On August 14, 2015 a
Hearing
was filed
involving a dispute between
Hershberger, Ashley,
and
Does 1 Through 20,
Hershberger, Ashley,
Ngai, Jennifer,
Ngai, Woon Keung,
for civil
in the District Court of San Francisco County.
Preview
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Mark Hooshmand, Esq. (SBN 194878)
Jasna Veledar, Esq. (SBN 290620)
Hooshmand Law Group
22 Battery St., Ste. 610
San Francisco, CA 94111
Tel: (415) 318-5709
Fax: (415) 376-5897
Attorney for Plaintiff Ashley Hershberger
ELECTRONICALLY
FILED
Superior Court of California,
County of San Francisco
10/23/2015
Clerk of the Court
BY:ROMY RISK
Deputy Clerk
SUPERIOR COURT OF THE STATE OF CALIFORNIA.
COUNTY OF SAN FRANCISCO
ASHLEY HERSHBERGER,
Plaintiff,
vs.
JENNIFER NGAI, WOON KEUNG NGAI,
AND DOES | THROUGH 20,
Defendants.
JENNIFER NGAI
Plaintiff,
VS.
ASHLEY HERSHBERGER and DOES | to
10,
Defendants.
SSS SS SS SS SS SS SS
CASE: CGC-15-547392
Date Action Filed: August 14, 2015
CASE: CGC-15-548206
Date Action Filed: September 29, 2015
NOTICE OF MOTION AND MOTION TO
CONSOLIDATE
Date: December 3, 2015
Time: 9:30 a.m.
Dept.: 302
Reservation No. 10221203-14
NOTICE OF MOTION AND MOTION TO CONSOLIDATE
NOTICE OF MOTION AND MOTION TO CONSOLIDATE; 1!Som ND HW BR WY
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TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that on December 3, 2015, in San Francisco County Superior
Court, located at 400 McAllister St., San Francisco, CA 94102, Plaintiffs in this matter, Ashley
Hershberger v. Jennifer Ngai, Woon Keung Ngai, et al., CGC-15-547392, will move the Court
for an Order consolidating this action with the matter of Jennifer Ngai v. Ashley Hershberger et
al., CGC-15-548206.
This motion is brought under Code of Civil Procedure section 1048 and is warranted as
both cases involve the same questions of fact and law, both cases have the same parties, and
consolidation will promote judicial economy. Consolidation will avoid unnecessary costs and
delay as both cases can be tried singly, eliminating the cost and expense of a second trial on
similar facts. Therefore, consolidation is requested for all purposes.
The parties named in Ashley Hershberger v. Jennifer Ngai, Woon Keung Ngai, et al.,
CGC-15-547392 are Plaintiff Ashley Hershberger and Defendants Jennifer Ngai and Woon
Keung Ngai. and Does | through 20. Plaintiffs are represented by Mark Hooshmand and Jasna
Veledar of Hooshmand Law Group. Defendants are represented by Robert H. Peterson, III of
Peterson & Peterson.
The parties named in Jennifer Ngai v. Ashley Hershberger et al., CGC-15-548206 are
Plaintiff Jennifer Ngai and Defendants Ashley Hershberger and Does 1 to 10. Defendant is
represented by Mark Hooshmand and Jasna Veledar of Hooshmand Law Group. Plaintiff is
represented by Robert H. Peterson, III of Peterson & Peterson.
The motion shall be based on this notice, the attached memorandum of points and
authorities, the supporting declaration of Jasna Veledar, all pleadings and papers currently on file
in this matter, and any arguments raised at hearing on this motion.
Dated: October 23, 2015 HOOSHMAND LAW GROUP
/s/ Jasna Veledar
Jasna Veledar, Esq.
Attorney for Plaintiff
NOTICE OF MOTION AND MOTION TO CONSOLIDATE; 2
Document Filed Date
October 23, 2015
Case Filing Date
August 14, 2015
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Som ND HW BR WY RN NY NY NY NN NK KY ee Be ee Be Be Be Be eIYA RAAB YBN fF SBC wHe A DAHA BF BH = Mark Hooshmand, Esq. (SBN 194878) Jasna Veledar, Esq. (SBN 290620) Hooshmand Law Group 22 Battery St., Ste. 610 San Francisco, CA 94111 Tel: (415) 318-5709 Fax: (415) 376-5897 Attorney for Plaintiff Ashley Hershberger ELECTRONICALLY FILED Superior Court of California, County of San Francisco 10/23/2015 Clerk of the Court BY:ROMY RISK Deputy Clerk SUPERIOR COURT OF THE STATE OF CALIFORNIA. COUNTY OF SAN FRANCISCO ASHLEY HERSHBERGER, Plaintiff, vs. JENNIFER NGAI, WOON KEUNG NGAI, AND DOES | THROUGH 20, Defendants. JENNIFER NGAI Plaintiff, VS. ASHLEY HERSHBERGER and DOES | to 10, Defendants. SSS SS SS SS SS SS SS CASE: CGC-15-547392 Date Action Filed: August 14, 2015 CASE: CGC-15-548206 Date Action Filed: September 29, 2015 NOTICE OF MOTION AND MOTION TO CONSOLIDATE Date: December 3, 2015 Time: 9:30 a.m. Dept.: 302 Reservation No. 10221203-14 NOTICE OF MOTION AND MOTION TO CONSOLIDATE NOTICE OF MOTION AND MOTION TO CONSOLIDATE; 1!Som ND HW BR WY RN NY NY NY NN NK KY ee Be ee Be Be Be Be eIYA RAAB YBN fF SBC wHe A DAHA BF BH = TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that on December 3, 2015, in San Francisco County Superior Court, located at 400 McAllister St., San Francisco, CA 94102, Plaintiffs in this matter, Ashley Hershberger v. Jennifer Ngai, Woon Keung Ngai, et al., CGC-15-547392, will move the Court for an Order consolidating this action with the matter of Jennifer Ngai v. Ashley Hershberger et al., CGC-15-548206. This motion is brought under Code of Civil Procedure section 1048 and is warranted as both cases involve the same questions of fact and law, both cases have the same parties, and consolidation will promote judicial economy. Consolidation will avoid unnecessary costs and delay as both cases can be tried singly, eliminating the cost and expense of a second trial on similar facts. Therefore, consolidation is requested for all purposes. The parties named in Ashley Hershberger v. Jennifer Ngai, Woon Keung Ngai, et al., CGC-15-547392 are Plaintiff Ashley Hershberger and Defendants Jennifer Ngai and Woon Keung Ngai. and Does | through 20. Plaintiffs are represented by Mark Hooshmand and Jasna Veledar of Hooshmand Law Group. Defendants are represented by Robert H. Peterson, III of Peterson & Peterson. The parties named in Jennifer Ngai v. Ashley Hershberger et al., CGC-15-548206 are Plaintiff Jennifer Ngai and Defendants Ashley Hershberger and Does 1 to 10. Defendant is represented by Mark Hooshmand and Jasna Veledar of Hooshmand Law Group. Plaintiff is represented by Robert H. Peterson, III of Peterson & Peterson. The motion shall be based on this notice, the attached memorandum of points and authorities, the supporting declaration of Jasna Veledar, all pleadings and papers currently on file in this matter, and any arguments raised at hearing on this motion. Dated: October 23, 2015 HOOSHMAND LAW GROUP /s/ Jasna Veledar Jasna Veledar, Esq. Attorney for Plaintiff NOTICE OF MOTION AND MOTION TO CONSOLIDATE; 2