On July 10, 2017 a
Order
was filed
involving a dispute between
City And County Of San Francisco,
City And County Of San Francisco (Consolidated,
Ghlotti Bros., Inc., A California Corporation,
Synergy Project Management, Inc.,
and
Breed, London,
City And County Of San Francisco,
Does 1-100,
Does 2-100, Et Al.,
Ghilotti Bros., Inc.,
Nuru, Mohammed,
San Francisco Department Of Public Works,
San Francisco Municipal Transportation Agency,
San Francisco Public Utilities Commission,
for OTHER NON EXEMPT COMPLAINTS (Intentional interference with contractual relations)
in the District Court of San Francisco County.
Preview
S00 me RA HW eB wWH
_
wn
— oe
Ny
—-
w&
N N N N N DY YF SY SB
RRRBRRBSSGEeEARS
27
28
TROUTMAN PEPPER
HAMILTON SANDERS LLP|
SEMmancabeno Cenmin STE, 800
SSaN FraNcwsco, CA 94111
TROUTMAN PEPPER HAMILTON SANDERS LLP
JAMES P. DIWIK (State Bar No. 164016)
james.diwik@troutman.com
RYAN A. LEWIS (State Bar No. 307253)
ryan.lewis@troutman.com
Three Embarcadero Center, Suite 800
San Francisco, CA 94111
Telephone: 415.477.5700
Facsimile: 415.477.5710 MAR 15 2021
we CLERK OF COURT
Attorneys for Defendant/Plaintiff/Cross-Defendant _ gy.
GHILOTTI BROS., INC. Deputy Clerk
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
CIVIL DIVISION
San Francisco County Superior Court
SYNERGY PROJECT MANAGEMENT, Case No. CGC-17-560034 [Consolidated with
INC., Case No. CGC-19-576488]
Plaintiff, |] ORDER GRANTING
DEFENDANT/PLAINTIFF/
vs. CROSS-DEFENDANT GHILOTTI BROS.,
INC.’S MOTION TO COMPEL
CITY AND COUNTY OF SAN DEPOSITION OF SYNERGY PROJECT
FRANCISCO, SAN FRANCISCO MANAGEMENT, INC.’S PERSON MOST
PUBLIC UTILITIES COMMISSION, QUALIFIED AND PRODUCTION OF
SAN FRANCISCO MUNICIPAL DOCUMENTS
TRANSPORTATION AGENCY, SAN
FRANCISCO DEPARTMENT OF
PUBLIC WORKS, LONDON BREED,
MOHAMMED NURJ, and DOES 1-100,
Defendants.
GHILOTTI BROS., INC., a California
Corporation,
Plaintiff,
v.
SYNERGY PROJECT MANAGEMENT,
INC., a California Corporation, and
DOES 1-30,
Defendants.
[PROPESED] ORDER GRANTING GHILOTTI BROS, INC.’S MOTION TO COMPEL
114188917v128
TROUTMAN PEPPER
HAMILTON SANDERS LLP
‘3 BMarcaDano Caren, STE-600
San Francesco, CA 94111
SYNERGY PROJECT MANAGEMENT,
INC., a California Corporation, (wh Ayes th pil fe ”
Cross-Complainant,
v.
GHILOTTI BROS., INC., a California
Corporation, and ROES 1-20,
Cross-Defendants.
Motion granted as follows:
(1) Deposition of Synergy's Person Most Knowledgeable—All objec’ are overruled
without prejudice. Synergy Plaintiff must make the objection at the deposition to a specific
question. Deposition to take place no later than March 22, 2021. The parties are to meet and
confer on a date, time and location for the deposition. If the parties cannot agree, then the
deposition shall take place via Zoom on March 22, 2021 at 9:30 a.m. df The fees Vin St dye
(2) Document Production at deposition. Demands # 1-5 All objections are overruled
except those on the claim of attorney client privilege or work product. Documents responsive to
Demands #1-5 and a privilege log that complies with CCP 2031.240 for any documents being
withheld on the claim of privilege to be produced before the deposition commences. Demand #6
is denied as it is not reasonably particularized.
