNATIONAL REAL TRIAL
ESTATE MANAGEMENT SERVICES
15 (CA), INC.; and DOES 1-100, inclusive, Judge: Hon. Ethan P. Schulman
Date: January 6, 2020
16 Defendants. Time: 9 a.m.
Dept. 302
17 Res. No.: 011210106-11
18 Complaint Filed: March 14, 2019
Trial Date: June 15, 2020
19
20 I, Julie Y. Zong, declare as follows:
21 1. I am an attorney licensed to practice law in the State of California and admitted to
22 appear before this Court. I am an associate with the law firm of Jackson Lewis P.C., attorneys of
23 record in this matter for Defendant Colliers International Real Estate Management Services (CA),
24 Inc. (“Colliers”). I have personal knowledge of the matters stated herein, and if called to testify
25 as to these matters, I could and would do so competently.
26 2. On March 14, 2019, Plaintiff filed a lawsuit arising out of the termination of his
27 employment with Colliers in San Francisco Superior Court.
28 ///
1 Case No. CGC-19-574527
DECLARATION OF ZONG IN SUPPORT OF DEFENDANT’S
OPPOSITION TO PLAINTIFF’S MOTION TO REINSTATE A JURY TRIAL
1 3. On the same day, the Court set a case management conference on August 14,
2 2019. Attached hereto as Exhibit A is a Notice to Plaintiff setting the case management
3 conference for August 14, 2019.
4 4. On April 17, 2019, Defendant timely filed an Answer to Plaintiffs Complaint.
5 5. On May 16, 2019, Plaintiffs Counsel Angela Alioto, of the Law Offices of Joseph
6 Alioto and Angela Alioto, withdrew as counsel. Attached hereto as Exhibit B is the Substitution
7 of Attorney of Angela Alioto.
8 6. Plaintiff failed to timely file a case management conference statement and post his
9 jury fees or seek relief.
10 7. On August 1, 2019, the Court vacated the initial case management conference and
11 set a trial date for April 13, 2020. Attached hereto as Exhibit C is the Court's Notice of Time
12 and Place of Trial vacating the initial case management conference and setting a trial date for
13 April 13, 2020.
14 8. On August 20, 2019, Daniel Feder, of the Law Offices of Daniel L. Feder, filed a
15 Substitution of Attorney. Attached hereto as Exhibit D is the Substitution of Attorney of Daniel
16 L. Feder of the Law Offices of Daniel L. Feder.
17 9. Defendant has already expended resources in defending the case.
18 I declare under penalty of perjury under the laws of the United States and the State of
19 California that the foregoing is true and correct. Executed this 19th day of December, 2019, in
20 San Francisco, California.
21
22
Julie Y. Zo
23
24
25
26
27
28
2 Case No. CGC- 19-574527
DECLARATION OF ZONG IN SUPPORT OF DEFENDANT'S
OPPOSITION TO PLAINTIFF'S MOTION TO REINSTATE A JURY TRIAL
Document Filed Date
December 19, 2019
Case Filing Date
March 14, 2019
Category
WRONGFUL DISCHARGE
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1 Mitchell F. Boomer (State Bar No. 121441) Janelle J. Sahouria (State Bar No. 253699) 2 Julie Y. Zong (State Bar No. 309804) JACKSON LEWIS P.C. ELECTRONICALLY 3 50 California Street, 9th Floor San Francisco, CA 94111 F I L E D Superior Court of California, 4 Telephone: (415) 394-9400 County of San Francisco Facsimile: (415) 394-9401 5 Mitchell.Boomer@jacksonlewis.com 12/19/2019 Clerk of the Court Janelle.Sahouria@jacksonlewis.com BY: DAVID YUEN 6 Deputy Clerk Attorneys for Defendant 7 COLLIERS INTERNATIONAL REAL ESTATE MANAGEMENT SERVICES (CA), INC. 8 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF SAN FRANCISCO 11 ARMANDO QUANT, an individual, Case No. CGC-19-574527 12 Plaintiff, DECLARATION OF JULIE Y. ZONG IN SUPPORT OF DEFENDANT’S 13 v. OPPOSITION TO PLAINTIFF’S MOTION TO REINSTATE A JURY 14 COLLIERS INTERNATIONAL REAL TRIAL ESTATE MANAGEMENT SERVICES 15 (CA), INC.; and DOES 1-100, inclusive, Judge: Hon. Ethan P. Schulman Date: January 6, 2020 16 Defendants. Time: 9 a.m. Dept. 302 17 Res. No.: 011210106-11 18 Complaint Filed: March 14, 2019 Trial Date: June 15, 2020 19 20 I, Julie Y. Zong, declare as follows: 21 1. I am an attorney licensed to practice law in the State of California and admitted to 22 appear before this Court. I am an associate with the law firm of Jackson Lewis P.C., attorneys of 23 record in this matter for Defendant Colliers International Real Estate Management Services (CA), 24 Inc. (“Colliers”). I have personal knowledge of the matters stated herein, and if called to testify 25 as to these matters, I could and would do so competently. 26 2. On March 14, 2019, Plaintiff filed a lawsuit arising out of the termination of his 27 employment with Colliers in San Francisco Superior Court. 28 /// 1 Case No. CGC-19-574527 DECLARATION OF ZONG IN SUPPORT OF DEFENDANT’S OPPOSITION TO PLAINTIFF’S MOTION TO REINSTATE A JURY TRIAL 1 3. On the same day, the Court set a case management conference on August 14, 2 2019. Attached hereto as Exhibit A is a Notice to Plaintiff setting the case management 3 conference for August 14, 2019. 4 4. On April 17, 2019, Defendant timely filed an Answer to Plaintiffs Complaint. 5 5. On May 16, 2019, Plaintiffs Counsel Angela Alioto, of the Law Offices of Joseph 6 Alioto and Angela Alioto, withdrew as counsel. Attached hereto as Exhibit B is the Substitution 7 of Attorney of Angela Alioto. 8 6. Plaintiff failed to timely file a case management conference statement and post his 9 jury fees or seek relief. 10 7. On August 1, 2019, the Court vacated the initial case management conference and 11 set a trial date for April 13, 2020. Attached hereto as Exhibit C is the Court's Notice of Time 12 and Place of Trial vacating the initial case management conference and setting a trial date for 13 April 13, 2020. 14 8. On August 20, 2019, Daniel Feder, of the Law Offices of Daniel L. Feder, filed a 15 Substitution of Attorney. Attached hereto as Exhibit D is the Substitution of Attorney of Daniel 16 L. Feder of the Law Offices of Daniel L. Feder. 17 9. Defendant has already expended resources in defending the case. 18 I declare under penalty of perjury under the laws of the United States and the State of 19 California that the foregoing is true and correct. Executed this 19th day of December, 2019, in 20 San Francisco, California. 21 22 Julie Y. Zo 23 24 25 26 27 28 2 Case No. CGC- 19-574527 DECLARATION OF ZONG IN SUPPORT OF DEFENDANT'S OPPOSITION TO PLAINTIFF'S MOTION TO REINSTATE A JURY TRIAL