Stipulation,Agreement: RAMESH SHRESTHA VS. HOTEL SUNRISE, INC. ET AL

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HANSON BRIDGETT LLP
GILBERT J. TSAI, SBN 247305

gtsai@hansonbridgett.com ELECTRONICALLY
ASHLEY A. BALTAZAR, SBN 284921 FILED
abaltazar@hansonbridgett.com iforni:
425 Market Street, 26th Floor Scouny pcan Planerest
San Francisco, California 94105 08/25
Telephone: (415) 777-3200 ne of 42017,
Facsimile: (415) 541-9366 BY:VANESSA WU

Deputy Clerk

Attorneys for Defendants
HOTEL SUNRISE, INC.,,
HOTEL SUNRISE, LLC,
KIRITKUMAR PATEL,
SHAKUNTLA PATEL, and
KETAN PATEL

SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO

RAMESH SHRESTHA aka RAY CASE NO. CGC-16-553387
SHRESTHA, an individual,
Plaintiff, |
DEFENDANTS! STIPULATED
v. EX PARTE APPLICATION TO
CONTINUE TRIAL DATE
HOTEL SUNRISE, INC., a California
corporation; HO" SUNRISE, LLC, a
California limited liability company; KIRIT
KUMAL PATEL aka KIRIT KUMAR
PATEL aka KIRITKUMAR PATEL aka KEN
PATEL, an individual; SHAKUNTALAL Date: August 29, 2017
PATEL aka SHAKUNTIA PATEL aka Time: 11:00 a.m.
SHAKUNTLA PATEL aka SKAKUNTA Dept: 206
PATEL aka NINA PATEL, an individual; and | Judge: Honorable Teri L. Jackson
DOES 1-100, inclusive,
Action Filed: August 1, 2016
Defendants. Trial Date: November 6, 2017

TO THE COURT, ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that pursuant to California Rules of Court, Rule 3.1200 et seq.
Defendants HOTEL SUNRISE, INC., HOTEL SUNRISE, LLC, KIRIT KUMAL PATEL, and

SHAKUNTALAL PATEL, will appear ex parte on August 29, 2017 or as soon thereafter as the

| matter may be heard by the Court, in Department 206 of the above-titled Court, located at 400

-l- Case No, CGC-16-553387
APPLICATION TO CONTINUE TRIAL DATE.

PIPULATED EX Pa.13680325.2

2)

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McAllister Street, San Francisco, CA 94102, seeking an order that (1) continues the trial date in
the above-captioned matter from November 6, 2017 to December 11, 2017 and (2) all pre-trial
deadlines associated with the former trial date, including all discovery deadlines, shall be
continued as if the new trial date was the date initially set for trial.

This stipulated ex parte application is brought on the grounds that the parties have
mediation scheduled with Jerry Spolter at JAMS on September 8, 2017. If mediation is
unsuccessful, the parties will be unable to obtain essential testimony, documents, or other material
evidence prior to the scheduled trial date of November 6, 2017.

This Application is based upon this Stipulated Ex Parte Application, the Memorandum of
Points and Authorities, the Declaration of Ashley A. Baltazar and the exhibits thereto, the
stipulation between the parties, on the records and files herein, and on such evidence as may be
presented at the hearing of the Ex Parte Application.

Notice of this Application was provided to all counsel of record in this matter, as reflected
in Exhibit B to the Declaration of Ashley A. Baltazar. In accordance with Rule 3.1202(a) of the
California Rules of Court, all such parties and their attorneys are listed in Defendants’
Memorandum of Points and Authorities In Support Of Defendants’ Stipulated Ex Parte
Application To Continue Trial Date, filed herewith.

DATED: August 25, 2017 HANSON BRIDGETT LLP

By:
GILBERT JSYSAl
ASHLEY A. BALTAZAR
Attorneys for Plaintiff
RAMESH SHRESTHA aka RAY SHRESTHA

-2- Case No. CGC-16-553387
TIPULATED EX PARTE APPLICATION TO CONTINUE TRIAL DATE

DEFENDANTS'