On July 10, 2017 a
Hearing
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
1 JOHNNY D. KNADLER (SBN 220942)
LAW OFFICE OF JOHNNY D. KNADLER
2 1527-E Pershing Drive
ELECTRONICALLY
San Francisco, CA 94129
3 Telephone: (310) 564-6695 F I L E D
Facsimile: (888) 323-0611 Superior Court of California,
County of San Francisco
4 Email: jdknadler@gmail.com
02/24/2021
5 Clerk of the Court
BY: SANDRA SCHIRO
Deputy Clerk
6
Attorneys for Plaintiff/Defendant/Cross-complainant
7 SYNERGY PROJECT MANAGEMENT, INC.
8
9 SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 IN AND FOR THE COUNTY OF SAN FRANCISCO
11 SYNERGY PROJECT MANAGEMENT, Case No. CGC-17-560034
INC., (Consolidated with Case No. CGC-19-576488)
12
Plaintiff,
13 SYNERGY PROJECT
vs. MANAGEMENT, INC.’S NOTICE
14 OF MOTION AND MOTION TO
CITY AND COUNTY OF SAN FRANCISCO, CONTINUE THE TRIAL DATE
15 LONDON BREED, MOHAMMED NURU,
16 Defendants.
______________________________________ Date: March 18, 2021
17 Time: 9:30 a.m.
GHILOTTI BROS., INC., a California Dept: 206
18 Corporation,
Complaint filed: July 10, 2017
19 Plaintiff,
20
vs,
21
SYNERGY PROJECT MANAGEMENT,
22 INC., a California Corporation, and
DOES 1-30,
23 Defendants.
24 ______________________________________
25 SYNERGY PROJECT MANAGEMENT, a
California Corporation,
26
Cross-Complainant,
27
vs.
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1 Case No. CGC-17-560034
GHILOTTI BROS, INC., a California
1 Corporation, and ROES 1-20,
2 Cross-Defendants.
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2 Case No. CGC-17-560034
1 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
2
PLEASE TAKE NOTICE that on March 18, 2021 at 9:30 a.m., in Department 206 of the
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Superior Court of California for the County of San Francisco, located at 400 McAllister Street,
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San Francisco, California, Plaintiff/Defendant/Cross-complainant SYNERGY PROJECT
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MANAGEMENT, INC. (hereafter “Synergy”) will, and hereby does, move for an order
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continuing the March 29, 2021 trial date in this matter and all dates related to trial by at least 180
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days.
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This motion is made pursuant to California Rules of Court rule 3.1332 on the grounds
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that (a) Synergy’s trial attorney will be unavailable for trial due to a serious and ongoing family
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medical emergency; (b) Synergy’s trial attorney will be unavailable for trial due to being the
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primary caretaker of two disabled children during this serious and ongoing family medical
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emergency; (c) the unavailability of necessary witnesses; (d) the inability to obtain discovery
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prior to the current trial date; and (e) a pending motion to add additional parties and causes of
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action necessitating additional time to conduct necessary discovery. Granting the requested
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relief will not materially prejudice any party, but denying the requested relief will deprive
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Synergy of the opportunity to fully and fairly present its case to the jury.
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This motion is based this Notice of Motion, the Memorandum of Points and Authorities,
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the Declaration of Johnny Knadler, all of the files and records of this action, and on any
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additional material that may be elicited at the hearing on this Motion.
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21 LAW OFFICE OF JOHNNY D.
KNADLER
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Dated: February 24, 2021 By: /s/ Johnny D. Knadler
24 JOHNNY D. KNADLER
Attorneys for Plaintiff/Defendant/Cross-
25 complainant
SYNERGY PROJECT MANAGEMENT,
26 INC.
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3 Case No. CGC-17-560034
Document Filed Date
February 24, 2021
Case Filing Date
July 10, 2017
Category
OTHER NON EXEMPT COMPLAINTS (Intentional interference with contractual relations)
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1 JOHNNY D. KNADLER (SBN 220942) LAW OFFICE OF JOHNNY D. KNADLER 2 1527-E Pershing Drive ELECTRONICALLY San Francisco, CA 94129 3 Telephone: (310) 564-6695 F I L E D Facsimile: (888) 323-0611 Superior Court of California, County of San Francisco 4 Email: jdknadler@gmail.com 02/24/2021 5 Clerk of the Court BY: SANDRA SCHIRO Deputy Clerk 6 Attorneys for Plaintiff/Defendant/Cross-complainant 7 SYNERGY PROJECT MANAGEMENT, INC. 8 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 IN AND FOR THE COUNTY OF SAN FRANCISCO 11 SYNERGY PROJECT MANAGEMENT, Case No. CGC-17-560034 INC., (Consolidated with Case No. CGC-19-576488) 12 Plaintiff, 13 SYNERGY PROJECT vs. MANAGEMENT, INC.’S NOTICE 14 OF MOTION AND MOTION TO CITY AND COUNTY OF SAN FRANCISCO, CONTINUE THE TRIAL DATE 15 LONDON BREED, MOHAMMED NURU, 16 Defendants. ______________________________________ Date: March 18, 2021 17 Time: 9:30 a.m. GHILOTTI BROS., INC., a California Dept: 206 18 Corporation, Complaint filed: July 10, 2017 19 Plaintiff, 20 vs, 21 SYNERGY PROJECT MANAGEMENT, 22 INC., a California Corporation, and DOES 1-30, 23 Defendants. 24 ______________________________________ 25 SYNERGY PROJECT MANAGEMENT, a California Corporation, 26 Cross-Complainant, 27 vs. 28 1 Case No. CGC-17-560034 GHILOTTI BROS, INC., a California 1 Corporation, and ROES 1-20, 2 Cross-Defendants. 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 Case No. CGC-17-560034 1 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 2 PLEASE TAKE NOTICE that on March 18, 2021 at 9:30 a.m., in Department 206 of the 3 Superior Court of California for the County of San Francisco, located at 400 McAllister Street, 4 San Francisco, California, Plaintiff/Defendant/Cross-complainant SYNERGY PROJECT 5 MANAGEMENT, INC. (hereafter “Synergy”) will, and hereby does, move for an order 6 continuing the March 29, 2021 trial date in this matter and all dates related to trial by at least 180 7 days. 8 This motion is made pursuant to California Rules of Court rule 3.1332 on the grounds 9 that (a) Synergy’s trial attorney will be unavailable for trial due to a serious and ongoing family 10 medical emergency; (b) Synergy’s trial attorney will be unavailable for trial due to being the 11 primary caretaker of two disabled children during this serious and ongoing family medical 12 emergency; (c) the unavailability of necessary witnesses; (d) the inability to obtain discovery 13 prior to the current trial date; and (e) a pending motion to add additional parties and causes of 14 action necessitating additional time to conduct necessary discovery. Granting the requested 15 relief will not materially prejudice any party, but denying the requested relief will deprive 16 Synergy of the opportunity to fully and fairly present its case to the jury. 17 This motion is based this Notice of Motion, the Memorandum of Points and Authorities, 18 the Declaration of Johnny Knadler, all of the files and records of this action, and on any 19 additional material that may be elicited at the hearing on this Motion. 20 21 LAW OFFICE OF JOHNNY D. KNADLER 22 23 Dated: February 24, 2021 By: /s/ Johnny D. Knadler 24 JOHNNY D. KNADLER Attorneys for Plaintiff/Defendant/Cross- 25 complainant SYNERGY PROJECT MANAGEMENT, 26 INC. 27 28 3 Case No. CGC-17-560034