Party Statement: JOHNA PECOT et al VS. SAN FRANCISCO DEPUTY SHERIFF'S ASSOCIATION, A et al

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                                LAW OFFICES OF PAUL L. KRANZ

PAUL L. KRANZ, ESQ., SBN 114999
2 | 499 14* Street, Suite 300 ELECTRONICALLY
Oaldand, CA 94612 FILED
3 || kranzlaw@sbeglobal.net Superior Court of California,
County of San Francisco
4} Telephone: (510) 839-1200 NOV 17 2014
Facsimile: (510) 444-6698 Clerk of the Court
—_ eee BY VANESSA Wy
Attorneys for Named Plaintiffs Johna Pecot, e al, Deputy Clerk
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SUPERIOR COURT FOR THE STATE OF CALIFORNIA
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COUNTY OF SAN FRANCISCO
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13 || JOHNA PECOT, et al. Individually and on Behalf of) |= CASE NO. CGC-10-501168
All Others Similarly Situated, )
14 ) DECLARATION OF PAUL L.
Plaintiffs, ) IXRANZIN SUPPORT OF
15 ) MOTION TO VACATE
v. )
16 ) Date: December 31, 2014
SAN FRANCISCO DEPUTY SHERIFF’S ) Time: 9:30 a.m.
17 || ASSOCIATION, a California Nonprofit ) Dept: 302
Corporation, et al. ) .
18 ) Reservation No, 111414-24.
Defendants. )
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20 I, Paul L. Kranz, declare:
21 1. Tam an attorney at law duly licensed to practice before all the courts of the State of
22 || California. 1 know the following facts of my own knowledge and could and would testil'y to
23 || them in a court of law if called upon to do so. | am attorney of record for the Plaintiffs in this
24 || matter,
25 2. Defendant San Francisco Deputy Association (“Defendant”) filed a Demurrer and
26 |) Motion to Strike that was scheduled to be heard on September 4, 2014.
27 3. Iwas scheduled to be and was out of town in Arizona on September 4, 2014.
28 4. Defendant’s attorney Lara C. Smith and | agreed to continue the hearing to a date in

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DECLARATION OF PAUL L. KRANZ IN SUPPORT OF MOTION TO VACATENovember 2014 because I was scheduled to be out of town on September 4, 2014.
5. Ms. Smith asked me to contact the Court to obtain a date to which the hearing could
be continued. I communicated with the Department 302 calendar clerk, requesting what hearing

dates were available in mid-September to mid-October. The clerk responded that October was

_ | tally bookedandthat“we are cimrently_providing demurrer reservations for November 7,125

and 13.” Ms. Smith and I agreed to November 12 and I provided her with the reservation
number, | assumed that as the moving party had to and that she would contact the contact to
move the motion. I later understood that Ms. Smith thought that I had moved the hearing date.

6. Asa result of the foregoing, Plaintiff did not file opposition to the motion, believing it
had been continued to November 12, 2014. J also did not check for a tentative ruling for the
same reason. I was out of town on the date of the hearing.

7. Tunderstand that Ms. Smith, believing that the motion had been continued, did not
attend the hearing or check the tentative ruling before the hearing.

J declare under penalty of perjury of the laws of the State of California that the foregoing

is true and correct and that this declaration was executed at Oakland, California, on November

Paul L. Kranz

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17, 2014. - a. LS

DECLARATION OF PAUL L. KRANZ IN SUPPORT OF MOTION TO VACATE