Proof of Service: SEAN MARTIN VS. SHANON LOFTUS et al

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                                ELECTRONICALLY

Stephanie A. Leroux, ESQ. FILED

567 Sutter Street, Third Floor Superior Court of Caltfornia,

San Francisco, CA 94102 06/19/2015

(415) 286-5291 7 : Clerk of the Court

stephanie.a.leroux@gmail.com BY:CAROL BALISTRERI
Deputy Clerk

Attorney for Defendant

SHANON LOFTUS
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Case No.: CGC 14 538489
SEAN MARTIN,
Plaintiff DECLARATION OF STEPHANIE A.
LEROUX RE: EX-PARTE SERVICE
aa Date: July 2, 2015
Time: 9:30am
SHANON LOFTUS, Dept: 206
Defendant

Filed: 6/19/2015
Trial: 7/6/2015

l.

I. INTRODUCTION
Iam an attorney duly licensed to practice law before all courts in the State
of California. I am a solo-practitioner at the Law Office of Stephanie A.
Leroux. I am counsel for the Defendant, Shanon Loftus, in this action.
As the attorney for the Defendant in this action and I verify that I have full
knowledge of these matters contained in this declaration. If called upon to
testify under oath as a witness, I verify that I would completely testify to
the facts within. I respectfully request that the Court receive this
declaration into evidence as my direct testimony as permitted by C.C.P.

Section 2009 and 2015.5 and California Rules of Court, Rule 1225.
11.

IL =FACTS
I am an attorney duly licensed to practice law before all courts in the State
of California. I am a solo-practitioner at the Law Office of Stephanie A.
Leroux. I am counsel for the Defendant, Shanon Loftus, in this action.
As the attorney for the Defendant in this action and I verify that I have full
knowledge of these matters contained in this declaration. If called upon to
testify under oath as a witness, I verify that I would completely testify to
the facts within. I respectfully request that the Court receive this
declaration into evidence as my direct testimony as permitted by C.C.P.
Section 2009 and 2015.5 and California Rules of Court, Rule 1225.
I, notified all parties of this action, as stated above on Thursday, June 18,
2015 at 9:50 and 10:00 A.M. telephone and/or e-mail respectively.
On May 29, 2015, I learned that I needed to take a personal medical
leave due to personal health issues. My leave is expected to last from
July 1, 2015 through September 1, 2015.

i. My personal medical leave is a personal and confidential matter,
that I am willing to privately disclose to the Honorable Judge
Stewart, but 1 do not want to disclose it in open court.

I initially provided opposing counsel with this information via e-mail on
June 3, 2015. At that time, it was my understanding that we would discuss
the need for a continuance and other related matters during the Mandatory

Settlement Conference on June 9, 2015.

. Unfortunately, on June 9, 2015, although some agreements were reached

related to the matter, an agreement regarding a continuance was not.

. Following June 9, 2015 through Monday, June 15, 2015, the parties in the

action engaged in some discussions relating to the Continuance and a
Stipulation, as such, I delayed filing an Ex-Parte Request.

A hearing on the Defendant’s Motion for a Continuance is necessary to
2afford the parties a fair and just hearing in this action.

9. There have been no previous continuances or delays.

10. There are no alternative means to address the issues.

11. The interests of justice and judicial economy are best served by granting
this Ex-Parte Request for an Order to Shorten Time for a Hearing on the

Motion for a Continuance.

I declare under the penalty of perjury under the laws of the State of California that the

foregoing is true and correct to the best of my knowledge.

DATED: 6/19/2015

STEPHANIE A. LEROUX

Attorney for Defendant