On July 30, 2019 a
Hearing
was filed
involving a dispute between
Herrera, Margarita,
and
City And County Of San Francisco,
Does 1 Through 15,
for OTHER NON EXEMPT COMPLAINTS
in the District Court of San Francisco County.
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1 DENNIS J. HERRERA, State Bar #139669
City Attorney
2 ELECTRONICALLY
KATHARINE HOBIN PORTER, State Bar #173180
Chief Labor Attorney F I L E D
3 Superior Court of California,
ERIN KUKA, State Bar #275042 County of San Francisco
Deputy City Attorney
4 Fox Plaza 01/06/2020
1390 Market Street, 5th Floor Clerk of the Court
BY: KENNETH HUNT
5 San Francisco, California 94102-5408 Deputy Clerk
Telephone: (415) 554-4229
6 Facsimile: (415) 554-4248
E-Mail: erin.kuka@sfcityatty.org
7
8 Attorneys for Defendant
CITY AND COUNTY OF SAN FRANCISCO
9
10 SUPERIOR COURT OF THE STATE OF CALIFORNIA
11 COUNTY OF SAN FRANCISCO
12 UNLIMITED JURISDICTION
13 MARGARITA HERRERA, Case No. CGC-19-578026
14 Plaintiff, DEFENDANT CITY AND COUNTY OF SAN
FRANCISCO’S NOTICE OF OBJECTION TO
15 vs. TRIAL DATE
16 CITY AND COUNTY OF SAN Hearing Date: January 8, 2020
FRANCISCO, Hearing Judge: Hon. Garrett L. Wong
17 Time: 10:30 a.m.
Defendant. Place: Dept. 610
18
Date Action Filed: July 30, 2019
19 Trial Date: October 5, 2020
20 Attached: Stipulation to Reset Trial and Pretrial
Deadlines
21
22
23
24
25
26
27
28 1
DEFENDANT’S NOTICE OF OBJECTION TO TRIAL DATE n:\labor\li2019\200243\01417355.docx
Margarita Herrera v. City and County of San Francisco CASE NO. CGC-19-578026
1 On December 23, 2019, the Court issued the Notice of Time and Place of Trial for this matter,
2 setting the trial date for October 5, 2020. Defendant City and County of San Francisco ("the City")
3 respectfully objects to this trial date.
4 Due to the complexity of issues presented by this case, including the range of matters for which
5 expert discovery will be necessary, the City requires additional time to complete discovery, engage in
6 motion practice, and prepare for trial. Counsel for both parties have met and conferred. Counsel have
7 other matters scheduled for trial, but have reached a mutually agreeable new trial date of Monday,
8 January 25, 2021. A stipulation signed by both parties is filed herewith.
9 The City therefore requests that the trial date be reset to Monday, January 25, 2021.
10 Furthermore, the City requests all pretrial dates and deadlines be reset according to the new trial date.
11
12 Dated: January 6, 2020 DENNIS J. HERRERA
City Attorney
13 KATHARINE HOBIN PORTER
Chief Labor Attorney
14 ERIN KUKA
Deputy City
15
16
17
18 . Attorneys for Defendant
CITY AND COUNTY OF SAN FRANCISCO
19
20
21
22
23
24
25
26
27
28
2
DEFENDANT'S NOTICE OF OBJECTION TO TRIAL DATE n:\labor\li2019\200243\01417355.docx
Margarita Herrera v. City and County of San Francisco CASE NO. CGC-19-578026
Document Filed Date
January 06, 2020
Case Filing Date
July 30, 2019
Category
OTHER NON EXEMPT COMPLAINTS
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1 DENNIS J. HERRERA, State Bar #139669 City Attorney 2 ELECTRONICALLY KATHARINE HOBIN PORTER, State Bar #173180 Chief Labor Attorney F I L E D 3 Superior Court of California, ERIN KUKA, State Bar #275042 County of San Francisco Deputy City Attorney 4 Fox Plaza 01/06/2020 1390 Market Street, 5th Floor Clerk of the Court BY: KENNETH HUNT 5 San Francisco, California 94102-5408 Deputy Clerk Telephone: (415) 554-4229 6 Facsimile: (415) 554-4248 E-Mail: erin.kuka@sfcityatty.org 7 8 Attorneys for Defendant CITY AND COUNTY OF SAN FRANCISCO 9 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA 11 COUNTY OF SAN FRANCISCO 12 UNLIMITED JURISDICTION 13 MARGARITA HERRERA, Case No. CGC-19-578026 14 Plaintiff, DEFENDANT CITY AND COUNTY OF SAN FRANCISCO’S NOTICE OF OBJECTION TO 15 vs. TRIAL DATE 16 CITY AND COUNTY OF SAN Hearing Date: January 8, 2020 FRANCISCO, Hearing Judge: Hon. Garrett L. Wong 17 Time: 10:30 a.m. Defendant. Place: Dept. 610 18 Date Action Filed: July 30, 2019 19 Trial Date: October 5, 2020 20 Attached: Stipulation to Reset Trial and Pretrial Deadlines 21 22 23 24 25 26 27 28 1 DEFENDANT’S NOTICE OF OBJECTION TO TRIAL DATE n:\labor\li2019\200243\01417355.docx Margarita Herrera v. City and County of San Francisco CASE NO. CGC-19-578026 1 On December 23, 2019, the Court issued the Notice of Time and Place of Trial for this matter, 2 setting the trial date for October 5, 2020. Defendant City and County of San Francisco ("the City") 3 respectfully objects to this trial date. 4 Due to the complexity of issues presented by this case, including the range of matters for which 5 expert discovery will be necessary, the City requires additional time to complete discovery, engage in 6 motion practice, and prepare for trial. Counsel for both parties have met and conferred. Counsel have 7 other matters scheduled for trial, but have reached a mutually agreeable new trial date of Monday, 8 January 25, 2021. A stipulation signed by both parties is filed herewith. 9 The City therefore requests that the trial date be reset to Monday, January 25, 2021. 10 Furthermore, the City requests all pretrial dates and deadlines be reset according to the new trial date. 11 12 Dated: January 6, 2020 DENNIS J. HERRERA City Attorney 13 KATHARINE HOBIN PORTER Chief Labor Attorney 14 ERIN KUKA Deputy City 15 16 17 18 . Attorneys for Defendant CITY AND COUNTY OF SAN FRANCISCO 19 20 21 22 23 24 25 26 27 28 2 DEFENDANT'S NOTICE OF OBJECTION TO TRIAL DATE n:\labor\li2019\200243\01417355.docx Margarita Herrera v. City and County of San Francisco CASE NO. CGC-19-578026