On January 20, 2012 a
Clerk Notice
was filed
involving a dispute between
Libre, Milagros,
and
Desoto Cab Company, Inc.,
Does 1 To 100,
Hart, Brian,
for civil
in the District Court of San Francisco County.
Preview
HEU
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Document Scanning Lead Sheet
Oct-10-2012 3:19 pm
Case Number: CGC-12-517517
Filing Date: Oct-10-2012 3:14
Filed by: RONNIE OTERO
Juke Box: 001 Image: 03797241
MOTION TO CONTINUE JURY TRIAL &/OR SETTLEMENT CONF.
MILAGROS LIBRE VS. BRIAN HART et al
001003797241
Instructions:
Please place this sheet on top of the document to be scanned.Cm ND nH BF WN Be
NR NY Be Be eB eB eB Be Be Be BB
FS oem YD WwW FB BDH FS
27
28
DALE L. ALLEN, JR., SBN 145279
KEVIN P. ALLEN, SBN 252290
LOW, BALL & LYNCH
505 Montgomery Street, 7th Floor
San Francisco, California 94111
Telephone: (415) 981-6630
Facsimile: (415) 982-1634
dallen@lowball.com
kallen@lowball.com
Attorneys for Defendants
BRIAN HART AND DESOTO CAB COMPANY, INC.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO
MILAGROS LIBRE, No. CGC-12-517517
(Unlimited Jurisdiction)
Plaintiff,
NOTICE OF DEFENDANTS’ MOTION
vs. TO CONTINUE THE TRIAL AND ALL
TRIAL-RELATED DEADLINES.
BRIAN HART, DESOTO CAB COMPANY,
INC., DOES 1 TO 100, Date: November 1, 2012
Time: 9:30 a.m.
Defendants. Dept.: 206
Complaint Filed: January 20, 2012
Current Trial Date: January 14, 2013
Requested Trial Date: May 14, 2013
TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD:
NOTICE IS HEREBY GIVEN that on November 1, 2012 at 9:30 a.m., in Department 206 of
this Court, BRIAN HART AND DESOTO CAB COMPANY, INC. (“Defendants”) will appear and
request a 120-day trial continuance, from January 14, 2013 until May 14, 2013. Defendants also
specifically request continuance of all trial-related deadlines.
The motion will be based upon this Notice; the Memorandum of Points and Authorities filed
and served herewith and all legal authorities discussed therein; the Request for Judicial Notice and all
Exhibits attached thereto; the Declaration of Kevin P. Allen and all Exhibits attached thereto; the
[Proposed] Order submitted herewith; and any and all such oral and documentary evidence and
argument which may be offered at the hearing on this matter.
//
-1-
NOTICE OF DEFENDANTS’ MOTION TO CONTINUE THE TRIAL AND ALL TRIAL-RELATED DEADLINES
J\2758\SF0005\PId\Mtn to Continue Trial\MTC-Notice.docxoO oe YD DH FF WB NY
The motion for trial continuance is brought pursuant to C.C.P. § 128 and Rule of Court 3.1332,
on the grounds that a significant, unanticipated change in the status of the case has occurred, for which
this case is not ready for trial. Because of this significant, unanticipated change, Defendants are
prejudiced by the current trial date.
Dated: October 10, 2012
LOW, BALL & LYNCH
» LM
DALE L. ALLEN, JR.
KEVIN P. ALLEN
Attorneys for Defendants
BRIAN HART AND DESOTO CAB COMPANY,
INC.
-2-
NOTICE OF DEFENDANTS’ MOTION TO CONTINUE THE TRIAL AND ALL TRIAL-RELATED DEADLINES
5J:\2758\SFO005\Pld\Mtn to Continue Trial\Notice of Motion.docx
Document Filed Date
October 10, 2012
Case Filing Date
January 20, 2012
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HEU SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO Document Scanning Lead Sheet Oct-10-2012 3:19 pm Case Number: CGC-12-517517 Filing Date: Oct-10-2012 3:14 Filed by: RONNIE OTERO Juke Box: 001 Image: 03797241 MOTION TO CONTINUE JURY TRIAL &/OR SETTLEMENT CONF. MILAGROS LIBRE VS. BRIAN HART et al 001003797241 Instructions: Please place this sheet on top of the document to be scanned.Cm ND nH BF WN Be NR NY Be Be eB eB eB Be Be Be BB FS oem YD WwW FB BDH FS 27 28 DALE L. ALLEN, JR., SBN 145279 KEVIN P. ALLEN, SBN 252290 LOW, BALL & LYNCH 505 Montgomery Street, 7th Floor San Francisco, California 94111 Telephone: (415) 981-6630 Facsimile: (415) 982-1634 dallen@lowball.com kallen@lowball.com Attorneys for Defendants BRIAN HART AND DESOTO CAB COMPANY, INC. SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE CITY AND COUNTY OF SAN FRANCISCO MILAGROS LIBRE, No. CGC-12-517517 (Unlimited Jurisdiction) Plaintiff, NOTICE OF DEFENDANTS’ MOTION vs. TO CONTINUE THE TRIAL AND ALL TRIAL-RELATED DEADLINES. BRIAN HART, DESOTO CAB COMPANY, INC., DOES 1 TO 100, Date: November 1, 2012 Time: 9:30 a.m. Defendants. Dept.: 206 Complaint Filed: January 20, 2012 Current Trial Date: January 14, 2013 Requested Trial Date: May 14, 2013 TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD: NOTICE IS HEREBY GIVEN that on November 1, 2012 at 9:30 a.m., in Department 206 of this Court, BRIAN HART AND DESOTO CAB COMPANY, INC. (“Defendants”) will appear and request a 120-day trial continuance, from January 14, 2013 until May 14, 2013. Defendants also specifically request continuance of all trial-related deadlines. The motion will be based upon this Notice; the Memorandum of Points and Authorities filed and served herewith and all legal authorities discussed therein; the Request for Judicial Notice and all Exhibits attached thereto; the Declaration of Kevin P. Allen and all Exhibits attached thereto; the [Proposed] Order submitted herewith; and any and all such oral and documentary evidence and argument which may be offered at the hearing on this matter. // -1- NOTICE OF DEFENDANTS’ MOTION TO CONTINUE THE TRIAL AND ALL TRIAL-RELATED DEADLINES J\2758\SF0005\PId\Mtn to Continue Trial\MTC-Notice.docxoO oe YD DH FF WB NY The motion for trial continuance is brought pursuant to C.C.P. § 128 and Rule of Court 3.1332, on the grounds that a significant, unanticipated change in the status of the case has occurred, for which this case is not ready for trial. Because of this significant, unanticipated change, Defendants are prejudiced by the current trial date. Dated: October 10, 2012 LOW, BALL & LYNCH » LM DALE L. ALLEN, JR. KEVIN P. ALLEN Attorneys for Defendants BRIAN HART AND DESOTO CAB COMPANY, INC. -2- NOTICE OF DEFENDANTS’ MOTION TO CONTINUE THE TRIAL AND ALL TRIAL-RELATED DEADLINES 5J:\2758\SFO005\Pld\Mtn to Continue Trial\Notice of Motion.docx