Preview
Christine Haw (SBN 289351)
e-mail: chaw@slpattorney.com
Gabriella Pedone (SBN 308384)
e-mail: gpedone@slpattorney.com
STRATEGIC LEGAL PRACTICES
A PROFESSIONAL LAW CORPORATION
1840 Century Park East, Suite 430
Los Angeles, CA 90067
Telephone: (310) 929-4900
Facsimile: (310) 943-3838
ELECTRONICALLY
FILED
Superior Court of California,
County of San Francisco
12/04/2018
Clerk of the Court
BY: VANESSA WU
Deputy Clerk
Attorneys for Plaintiff DAWN ANN MASON and JAMES MASON
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN FRANCISCO
DAWN ANN MASON and JAMES
MASON,
Plaintiff,
v.
FCA US, LLC, and DOES 1 through 10,
inclusive,
Defendants.
Case No.: CGC-18-564545
DISCOVERY
Hon. Harold Kahn
Dept. 302
PLAINTIFFS’ NOTICE OF
CONTINUANCE OF HEARING RE:
PLAINTIFFS’ MOTION TO COMPEL
FURTHER RESPONSES TO
PLAINTIFFS’ REQUEST FOR
PRODUCTION OF DOCUMENTS, SET
ONE
Date: December 27, 2018
Time: 9:00 am
Dept.: 301
PLAINTIFFS’ NOTICE OF CONTINUANCE OF HEARING RE: PLAINTIFFS’ MOTION TO COMPEL FURTHER
RESPONSES TO PLAINTIFFS’ REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONETO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that, per the Court’s December 3, 2018 tentative ruling, the
hearing on Plaintiffs DAWN ANN MASON and JASMES MASON’s (hereinafter “Plaintiffs”)
Motion to Compel Further Responses to Plaintiffs’ Requests for Production of Documents, Set
One, previously set for December 4, 2018, is continued to December 27, 2018 at 9:00 a.m. in
Department 301 of the above-captioned court, located at 400 McAllister Street, San Francisco,
California 94102.
Furthermore, Plaintiff has been ordered to provide courtesy copies of Plaintiffs’ moving
and reply papers, (with notice of such to counsel for Defendant) to Department 301 by no later
than December 12, 2018.
A copy of the Court’s ruling is attached hereto as Exhibit A.
Dated: December 4, 2018 Respectfully submitted,
Strategic Legal Practices, APC
6 OG_ D>
Gabriella Pedone
Attorney for Plaintiffs DAWN ANN MASON
and JAMES MASON
By:
1
PLAINTIFFS” NOTICE OF CONTINUANCE OF HEARING RE: PLAINTIFFS’ MOTION TO COMPEL FURTHER
RESPONSES TO PLAINTIFFS’ REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONEEXHIBIT AContact Us
THE SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Tentative Rulings
Law & Motion/Discovery Department 302
You can search by Case Number, Court Date or a combination of Court Date and Case Number.
CaseNumber, [oo |
And/Or
‘Court Date.
[seach
Total Records Found 5,
Case Number. (CGC15549626
Case Title REBECCA CHAMORRO ET AL VS. DIGNITY HEALTH ET Al,
Court Date DEC-04-2078 14:00 PM
Calendar Maiter: Notice Of Motion And Motion To Compel Further Deposition Of Person Most Qualified
Rulings. Maiter on calendar for Tuesday, December 4, 2018, Line 1, PETITIONERs REBECCA CHAMORRO and PHYSICIANS FOR REPRODUCTIVE HEALTH's Motion
‘Yo Compel Further Deposition Of Person Most Qualified. To be heard on 12/4/18 at 2:00 pm in the Law and Motion Dept. before Judge Kahn, =(302/JPT)
Gase Number G017587171
Case Title. VICTORIA SMITH VS. AMERICAN CONSERVATORY THEATER ET AL.
Court Date’ DEC-04-2018 09:00 AM
Calendar Matter: Notice Of Motion To Compel Further Responses To Form interrogatories -Employment Law And Request For Sanctions.
Rulings: Matter on calendar for Tuesday, December 4, 2018, Line 2, PLAINTIFF VICTORIA SMITH's Motion To Compel Further Responses To Form interrogatories
Employment Law And Request For Sanctions. CONTINUED to December 19, 2018 at 9:00 AM per agreement of the parties. =(302/JPT)
Case Number. cGC17558112
Case Title. ASHLEY RUST VS. SENDHUB, INC.
