Stipulation,Agreement: JUSTIN PHAM VS. ZEN COMPOUND, LLC ET AL

• 
• 
• 
• 
• 
• 
• 
• 

						
                                
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