On April 10, 2014 a
Hearing
was filed
involving a dispute between
Garcia, Phillip,
and
Carrie Wilson, In Her Capacitcy As Trustee Of The,
Does 1 To 20,
Markham, Erika,
Markham, Shaun,
Markham, Shawn,
Wilson, Angelo,
Wilson, Carrie,
for civil
in the District Court of San Francisco County.
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ELECTRONICALLY
LAW OFFICES OF BENNY MARTIN
Benjamin Martin (SBN 257452) cee D
647 Santa Clara Ave. County of San Francisco
Venice, CA 90291 10/25/2016
Phone: (510) 227-4406 Clerk of the Court
BY-ANNA TORRES
Deputy Clerk
Email: knowyourightsinsf@ gmail.com
Attorneys for Plaintiff Phil Garcia
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
UNLIMITED JURISDICTION
PHILLIP GARCIA, an individual, Case No. CGC-14-538560
DECLARATION OF PLAINTIFF’S
COUNSEL BENNY MARTIN IN
SUPPORT OF COURTCALL
APPEARANCE OF PLAINTIFF’S
COUNSEL ON THE HEARING ON
PLAINTIFF’S MOTION FOR TRIAL
PREFERENCE
Plaintiff,
vs.
ANGELO WILSON, an individual, et. al.
Defendants.
I, Benny Martin, declare:
1. Lam Plaintiff Garcia’s counsel, and am licensed to practice law in every state in California. I
make this declaration upon my own personal knowledge, and if called as a witness to testify, I
can and will do so.
2. [have been working in Europe for the past three (3) months in various cities. I have been
hired by various entities to do international transactional work. It appears that this work will
persist for at least another three (3) months. However, the employers for whom I have
temporarily relocated to Europe are well informed of my long-standing obligation to Plaintiff
-1-
DECLARATION OF PLAINTIFF’S COUNSEL BENNY MARTIN IN SUPPORT OF COURTCALL APPEARANCE
AT HEARINGPhillip Garcia, and his case in San Francisco Superior Court. [ anticipate trial to last three (3)
weeks, and in that regard, I will return to the United States for those three (3) weeks, and then
return to Europe to complete my work. What I cannot do is return to the United States for a
hearing at 9:30 a.m. on November 1, 2016. Nor can I re-notice this motion for ninety (90)
days in the future; that would defeat the relief this Motion seeks.
3. [have spoken to my client Mr. Garcia about this matter. We spoke about the possibility of
hiring appearance counsel for this single hearing. My client stated that he could not afford to
hire appearance counsel. Mr. Garcia stated it would be impossible. Instead, Mr. Garcia stated
that he would appear himself, and argue the motion to Your Honor.
4. Mr. Garcia has stated to me that if I am not permitted to appear by Courtcall, than he will
appear himself and argue on the moving papers I drafted and filed, as well as this Reply
Declaration.
5. The last Courtcall appearance I made on this case was on August 17, 2016, at a trial date
objection hearing. I intend to make no further Courtcall appearance in this matter.
6. On behalf of Mr. Garcia and myself, I ask for an accommodation—please let me appear
telephonically for the hearing on November 1, 2016 at 9:30 a.m.
I declare under penalty of perjury under the laws of California that the foregoing is true and correct,
and that this declaration was executed on October 25, 2016. Executed in Riga, Latvia.
LAW OFFICES OF BENNY MARTIN
Benny Martin,
Attorney for Plaintiff
-2-
DECLARATION OF PLAINTIFF’S COUNSEL BENNY MARTIN IN SUPPORT OF COURTCALL APPEARANCE
AT HEARING
Document Filed Date
October 25, 2016
Case Filing Date
April 10, 2014
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ELECTRONICALLY LAW OFFICES OF BENNY MARTIN Benjamin Martin (SBN 257452) cee D 647 Santa Clara Ave. County of San Francisco Venice, CA 90291 10/25/2016 Phone: (510) 227-4406 Clerk of the Court BY-ANNA TORRES Deputy Clerk Email: knowyourightsinsf@ gmail.com Attorneys for Plaintiff Phil Garcia SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO UNLIMITED JURISDICTION PHILLIP GARCIA, an individual, Case No. CGC-14-538560 DECLARATION OF PLAINTIFF’S COUNSEL BENNY MARTIN IN SUPPORT OF COURTCALL APPEARANCE OF PLAINTIFF’S COUNSEL ON THE HEARING ON PLAINTIFF’S MOTION FOR TRIAL PREFERENCE Plaintiff, vs. ANGELO WILSON, an individual, et. al. Defendants. I, Benny Martin, declare: 1. Lam Plaintiff Garcia’s counsel, and am licensed to practice law in every state in California. I make this declaration upon my own personal knowledge, and if called as a witness to testify, I can and will do so. 2. [have been working in Europe for the past three (3) months in various cities. I have been hired by various entities to do international transactional work. It appears that this work will persist for at least another three (3) months. However, the employers for whom I have temporarily relocated to Europe are well informed of my long-standing obligation to Plaintiff -1- DECLARATION OF PLAINTIFF’S COUNSEL BENNY MARTIN IN SUPPORT OF COURTCALL APPEARANCE AT HEARINGPhillip Garcia, and his case in San Francisco Superior Court. [ anticipate trial to last three (3) weeks, and in that regard, I will return to the United States for those three (3) weeks, and then return to Europe to complete my work. What I cannot do is return to the United States for a hearing at 9:30 a.m. on November 1, 2016. Nor can I re-notice this motion for ninety (90) days in the future; that would defeat the relief this Motion seeks. 3. [have spoken to my client Mr. Garcia about this matter. We spoke about the possibility of hiring appearance counsel for this single hearing. My client stated that he could not afford to hire appearance counsel. Mr. Garcia stated it would be impossible. Instead, Mr. Garcia stated that he would appear himself, and argue the motion to Your Honor. 4. Mr. Garcia has stated to me that if I am not permitted to appear by Courtcall, than he will appear himself and argue on the moving papers I drafted and filed, as well as this Reply Declaration. 5. The last Courtcall appearance I made on this case was on August 17, 2016, at a trial date objection hearing. I intend to make no further Courtcall appearance in this matter. 6. On behalf of Mr. Garcia and myself, I ask for an accommodation—please let me appear telephonically for the hearing on November 1, 2016 at 9:30 a.m. I declare under penalty of perjury under the laws of California that the foregoing is true and correct, and that this declaration was executed on October 25, 2016. Executed in Riga, Latvia. LAW OFFICES OF BENNY MARTIN Benny Martin, Attorney for Plaintiff -2- DECLARATION OF PLAINTIFF’S COUNSEL BENNY MARTIN IN SUPPORT OF COURTCALL APPEARANCE AT HEARING