Court Date: DEC-04-2018 09:00 AM
Calendar Matter. Notice Of Motion And Motion Of Ash Rust, Garrett Johnson, Ryan Pfeffer, And John Fallone To Compel Production Of Documents; Memorandum Of
Points And Authorities
Rulings: Matter on calendar for Tuesday, December 4, 2078, Line 3, PLAINTIFFS ASHLEY RUST, GARRETT JOHNSON, RYAN PFEFFER, and JOHN FALLONE's
Motion To Compet Production Of Documents. CONTINUED to December 19, 2018 at 9:00 AM per agreement of all parties (email dated 11/19/18). =
(02/PT)
Case Number. CGC17558695,
Case Title. GILBERT PAPAZIAN II'VS, KEVIN MICHAEL SULLIVAN ET AL
Court Date: DEC-04-2018 09:00 AM
Calendar Matter. Notice Of Motion To Furthre Responses To Judicial Counsi! Form interrogatories And For Monetary Sanctions
Rulings. Matter on calendar for Tuesday, December 4, 2078, Line 4, DEFENDANTS GRIFFIN & SULLIVAN and KEVIN SULLIVAN's Motion To Compel Further
Responses To Judicial Council Form interrogatories And For Monetary Sanctions. Pro Tem Judge Robert Kane, @ member of the California State Bar who
meets all the requirements set forth in CRC 2.812 to serve as a temporary judge, has been assigned to hear this motion. Prior to the hearing all parties to
the motion will be asked to sigh a stipulation agreeing that the motion may be heard by the Pro Tem Judge. If all parties to the motion sign the stipulation,
the hearing will proceed before the Judge Pro Tem who will decide the motion with the same authority as a Superior Court Judge. If a party appears by
telephone, the stipulation may be signed via fax or consent to sign given by email. f not all parties to the motion sign the stipulation, the Pro Tem Judge
will hold a hearing on the motion and, based on the papers submitted by the parties and the hearing, issue a report in the nature of a recommendation to
the Dept. 302 Judge, who will then decide the motion, if a party does not appear at the hearing, the party will be deemed to have stipulated that the
‘motion will be decided by the Pro Tetn Judge with the same authority as a Superior Court Judge. The Pro Tem Judge has issued the following tentative
ruling: Parties to appear. Any party who contests a tentative ruling must send an email to rkane1089@aol.com with a copy to all other parties by 4pm
stating, without argument, the portion(s) of the tentative ruling thet the party contests. The subject fine of the email shall inciude the line number, case
name and case number. f the tentative ruling is not contested, the parties are deemed to have stipulated to the Pro Tem hearing the motion and the Pro
‘Tem will sign an order confirming the tentative ruling. The prevailing party is required to prepare a proposed order repeating verbatim the substantive
portion of the tentative ruling and must bring the proposed order to the hearing even if the motion is not opposed or the tentative ruling is not contested.
=(302/NPT)
Case Number, G018564545Case Title:
Court Date:
Calendar Matter:
Rulings:
DAWN ANN MASON ET AL VS. FCAUS, LLC ET At,
DEG-04-2018 09:00 AM
Notice Of Motion To Compel Further Responses To Plaintiffs Request For Production Of Documents, Set One
Matter on calendar for Tuesday, December 4, 2078, Line 5, PLAINTIFFs DAWN MASON and JAMES MASON's Motion To Compel Further Responses To
Plaintiffs Request For Production Of Documents, Set One. Pro Tem Judge Robert Kane, a member of the California State Bar who meets all the
requirements set forth in CRC 2.812 to serve as a temporary judge, has been assigned to hear this motion. Prior to the hearing alf parties to the m
will be asked to sign a stipulation agreeing that the motion may be heard by the Pro Tem Judge. If all parties to the motion sign the stipulation, the
hearing will proceed before the Judge Pro Tem who will decide the motion with the same authority as a Superior Court Judge. Ifa party appears by
telephone, the stipulation may be signed via fax or consent to sign given by email. If not all parties to the motion sign the stipulation, the Pro Tem Judge
‘will hold a hearing on the motion and, based on the papers submitted by the parties and the hearing, issue a report in the nature of a recommendation to
the Dept. 202 Judge, who will then decide the motion. if a party does not appear at the hearing, the party will be deemed to have stipulated that the
motion will be decided by the Pro Tem Judge with the same authority as a Superior Court Judge. The Pro Tem judge has issued the following tentative
ruling: No courtesy copies of moving papers provided to court by Plaintiff. if Plaintiff provides courtesy copies to Dept. 301 by December 12 (with notice
‘of such te counsel for Defendant) the matter will be continued to December 27, 2018. Otherwise, the matter is off calendar. Any party who contests @
tentative culing must send an email to rkane1 089@aol.com with a copy to all other parties by 4pm stating, without argument, the portion(s} of the
tentative ruling that the party contests. The subject line of the email shall include the fine number, case name and case number. If the tentative ruling is
not contested, the parties are deemed to have stipulated to the Pro Tem hearing the motion and the Pro Term will sign an order confirming the tentative
ruling, The prevailing party is required to prepare a proposed order repeating verbatim the substantive portion of the tentative ruling and must bring the
proposed order to the hearing even if the motion is not opposed or the tentative ruling is not contested, =(202/JPT)
‘ionPROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
Tam employed in the County of Los Angeles, State of California. I am over the age of
18 and not a party to the within action. My business address is Strategic Legal Practices, 1840
Century Park East, Suite 430, Los Angeles, California 90067.
