arrow left
arrow right
  • JUSTIN PHAM VS. ZEN COMPOUND, LLC ET AL PERSONAL INJURY/PROPERTY DAMAGE - NON-VEHICLE RELATED document preview
  • JUSTIN PHAM VS. ZEN COMPOUND, LLC ET AL PERSONAL INJURY/PROPERTY DAMAGE - NON-VEHICLE RELATED document preview
  • JUSTIN PHAM VS. ZEN COMPOUND, LLC ET AL PERSONAL INJURY/PROPERTY DAMAGE - NON-VEHICLE RELATED document preview
  • JUSTIN PHAM VS. ZEN COMPOUND, LLC ET AL PERSONAL INJURY/PROPERTY DAMAGE - NON-VEHICLE RELATED document preview
  • JUSTIN PHAM VS. ZEN COMPOUND, LLC ET AL PERSONAL INJURY/PROPERTY DAMAGE - NON-VEHICLE RELATED document preview
  • JUSTIN PHAM VS. ZEN COMPOUND, LLC ET AL PERSONAL INJURY/PROPERTY DAMAGE - NON-VEHICLE RELATED document preview
  • JUSTIN PHAM VS. ZEN COMPOUND, LLC ET AL PERSONAL INJURY/PROPERTY DAMAGE - NON-VEHICLE RELATED document preview
  • JUSTIN PHAM VS. ZEN COMPOUND, LLC ET AL PERSONAL INJURY/PROPERTY DAMAGE - NON-VEHICLE RELATED document preview
						
                                