Defendant's request for sanctions is granted in the amount of $1,875 again’ plaintiffs and
their counsel, bulbs bre stised Goh shal) de Wid th, reg y Cloagp ha
IT IS SO ORDERED lath Ms oft ' A
paws Mar. (E20!
~ fell gd —
Superior Court Judge
County of San Francisco
-2-
[PROPOSED] ORDER GRANTING GHILOTTI BROS., INC.’S MOTION TO COMPEL
114188917v1REPORT FROM PRO TEM KATHERINE GALLO
CASE: CGC-17-560034 SYNERGY PROJECT MANAGEMENT, INC. VS.
CITY AND COUNTY OF SAN FRANCISCO
MOTION: Defendant Plaintiff Cross-Defendant Ghilotti Bros., Inc.’s’ Motion To
Compel Deposition Of Synergy Project Management, Inc.’s Person Most
Qualified And Production Of Documents and request for sanctions
HEARING DATE: March 5, 2021
RECOMMENDED RULING: Motion granted as follows:
Plaintiff’s objection to untimely declaration is overruled.
(1) Deposition of Synergy’s Person Most Knowledgeable--All objections are
overruled without prejudice. Plaintiff must make the objection at the deposition to a
specific question. Deposition to take place no later than March 26, 2021. The parties are to
meet and confer on a date, time and location for the deposition. If the parties cannot agree,
then the deposition shall take place via Zoom on March 26, 2021 at 9:30 a.m.
(2) Document Production at deposition. Demands # 1-5--All objections are
overruled except those on the claim of attorney client privilege or work product.
Documents responsive to Demands #1-5 and a privilege log that complies with CCP
2031.240 for any documents being withheld on the claim of privilege to be produced before
the deposition commences. Demand #6 is denied as it is not reasonably particularized.
Request for sanctions is granted in the amount of $1875 against plaintiffs. Payment
to be made to the Client Trust Fund of TROUTMAN PEPPER HAMILTON SANDERS
LLP no later than March 26, 2021.
Plaintiff objected to every category of testimony and category of documents with the same
response. The above was my tentative ruling
At the hearing, neither side stipulated to my hearing the matter. However, plaintiff counsel
advised me that they were going to comply with the PMK notice and my rulings. I asked the
parties to meet and confer and advise me by March 9, 2021 to provide me with a stipulation. I
didn’t receive a stipulation.
I noted in the docket that the motion to continue trial was withdrawn. Maybe the parties settled.
Preview
S00 me RA HW eB wWH _ wn — oe Ny —- w& N N N N N DY YF SY SB RRRBRRBSSGEeEARS 27 28 TROUTMAN PEPPER HAMILTON SANDERS LLP| SEMmancabeno Cenmin STE, 800 SSaN FraNcwsco, CA 94111 TROUTMAN PEPPER HAMILTON SANDERS LLP JAMES P. DIWIK (State Bar No. 164016) james.diwik@troutman.com RYAN A. LEWIS (State Bar No. 307253) ryan.lewis@troutman.com Three Embarcadero Center, Suite 800 San Francisco, CA 94111 Telephone: 415.477.5700 Facsimile: 415.477.5710 MAR 15 2021 we CLERK OF COURT Attorneys for Defendant/Plaintiff/Cross-Defendant _ gy. GHILOTTI BROS., INC. Deputy Clerk SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO CIVIL DIVISION San Francisco County Superior Court SYNERGY PROJECT MANAGEMENT, Case No. CGC-17-560034 [Consolidated with INC., Case No. CGC-19-576488] Plaintiff, |] ORDER GRANTING DEFENDANT/PLAINTIFF/ vs. CROSS-DEFENDANT GHILOTTI BROS., INC.’S MOTION TO COMPEL CITY AND COUNTY OF SAN DEPOSITION OF SYNERGY PROJECT FRANCISCO, SAN FRANCISCO MANAGEMENT, INC.’S PERSON MOST PUBLIC UTILITIES COMMISSION, QUALIFIED AND PRODUCTION OF SAN FRANCISCO MUNICIPAL DOCUMENTS TRANSPORTATION AGENCY, SAN FRANCISCO DEPARTMENT OF PUBLIC WORKS, LONDON BREED, MOHAMMED NURJ, and DOES 1-100, Defendants. GHILOTTI BROS., INC., a California Corporation, Plaintiff, v. SYNERGY PROJECT