On December 4, 2018, I served the document(s) described as:
PLAINTIFFS’ NOTICE OF CONTINUANCE OF HEARING RE: PLAINTIFFS’
MOTION TO COMPEL FURTHER RESPONSES TO PLAINTIFFS’ REQUEST FOR
PRODUCTION OF DOCUMENTS, SET ONE
on the interested parties in this action by sending [ ] the original [or] [v] a true copy thereof
[v ]to interested parties as follows [or] [ ] as stated on the attached service list:
Jon D. Universal
Universal & Shannon, LLP
2240 Douglas Blvd. Suite 290
Roseville, CA 95661
x BY MAIL (ENCLOSED IN A SEALED ENVELOPE): | deposited the envelope(s)
for mailing in the ordinary course of business at Los Angeles, California. | am “readily
familiar” with this firm’s practice of collection and processing correspondence for
mailing. Under that practice, sealed envelopes are deposited with the U.S. Postal
Service that same day in the ordinary course of business with postage thereon fully
prepaid at Los Angeles. California.
BY E-MAIL: I hereby certify that this document was served from Los Angeles,
California, by e-mail delivery on the parties listed herein at their most recent known e-
mail address or e-mail of record in this action.
BY PERSONAL SERVICE: I delivered the document, enclosed in a sealed envelope,
bv hand to the offices of the addressee(s) named herein.
BY OVERNIGHT DELIVERY: | am “readily familiar” with this firm’s practice of
collection and processing correspondence for overnight delivery. Under that practice,
overnight packages are enclosed in a sealed envelope with a packing slip attached
thereto fully prepaid. The packages are picked up by the carrier at our offices or
delivered bv our office to a designated collection site.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
Executed this December 4, 2018, at Los Angeles, California. ;
iff. oe
/ tm 4
Katrina Gorgy AhAR> a
Type or Print Name “Signature.
2
PLAINTIFFS” NOTICE OF CONTINUANCE OF HEARING RE: PLAINTIFFS’ MOTION TO COMPEL FURTHER
RESPONSES TO PLAINTIFFS’ REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE
Preview
Christine Haw (SBN 289351) e-mail: chaw@slpattorney.com Gabriella Pedone (SBN 308384) e-mail: gpedone@slpattorney.com STRATEGIC LEGAL PRACTICES A PROFESSIONAL LAW CORPORATION 1840 Century Park East, Suite 430 Los Angeles, CA 90067 Telephone: (310) 929-4900 Facsimile: (310) 943-3838 ELECTRONICALLY FILED Superior Court of California, County of San Francisco 12/04/2018 Clerk of the Court BY: VANESSA WU Deputy Clerk Attorneys for Plaintiff DAWN ANN MASON and JAMES MASON SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO DAWN ANN MASON and JAMES MASON, Plaintiff, v. FCA US, LLC, and DOES 1 through 10, inclusive, Defendants. Case No.: CGC-18-564545 DISCOVERY Hon. Harold Kahn Dept. 302 PLAINTIFFS’ NOTICE OF CONTINUANCE OF HEARING RE: PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES TO PLAINTIFFS’ REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE Date: December 27, 2018 Time: 9:00 am Dept.: 301 PLAINTIFFS’ NOTICE OF CONTINUANCE OF HEARING RE: PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES TO PLAINTIFFS’ REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONETO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that, per the Court’s December 3, 2018 tentative ruling, the hearing on Plaintiffs DAWN ANN MASON and JASMES MASON’s (hereinafter “Plaintiffs”) Motion to Compel Further Responses to Plaintiffs’ Requests for Production of Documents, Set One, previously set for December 4, 2018, is continued to December 27, 2018 at 9:00 a.m. in Department 301 of the above-captioned court, located at 400 McAllister Street, San Francisco, California 94102. Furthermore, Plaintiff has been ordered to provide courtesy copies of Plaintiffs’ moving and reply papers, (with notice of such to counsel for Defendant) to Department 301 by no later than December 12, 2018. A copy of the Court’s ruling is attached hereto as Exhibit A. Dated: December 4, 2018 Respectfully submitted, Strategic Legal Practices, APC 6 OG_ D> Gabriella Pedone Attorney for Plaintiffs DAWN ANN MASON and JAMES MASON By: 1 PLAINTIFFS” NOTICE OF CONTINUANCE OF HEARING RE: PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES TO PLAINTIFFS’ REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONEEXHIBIT AContact Us THE SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Tentative Rulings Law & Motion/Discovery Department 302 You can search by Case Number, Court Date or a combination of Court Date and Case Number. CaseNumber, [oo | And/Or ‘Court Date. [seach Total Records Found 5, Case Number. (CGC15549626 Case Title REBECCA CHAMORRO ET AL VS. DIGNITY HEALTH ET Al, Court Date DEC-04-2078 14:00 PM Calendar Maiter: Notice Of Motion And Motion To Compel Further Deposition Of Person Most Qualified Rulings. Maiter on calendar for Tuesday, December 4, 2018, Line 1, PETITIONERs REBECCA CHAMORRO and PHYSICIANS FOR REPRODUCTIVE HEALTH's Motion ‘Yo Compel Further Deposition Of Person Most Qualified. To be heard on 12/4/18 at 2:00 pm in the Law and Motion Dept. before Judge Kahn, =(302/JPT) Gase Number G017587171 Case Title. VICTORIA SMITH VS. AMERICAN CONSERVATORY THEATER ET AL. Court Date’ DEC-04-2018 09:00 AM Calendar Matter: Notice Of Motion To Compel Further Responses To Form interrogatories -Employment Law And Request For Sanctions. Rulings: Matter on calendar for Tuesday, December 4, 2018, Line 2, PLAINTIFF VICTORIA SMITH's Motion To Compel Further Responses To Form interrogatories Employment Law And Request For Sanctions. CONTINUED to December 19, 2018 at 9:00 AM per agreement of the parties. =(302/JPT) Case Number. cGC17558112 Case Title. ASHLEY RUST VS. SENDHUB, INC. Court Date: DEC-04-2018 09:00 AM Calendar Matter. Notice Of Motion And Motion Of Ash Rust, Garrett Johnson, Ryan Pfeffer, And John Fallone To Compel Production Of Documents; Memorandum Of Points And Authorities Rulings: Matter on calendar for Tuesday, December 4, 2078, Line 3, PLAINTIFFS ASHLEY RUST, GARRETT JOHNSON, RYAN PFEFFER, and JOHN FALLONE's Motion To Compet Production Of Documents. CONTINUED to December 19, 2018 at 9:00 AM per agreement of all parties (email dated 11/19/18). = (02/PT) Case Number. CGC17558695, Case Title. GILBERT PAPAZIAN II'VS, KEVIN MICHAEL SULLIVAN ET AL Court Date: DEC-04-2018 09:00 AM Calendar Matter. Notice Of Motion To Furthre Responses To Judicial Counsi! Form interrogatories And For Monetary Sanctions Rulings. Matter on calendar for Tuesday, December 4, 2078, Line 4, DEFENDANTS GRIFFIN & SULLIVAN and KEVIN SULLIVAN's Motion To Compel Further Responses To Judicial Council Form interrogatories And For Monetary Sanctions. Pro Tem Judge Robert Kane, @ member of the California State Bar who meets all the requirements set forth in CRC 2.812 to serve as a temporary judge, has been assigned to hear this motion. Prior to the hearing all parties to the motion will be asked to sigh a stipulation agreeing that the motion may be heard by the Pro Tem Judge. If all parties to the motion sign the stipulation, the hearing will proceed before the Judge Pro Tem who will decide the motion with the same authority as a Superior Court Judge. If a party appears by telephone, the stipulation may be signed via fax or consent to sign given by email. f not all parties to the motion sign the stipulation, the Pro Tem Judge will hold a hearing on the motion and, based on the papers submitted by the parties and the hearing, issue a report in the nature of a recommendation to the Dept. 302 Judge, who will then decide the motion, if a party does not appear at the hearing, the party will be deemed to have stipulated that the ‘motion will be decided by the Pro Tetn Judge with the same authority as a Superior Court Judge. The Pro Tem Judge has issued the following tentative ruling: Parties to appear. Any party who contests a tentative ruling must send an email to rkane1089@aol.com with a copy to all other parties by 4pm stating, without argument, the portion(s) of the tentative ruling thet the party contests. The subject fine of the email shall inciude the line number, case name and case number. f the tentative ruling is not contested, the parties are deemed to have stipulated to the Pro Tem hearing the motion and the Pro ‘Tem will sign an order confirming the tentative ruling. The prevailing party is required to prepare a proposed order repeating verbatim the substantive portion of the tentative ruling and must bring the proposed order to the hearing even if the motion is not opposed or the tentative ruling is not contested. =(302/NPT) Case Number, G018564545Case Title: Court Date: Calendar Matter: Rulings: DAWN ANN MASON ET AL VS. FCAUS, LLC ET At, DEG-04-2018 09:00 AM Notice Of Motion To Compel Further Responses To Plaintiffs Request For Production Of Documents, Set One Matter on calendar for Tuesday, December 4, 2078, Line 5, PLAINTIFFs DAWN MASON and JAMES MASON's Motion To Compel Further Responses To Plaintiffs Request For Production Of Documents, Set