Preview

1 JOHN P. STROUSS, III (SBN 221723) LAW OFFICES OF JOHN P. STROUSS, III 2 819 Eddy Street ELECTRONICALLY 3 San Francisco, CA 94109 FILED Telephone: (415) 771-6174 Superior Court of California, County of San Francisco 4 Facsimile: (415) 236-6102 12/19/2019 Attorneys for Plaintiff Clerk of the Court 5 BY: RONNIE OTERO JUSTIN PHAM Deputy Clerk 6 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 COUNTY OF SAN FRANCISCO – UNLIMITED CIVIL JURISDICTION 9 10 JUSTIN PHAM, ) CASE NO. CGC-18-564727 ) 11 Plaintiff, ) ) DECLARATION IN SUPPORT 12 vs. ) OF STIPULATED EX PARTE ) APPLICATION TO CONTINUE TRIAL 13 ZEN COMPOUND, LLC, dba TEMPLE SF ) NIGHT CLUB, SECURITY ) Date: December 20, 2019 14 INTELLIGENCE SPECIALIST ) Time: 11:00 a.m. CORPORATION, DOES 1 TO 50, ) Dept.: 206 15 ) 16 ) Action filed: March 2, 2018 Defendants. ) Trial Date: February 24, 2020 17 ___________________________________ ) 18 DECLARATION 19 I, JOHN P. STROUSS, III, declare: 20 1. I am an attorney at law licensed to practice before all the courts of California and am 21 attorney of record for plaintiff JUSTIN PHAM in the above-entitled action. 22 2. Trial is currently set for February 24, 2020. 23 3. The parties have stipulated to this continuance. Attached hereto as Exhibit A is a true 24 and correct copy of the fully executed Stipulation to Continue Trial. 25 Declaration In Support of Stipulated Ex Parte Application to Continue 1 Trial 1 2. The parties have not yet participated in mediation, but would like the opportunity to do 2 so prior to trial. 3 3. All parties were notified of the ex parte hearing herein, in accordance with C.R.C. Rule 4 3.1203. On December 19, 2019, at 9:51 a.m., I provided written notice to defense counsel via 5 email that this ex parte appearance would be made in Department 206 of San Francisco Superior 6 Court, 400 McAllister St., San Francisco, CA. Attached as Exhibit B is my email to defense 7 counsel Mark Rennie, Jamie Lee, Mary Beth Lozano, and Darren Ebner on December 19, 2019). 8 5. There have been no prior continuances by the parties, and the continuance will not 9 10 prejudice any of the parties. 11 I declare under penalty of perjury under the laws of the State of California that the 12 foregoing is true and correct. 13 14 DATED: December 19, 2020 LAW OFFICES OF JOHN P. STROUSS, III 15 ______________________________________ 16 JOHN P. STROUSS, III 17 Attorney for Plaintiff JUSTIN PHAM 18 19 20 21 22 23 24 25 Declaration In Support of Stipulated Ex Parte Application to Continue 2 Trial EXHIBIT A 1 JOHN P. STROUSS, III (SBN 221723) Law Offices of John P. Strouss, III 2 819 Eddy Street San Francisco, CA 94109 3 Telephone: 415-771-6174 4 Facsimile: 415-236-6102 5 Attorneys for Plaintiff JUSTIN PHAM 6 7 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 FOR THE COUNTY OF SAN FRANCISCO - UNLIMITED JURISDICTION 9 JUSTIN PHAM, ) CASE NO. CGC-18-564727 10 ) Plaintiff, ) STIPULATION TO CONTINUE 11 ) TRIAL DATE vs. ) 12 ) ZEN COMPOUND, LLC, dba TEMPLE SF ) Date: December 20, 2019 Time: 13 NIGHT CLUB, SECURITY ) 11:00 a.m. INTELLIGENCE SPECIALIST ) Dept. No.: 206 14 CORPORATION, DOES 1 to 50, ) 15 ) Trial Date: February 24, 2020 Defendants. ) 16 ) ___________________________________ ) 17 18 Plaintiff Justin Pham and defendants ZEN COMPOUND, LLC dba TEMPLE SF NIGHT 19 CLUB and SECURITY INTELLIGENCE SPECIALIST CORPORATION, by and through their 20 counsel of record, hereby stipulate to continue the February 24, 2020 trial date to April 27, 2020, 21 and that all associated pretrial deadlines be continued in accordance with the new trial date. 22 Good cause exists for continuing the trial date. The trial in this matter is currently set for 23 February 24, 2020, a little over two months away, with a discovery cut off of January 27, 2020. 24 A trial continuance is necessary because the parties have not yet had the opportunity to engage in 25 Stipulation to Continue Trial Date 1 1 mediation. The parties intend to mediate the case if a continuance is granted. Furthermore, the 2 parties need additional time to conduct further discovery. 3 Pursuant to California Rule of Court 3.1332(c) and (d) and based on the foregoing, good 4 cause exists to continue the trial in this matter. For this reason, the trial date should be continued. 5 Based on the above, the parties request that the Court continue the February 24, 2020 trial date to 6 April 27, 2020, or ano her da e ha is con enien o he Co r s calendar, and that all associated 7 pretrial deadlines be continued in accordance with the new trial date. 8 LAW OFFICES OF JOHN P. STROUSS III 9 12/19/19 DATED: ________ __________________________ 10 JOHN P. STROUSS III 11 Attorney for Plaintiff Justin Pham 12 LAW OFFICES OF MARK E. RENNIE 13 DATED: ________ __________________________ 14 MARK E. RENNIE Attorney for Defendant Zen Compound, LLC 15 dba Temple SF Night Club 16 SPRINGEL & FINK LLP 17 12/18/19 18 DATED: ________ _______________________ __ JAMIE LEE 19 Attorney for Defendant Security Intelligence Specialist Corporation 20 21 22 23 24 25 Stipulation to Continue Trial Date 2 EXHIBIT B 12/19/2019 Gmail - Pham v. Temple SF Nightclub, et al. John Strouss III Pham v. Temple SF Nightclub, et al. John P. Strouss III Thu, Dec 19, 2019 at 9:51 AM To: Mark Rennie Cc: Jamie Lee , Mary Beth Lozano , Darren Ebner Counsel, I will be appearing ex parte tomorrow, December 20, 2019, at 11:00 a.m. in Department 206 of the San Francisco Superior Court, located at 400 McAllister St., San Francisco, CA 94102, in order to file the stipulated ex parte application to continue the trial date. The case is Pham v. Zen Compound, LLC, dba Temple SF Night Club, et al. I will email a copy of the application separately. Thank you, [Quoted text hidden] [Quoted text hidden] https://mail.google.com/mail/u/0?ik=6bfacaaf97&view=pt&search=all&permmsgid=msg-a%3Ar6916699228384592635&simpl=msg-a%3Ar6916699228384592635 1/1