MANAGEMENT, INC., a California Corporation, and DOES 1-30, Defendants. [PROPESED] ORDER GRANTING GHILOTTI BROS, INC.’S MOTION TO COMPEL 114188917v128 TROUTMAN PEPPER HAMILTON SANDERS LLP ‘3 BMarcaDano Caren, STE-600 San Francesco, CA 94111 SYNERGY PROJECT MANAGEMENT, INC., a California Corporation, (wh Ayes th pil fe ” Cross-Complainant, v. GHILOTTI BROS., INC., a California Corporation, and ROES 1-20, Cross-Defendants. Motion granted as follows: (1) Deposition of Synergy's Person Most Knowledgeable—All objec’ are overruled without prejudice. Synergy Plaintiff must make the objection at the deposition to a specific question. Deposition to take place no later than March 22, 2021. The parties are to meet and confer on a date, time and location for the deposition. If the parties cannot agree, then the deposition shall take place via Zoom on March 22, 2021 at 9:30 a.m. df The fees Vin St dye (2) Document Production at deposition. Demands # 1-5 All objections are overruled except those on the claim of attorney client privilege or work product. Documents responsive to Demands #1-5 and a privilege log that complies with CCP 2031.240 for any documents being withheld on the claim of privilege to be produced before the deposition commences. Demand #6 is denied as it is not reasonably particularized. Defendant's request for sanctions is granted in the amount of $1,875 again’ plaintiffs and their counsel, bulbs bre stised Goh shal) de Wid th, reg y Cloagp ha IT IS SO ORDERED lath Ms oft ' A paws Mar. (E20! ~ fell gd — Superior Court Judge County of San Francisco -2- [PROPOSED] ORDER GRANTING GHILOTTI BROS., INC.’S MOTION TO COMPEL 114188917v1REPORT FROM PRO TEM KATHERINE GALLO CASE: CGC-17-560034 SYNERGY PROJECT MANAGEMENT, INC. VS. CITY AND COUNTY OF SAN FRANCISCO MOTION: Defendant Plaintiff Cross-Defendant Ghilotti Bros., Inc.’s’ Motion To Compel Deposition Of Synergy Project Management, Inc.’s Person Most Qualified And Production Of Documents and request for sanctions HEARING DATE: March 5, 2021 RECOMMENDED RULING: Motion granted as follows: Plaintiff’s objection to untimely declaration is overruled. (1) Deposition of Synergy’s Person Most Knowledgeable--All objections are overruled without prejudice. Plaintiff must make the objection at the deposition to a specific question. Deposition to take place no later than March 26, 2021. The parties are to meet and confer on a date, time and location for the deposition. If the parties cannot agree, then the deposition shall take place via Zoom on March 26, 2021 at 9:30 a.m. (2) Document Production at deposition. Demands # 1-5--All objections are overruled except those on the claim of attorney client privilege or work product. Documents responsive to Demands #1-5 and a privilege log that complies with CCP 2031.240 for any documents being withheld on the claim of privilege to be produced before the deposition commences. Demand #6 is denied as it is not reasonably particularized. Request for sanctions is granted in the amount of $1875 against plaintiffs. Payment to be made to the Client Trust Fund of TROUTMAN PEPPER HAMILTON SANDERS LLP no later than March 26, 2021. Plaintiff objected to every category of testimony and category of documents with the same response. The above was my tentative ruling At the hearing, neither side stipulated to my hearing the matter. However, plaintiff counsel advised me that they were going to comply with the PMK notice and my rulings. I asked the parties to meet and confer and advise me by March 9, 2021 to provide me with a stipulation. I didn’t receive a stipulation. I noted in the docket that the motion to continue trial was withdrawn. Maybe the parties settled.