On September 05, 2017 a
Motion,Ex Parte
was filed
involving a dispute between
Columbia Property Trust,
Jones Lang Lasalle Americas, Inc.,
De Guzman, Marie,
and
Columbia Property Trust,
Crown Building Maintenance Co.,
Does 1 To 50,
Jones Lang Lasalle Americas, Inc.,
for PERSONAL INJURY/PROPERTY DAMAGE - NON-VEHICLE RELATED
in the District Court of San Francisco County.
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we
Debra Steel Sturmer (#105276)
LERCH STURMER LLP
One Sansome Street, Ste. 2060
San Francisco, CA 94104
P: 415-217-6342
dsturmer@lerchsturmer.com
Attorney for Defendant
COLUMBIA PROPERTY TRUST
ELECTRONICALLY
FILED
Superior Court of Catifornia,
County of San Francisco
08/10/2018
Clerk of the Court
BY:BOWMAN LIU
Deputy Clerk
THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN FRANCISCO
UNLIMITED JURISDICTION
MARIE DE GUZMAN,
Plaintiff,
vs.
COLUMBIA PROPERY TRUST; JONES
LANG LASALLE AMERICAS, INC.;
CROWN BUILDING MAINTENANCE CO,;
and DOES 1-50, inclusive,
Defendants
AND RELATED CROSS-COMPLAINTS
I, Debra Steel Sturmer, hereby declare as follows:
Case No.: CGC-17-561142
SUPPLEMENTAL DECLARATION OF
DEBRA STEEL STURMER IN SUPPORT
OF DEFENDANT COLUMBIA
PROPERTY TRUST’S EX PARTE
MOTION TO CONTINUE TRIAL
DATE: August 15, 2018
TIME: 11:00 AM
DEPT.: 206
Current Trial Date: 1 1-5-18
1. Lam an attorney licensed and in good standing to practice law in the State of California.
2. [am the attorney of record for the Defendant Columbia Property Trust in the above-
referenced case.
3. [have personal knowledge of the following, and could testify competently thereto.
4. The parties have been unable to conduct sufficient discovery to meet the November 5,
2018 trial date. Specifically, insurance tender disputes have contributed to a delay in
the parties being in a position to conduct discovery.
5. Plaintiff and Defendants have entered into
a Stipulation on August 3, 2018 allowing for
the trial date to be continued from November 5, 2018 to June 3, 2019.
SUPP. DECLARATION OF STURMER IN SUPPORT
OF DEF. COLUMBIA PROPERTY TRUST'S
MOTION TO CONTINUE TRIAL (SF Sup, Ct. cge-17-561142)
16. All parties have their clients’ authority to enter into the Stipulation.
7. Discovery cutoffs will be revised as a part of the Stipulation.
8. The Stipulation also declares there is no prejudice to the parties in continuing trial.
9. There have been no prior requests for a trial continuance in this matter by either party.
10. The proposed new trial date of June 3, 2019 is the first available date that can
accommodate the calendars of all counsel. In particular, Plaintiff's counsel Nikolaus Reed has
advised me that he has numerous trials set between November 2018 and the end of May 2019.
10. I provided email notice of this hearing to counsel of record for all parties by emailing this
Supplemental declaration, and the Notice, and Points and Authorities in support of this ex parte
motion. Said email was sent to all counsel via email on August 10, 2018.
I declare under penalty of perjury under the laws of the State of California the above
statements are true and correct.
Dated: August 10, 2018 LERCH STURMER LLP
7
By:
Debra Steel Sturmer, ESQ.
Attomey for Defendant Columbia Property Trust
“SUPP. DECLARATION OF STURMER IN SUPPORT OF DEF. COLUMBIA PROPERTY TRUST'S
MOTION TO CONTINUE TRIAL (SF Sup. Ct. cge-17-561142)
?
Document Filed Date
August 10, 2018
Case Filing Date
September 05, 2017
Category
PERSONAL INJURY/PROPERTY DAMAGE - NON-VEHICLE RELATED
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we Debra Steel Sturmer (#105276) LERCH STURMER LLP One Sansome Street, Ste. 2060 San Francisco, CA 94104 P: 415-217-6342 dsturmer@lerchsturmer.com Attorney for Defendant COLUMBIA PROPERTY TRUST ELECTRONICALLY FILED Superior Court of Catifornia, County of San Francisco 08/10/2018 Clerk of the Court BY:BOWMAN LIU Deputy Clerk THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN FRANCISCO UNLIMITED JURISDICTION MARIE DE GUZMAN, Plaintiff, vs. COLUMBIA PROPERY TRUST; JONES LANG LASALLE AMERICAS, INC.; CROWN BUILDING MAINTENANCE CO,; and DOES 1-50, inclusive, Defendants AND RELATED CROSS-COMPLAINTS I, Debra Steel Sturmer, hereby declare as follows: Case No.: CGC-17-561142 SUPPLEMENTAL DECLARATION OF DEBRA STEEL STURMER IN SUPPORT OF DEFENDANT COLUMBIA PROPERTY TRUST’S EX PARTE MOTION TO CONTINUE TRIAL DATE: August 15, 2018 TIME: 11:00 AM DEPT.: 206 Current Trial Date: 1 1-5-18 1. Lam an attorney licensed and in good standing to practice law in the State of California. 2. [am the attorney of record for the Defendant Columbia Property Trust in the above- referenced case. 3. [have personal knowledge of the following, and could testify competently thereto. 4. The parties have been unable to conduct sufficient discovery to meet the November 5, 2018 trial date. Specifically, insurance tender disputes have contributed to a delay in the parties being in a position to conduct discovery. 5. Plaintiff and Defendants have entered into a Stipulation on August 3, 2018 allowing for the trial date to be continued from November 5, 2018 to June 3, 2019. SUPP. DECLARATION OF STURMER IN SUPPORT OF DEF. COLUMBIA PROPERTY TRUST'S MOTION TO CONTINUE TRIAL (SF Sup, Ct. cge-17-561142) 16. All parties have their clients’ authority to enter into the Stipulation. 7. Discovery cutoffs will be revised as a part of the Stipulation. 8. The Stipulation also declares there is no prejudice to the parties in continuing trial. 9. There have been no prior requests for a trial continuance in this matter by either party. 10. The proposed new trial date of June 3, 2019 is the first available date that can accommodate the calendars of all counsel. In particular, Plaintiff's counsel Nikolaus Reed has advised me that he has numerous trials set between November 2018 and the end of May 2019. 10. I provided email notice of this hearing to counsel of record for all parties by emailing this Supplemental declaration, and the Notice, and Points and Authorities in support of this ex parte motion. Said email was sent to all counsel via email on August 10, 2018. I declare under penalty of perjury under the laws of the State of California the above statements are true and correct. Dated: August 10, 2018 LERCH STURMER LLP 7 By: Debra Steel Sturmer, ESQ. Attomey for Defendant Columbia Property Trust “SUPP. DECLARATION OF STURMER IN SUPPORT OF DEF. COLUMBIA PROPERTY TRUST'S MOTION TO CONTINUE TRIAL (SF Sup. Ct. cge-17-561142) ?