One. Pro Tem Judge Robert Kane, a member of the California State Bar who meets all the requirements set forth in CRC 2.812 to serve as a temporary judge, has been assigned to hear this motion. Prior to the hearing alf parties to the m will be asked to sign a stipulation agreeing that the motion may be heard by the Pro Tem Judge. If all parties to the motion sign the stipulation, the hearing will proceed before the Judge Pro Tem who will decide the motion with the same authority as a Superior Court Judge. Ifa party appears by telephone, the stipulation may be signed via fax or consent to sign given by email. If not all parties to the motion sign the stipulation, the Pro Tem Judge ‘will hold a hearing on the motion and, based on the papers submitted by the parties and the hearing, issue a report in the nature of a recommendation to the Dept. 202 Judge, who will then decide the motion. if a party does not appear at the hearing, the party will be deemed to have stipulated that the motion will be decided by the Pro Tem Judge with the same authority as a Superior Court Judge. The Pro Tem judge has issued the following tentative ruling: No courtesy copies of moving papers provided to court by Plaintiff. if Plaintiff provides courtesy copies to Dept. 301 by December 12 (with notice ‘of such te counsel for Defendant) the matter will be continued to December 27, 2018. Otherwise, the matter is off calendar. Any party who contests @ tentative culing must send an email to rkane1 089@aol.com with a copy to all other parties by 4pm stating, without argument, the portion(s} of the tentative ruling that the party contests. The subject line of the email shall include the fine number, case name and case number. If the tentative ruling is not contested, the parties are deemed to have stipulated to the Pro Tem hearing the motion and the Pro Term will sign an order confirming the tentative ruling, The prevailing party is required to prepare a proposed order repeating verbatim the substantive portion of the tentative ruling and must bring the proposed order to the hearing even if the motion is not opposed or the tentative ruling is not contested, =(202/JPT) ‘ionPROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF LOS ANGELES Tam employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action. My business address is Strategic Legal Practices, 1840 Century Park East, Suite 430, Los Angeles, California 90067. On December 4, 2018, I served the document(s) described as: PLAINTIFFS’ NOTICE OF CONTINUANCE OF HEARING RE: PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES TO PLAINTIFFS’ REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE on the interested parties in this action by sending [ ] the original [or] [v] a true copy thereof [v ]to interested parties as follows [or] [ ] as stated on the attached service list: Jon D. Universal Universal & Shannon, LLP 2240 Douglas Blvd. Suite 290 Roseville, CA 95661 x BY MAIL (ENCLOSED IN A SEALED ENVELOPE): | deposited the envelope(s) for mailing in the ordinary course of business at Los Angeles, California. | am “readily familiar” with this firm’s practice of collection and processing correspondence for mailing. Under that practice, sealed envelopes are deposited with the U.S. Postal Service that same day in the ordinary course of business with postage thereon fully prepaid at Los Angeles. California. BY E-MAIL: I hereby certify that this document was served from Los Angeles, California, by e-mail delivery on the parties listed herein at their most recent known e- mail address or e-mail of record in this action. BY PERSONAL SERVICE: I delivered the document, enclosed in a sealed envelope, bv hand to the offices of the addressee(s) named herein. BY OVERNIGHT DELIVERY: | am “readily familiar” with this firm’s practice of collection and processing correspondence for overnight delivery. Under that practice, overnight packages are enclosed in a sealed envelope with a packing slip attached thereto fully prepaid. The packages are picked up by the carrier at our offices or delivered bv our office to a designated collection site. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed this December 4, 2018, at Los Angeles, California. ; iff. oe / tm 4 Katrina Gorgy AhAR> a Type or Print Name “Signature. 2 PLAINTIFFS” NOTICE OF CONTINUANCE OF HEARING RE: PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES TO PLAINTIFFS’ REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE