Preview
FiLEO/EMDOBSE0
1 JOSHUA S. FALAKASSA (SBN: 295045)
FALAKASSA LAW, P.C.
AUG 0 2022
2 1901 Avenue ofttieStars Suite # 450
By:. E. Macdonald
3 Los Angeles, Califomia 90067 Oepu'v Clerk
Tel.: (818) 456-6168; Fax: (888) 505-0868
4 Email: josh@falakassalaw.com
5 ARASH S. KHOSROWSHAHI (SBN: 293246)
6 LIBERTY MAN LAW, P.C.
1010 F Street, Ste. 300
7 Sacramento, Califomia 95814
Tel.: (916) 573-0469; Fax: (866) 700-0787
8 Email: ash@libertymanlaw.com
9
Attomeys for Plaintiff,
10 SAJIDA ZAMAN
11 SUPERIOR COURT OF CALIFORNIA
12
COUNTY OF SACRAMENTO BY FAX
13
SAJIDA ZAMAN, CASE NO.: 34-2019-00252121
14
Plaintiff, NOTICE OF EX PARTE
15 APPLICATION FOR ORDER (1)
vs. SPECIALLY SETTING HEARINGS ON
16 DISCOVERY MOTIONS; (2)
LIQUI-BOX CORPORATION, and DOES 1 CONTINUING MOTION FOR
17 through 20, inclusive. SUMMARY JUDGMENT/SUMMARY
Defendants. ADJUDICATION HEARING; AND (3)
18 FOR LEAVE TO FILE ADDITIONAL
EVIDENCE IN OPPOSITION TO
19 DEFENDANT'S MOTION FOR
SUMMARY JUDGMENT/SUMMARY
20 ADJUDICATION
21
Date: August 5, 2022
22 Time: 9:00am
Dept.: 53
23 Trial Date: September 12, 2022
24
TO DEFENDANT LIQUI-BOX CORPORATION AND ITS ATTORNEY OF RECORD:
25
NOTICE IS HEREBY GIVEN that on August 5, 2022 at 9:00a.m., or as soon thereafter as
26
the matter may be heard, in Department 53 this court, located at the Hall of Justice, 813 6th Stteet
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28 NOTICE OF EX PARTE APPLICATION FOR ORDER (1) SPECIALLY SETTING HEARINGS ON
DISCOVERY MOTIONS; (2) CONTINUING MOTION FOR SUMMARY JUDGMENT/SUMMARY
ADJUDICATION HEARING; AND (3) FOR LEAVE TO FILE ADDITIONAL EVIDENCE IN OPPOSITION TO
DEFENDANT'S MOTION FOR SUMMARY JUDGMENT/SUMMARY ADJUDICATION
1 n f l
1 Sacramento, Califomia 95814, Plaintiff Sajida Zaman ("Plaintiff') will, and hereby does, apply to
2 the Court ex parte for an order
3 (1) specially setting hearings on Plaintiffs (i) Motion to Deem Admitted Requests foi
4 Admissions, Set One; (ii) Motion to Compel Responses to Form Interrogatories—General, Set
5 Two; (iii) Motion to Compel Further Responses to Special Interrogatories, Set Three; (iv) Motion
6 to Compel Further Responses to Special Interrogatories, Set Four; (v) Motion to Compel
7 Responses to Special Interrogatories, Set Five; (vi) Motion to Compel Further Responses to
8 Requests for Production of Documents, Set Four; and (vii) Motion to Compel Further Responses
9 to Requests for Production of Documents, Set Five; on or before September 1, 2022.
10 (2) continuing the hearing date on Defendant Liqui-Box Corporation's ("Defendant")
11 Motion for Summary Judgment and/or Summary Adjudication of Issues ("MSJ") sixty (60) days
12 from August 10, 2022 to October 10, 2022; and
13 (3) granting leave for Plaintiffto file a supplemental brief in opposition to the MSJ.
14 Altematively, Plaintiff requests an order specially setting the discovery motions referenced in (1),
15 (i)-(vii) above for a hearing on September 1, 2022.
16 This application for relief is made on the grounds that Plaintiff suffers irreparable harm il
17 she is not allowed access to additional outstanding discovery Defendant withheld during her time
18 to oppose the MSJ. Good cause exists for Plaintiff to be provided additional time to have bet
19 discovery motions heard, review the discovery provided after this Court mles on Plaintiffs
20 motions, and rely on said discovery to provide supplemental briefing in opposition to the MSJ
21 (Code Civ. Proc. § 437c(h); Chavez v. 24 Hour Fitness USA, Inc. (2015) 238 Cal.App.4th 632;
22 Lerma v. County of Orange (2004) 120 Cal.App.4th 709.)
23 The application will be based on this Notice, Declaration of Arash S. Khosrowshahi, the
24 Memorandum of Points and Authorities, on the records and file herein, and on such evidence as
25 may be presented at the hearing of the motion.
26 Pursuant to Local Rule 1.06 (A), the court will make a tentative mling on the merits ofthis
27 matter by 2:00 p.m., the court day before the hearing. The complete text ofthe tentative mlings
28 NOTICE OF EX PARTE APPLICATION FOR ORDER (1) SPECIALLY SETTING HEARINGS ON
DISCOVERY MOTIONS; (2) CONTINUING MOTION FOR SUMMARY JUDGMENT/SUMMARY
ADJUDICATION HEARING; AND (3) FOR LEAVE TO FILE ADDITIONAL EVIDENCE IN OPPOSITION TO
DEFENDANT'S MOTION FOR SUMMARY JUDGMENT/SUMMARY ADJUDICATION
2 of 3
1 for the department may be downloaded off the court's website. If the party does not have online
2 access, they may call the dedicated phone number for the department as referenced in the local
3 telephone directory between the hours of 2:00 p.m. and 4:00 p.m. on the court day before the
4 hearing and receive the tentative mling. If you do not call the court and the opposing party by 4:00
5 p.m. the court day before the hearing, no hearing will be held.
6 Dated: August 4, 2022 LIBERTY MAN LAW, P.C.
FALAKASSA LAW, P.C.
7
8
Bv:^
9 Arash S. Khosrowshahi
10 Joshua S. Falakassa
Attomeys for Plaintiff Sajida Zaman
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28 NOTICE OF EX PARTE APPLICATION FOR ORDER (1) SPECIALLY SETTING HEARINGS ON
DISCOVERY MOTIONS; (2) CONTINUING MOTION FOR SUMMARY JUDGMENT/SUMMARY
ADJUDICATION HEARING; AND (3) FOR LEAVE TO FILE ADDITIONAL EVIDENCE IN OPPOSITION TO
DEFENDANT'S MOTION FOR SUMMARY JUDGMENT/SUMMARY ADJUDICATION
3 of 3
1 TABLE OF CONTENTS
2 I. INTRODUCTION
3 IL STATEMENT OF FACTS 3
4 A. Plaintiff Sustained Work-Related Injuries and Disabilities to her Knee While on
5 the Job but was Terminated for Allegedly Not Reporting Immediately 3
6 B. Defendant's Counsel Seeks Ex Parte Relief at the Last Minute to Set a Hearing
7 for Defendant's Motion for Summary Judgment 3
8 C. Plaintiff Diligently Served Discovery Regarding Essential Issues to be
9 Adjudicated in the MSJ, But Defendant Stonewalled Production of Anv
10 Discovery During PlaintifPs Time to Oppose the MSJ 4
11 1. OSHA Logs, Related Documents, and Witness/Factual Information
12 Regarding Their Drafting and Storage 4
13 2. "Me Too" Evidence as to Iniured Employees Reprimanded or Terminated
14 for Violating Defendant's CSB Policv 5
15 3. Defendant's Safety Training/Injury Reporting Practices; Steps to
16 Accommodate Plaintiff; Defective Trolleys; Employees Missing Work from
17 Cumulative Trauma Injuries; and Diagnoses of PlaintifPs Injuries 6
18 4. Immediate Reporting of Work-Related Injuries; Training on Recognizing
19 Cumulative Trauma Injuries versus Pain/Soreness; PlaintifPs Injury;
20 Discussion of PlaintifPs Rights Under FEHA; and Work Restrictions 7
21 D. Defendant Had Possession of Responses to the Requests for Admissions But
22 Waited Five Days After Plaintiff Filed Her Opposition to Serve Them 8
23 m. ARGUMENT 8
24 A. Plaintiff Had Minimal Time to Oppose the MSJ and No Prior Continuances Have
25 Been Sought 10
26 B. The Outstanding Discoverv Go to Essential Issues to be Adjudicated in the
27 MSJ 10
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TABLE OF CONTENTS
lof 2
1 1. OSHA Logs. Related Documents, and Witness/Factual Information
2 Regarding Their Drafting and Storage 10
3 2. "Me Too" Evidence as to Injured Employees Reprimanded or Terminated
4 for Violating Defendant's CSB Policy 11
5 3. Defendant's Safety Training/Injury Reporting Practices; Steps to
6 Accommodate Plaintiff; Defective Trolleys; Employees Missing Work from
7 Cumulative Trauma Injuries; and Diagnoses of PlaintifPs Injuries 12
8 4. Defendant's Responses to Requests for Admissions Set 1 Have Created New
9 Disputes of Fact 13
10 C. The Outstanding Discovery Justifies an Order Specially Setting Hearings on the
11 Discoverv Motions and an Order Continuing the MSJ Hearing by 60 Days for
12 Plaintiff to Provide Supplemental Briefing to Prevent Irreparable Harm 14
13 IV. CONCLUSION 15
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TABLE OF CONTENTS
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1 TABLE OF AUTHORITIES
2 Case Law
3 1. Chavez V. 24 Hour Fitness USA, Inc. (10\5)2'i^Ca\.A^^.Aih 6^2 9,10
4 2. Frazee V. 5ee/y (2002) 95 Cal.App.4th 627 9
5 3. Lerma v. County of Orange (2004) 120 Cal.App.4tti 709 9
6 A. San Diego Watercrafts. Inc. v. Wells Fargo Bank. N.A., (2002) 102 Cal. App. 4th 308... .9
7 5. Wiler v. Firestone Tire & Rubber Co. (1979) 95 Cal.App.3d 621 9
8 Statutes and Rules
9 1. 29 CFR § 1904.35(b)(2) 4
10 2. Code ofCivil Procedure § 128 8
11 3. Code ofCivil Procedure § 166(a) 8
12 4. Code ofCivil Procedure § 437c 8,9
13 5. Labor Code § 3208.1 14
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TABLE OF AUTHORITIES
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1 JOSHUA S. FALAKASSA (SBN: 295045)
FALAKASSA LAW, P.C.
2 1901 Avenue ofthe Stars Suite # 450
3 Los Angeles, Califomia 90067
Tel.: (818) 456-6168; Fax: (888) 505-0868
4 Email: josh@falakassalaw.com
5 ARASH S. KHOSROWSHAHI (SBN: 293246)
6 LIBERTY MAN LAW, P.C.
1010 F Stteet, Ste. 300
7 Sacramento, Califomia 95814
Tel.: (916) 573-0469; Fax: (866) 700-0787
8 Email: ash@libertymanlaw.com
9
Attomeys for Plaintiff,
10 SAJIDA ZAMAN
11 SUPERIOR COURT OF CALIFORNIA
12
COUNTY OF SACRAMENTO BY FAX
13
SAJIDA ZAMAN, CASE NO.: 34-2019-00252121
14 [PROPOSED] ORDER GRANTING EX
Plaintiff, PARTE APPLICATION FOR ORDER (1)
15
SPECIALLY SETTING HEARINGS ON
16 vs. DISCOVERY MOTIONS; (2)
CONTINUING MOTION FOR
17 LIQUI-BOX CORPORATION, and DOES 1 SUMMARY JUDGMENT/SUMMARY
through 20, inclusive. ADJUDICATION HEARING; AND (3)
18 FOR LEAVE TO FILE ADDITIONAL
Defendants. EVIDENCE IN OPPOSITION TO
19
DEFENDANT'S MOTION FOR
20 SUMMARY JUDGMENT/SUMMARY
ADJUDICATION
21
Date: August 5,2022
22
Time: 9:00am
23 Dept.: 53
Trial Date: September 12, 2022
24
Plaintiff Sajida Zaman's ("Plaintiff') Ex Parte Applicatton for Order (1) Specially Setting
25
Hearings on Discovery Motions; (2) Continuing Motion for Summary Judgment/Summary
^
dication Hearing; and (3) for Leave to File Additional Evidence in Opposition to Defendant's
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AUG Motion for Summary Judgment/Summary Adjudication ("Ex Parte Application") was regularly
;-4
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[PROPOSED] ORDER
1n f y
1 heard at the above date and time. Arash S. Khosrowshahi, Esq. appeared on behalf of Plaintiff;
2 James T. Jones, Esq. appeared on behalf of Defendant Liqui-Box Corporation ("Defendant").
3 Satisfactory proof having been made, and good cause appearing, IT IS ORDERED that:
4 1. PiaintifFs Ex Parte Applicatton is GRANTED as follows:
5 A. The Court shall specially setting hearings on Plaintiffs (i) Motion to Deem
6 Admitted Requests for Admissions, Set 1; (ii) Motion to Compel Responses to
7 Form Interrogatories—General, Set Two; (iii) Motion to Compel Further
8 Responses to Special Interrogatories, Set Three; (iv) Motion to Compel Further
9 Responses to Special Interrogatories, Set Four; (v) Motion to Compel Responses to
10 Special Interrogatories, Set Five; (vi) Motion to Compel Further Responses to
11 Requests for Production of Documents, Set Four; and (vii) Motion to Compel
12 Further Responses to Requests for Production of Documents, Set Five on
13 August/September , 2022; and/or
14 B. The Court shall continue the hearing date on Defendant's Motion for Summary
15 Judgment and/or Summary Adjudication of Issues ("MSJ") sixty (60) days from
16 August 10, 2022 to October 10, 2022; and/or
17 C. The Court shall grant Plaintiff leave to file a supplemental brief in opposition to the
18 MSJ; and
19 2. Any other relief the Court deems proper.
20 Date:
21
22
Judge of the Superior Court
23 County of Sacramento
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25
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27
28
[PROPOSED] ORDER
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Preview
FiLEO/EMDOBSE0 1 JOSHUA S. FALAKASSA (SBN: 295045) FALAKASSA LAW, P.C. AUG 0 2022 2 1901 Avenue ofttieStars Suite # 450 By:. E. Macdonald 3 Los Angeles, Califomia 90067 Oepu'v Clerk Tel.: (818) 456-6168; Fax: (888) 505-0868 4 Email: josh@falakassalaw.com 5 ARASH S. KHOSROWSHAHI (SBN: 293246) 6 LIBERTY MAN LAW, P.C. 1010 F Street, Ste. 300 7 Sacramento, Califomia 95814 Tel.: (916) 573-0469; Fax: (866) 700-0787 8 Email: ash@libertymanlaw.com 9 Attomeys for Plaintiff, 10 SAJIDA ZAMAN 11 SUPERIOR COURT OF CALIFORNIA 12 COUNTY OF SACRAMENTO BY FAX 13 SAJIDA ZAMAN, CASE NO.: 34-2019-00252121 14 Plaintiff, NOTICE OF EX PARTE 15 APPLICATION FOR ORDER (1) vs. SPECIALLY SETTING HEARINGS ON 16 DISCOVERY MOTIONS; (2) LIQUI-BOX CORPORATION, and DOES 1 CONTINUING MOTION FOR 17 through 20, inclusive. SUMMARY JUDGMENT/SUMMARY Defendants. ADJUDICATION HEARING; AND (3) 18 FOR LEAVE TO FILE ADDITIONAL EVIDENCE IN OPPOSITION TO 19 DEFENDANT'S MOTION FOR SUMMARY JUDGMENT/SUMMARY 20 ADJUDICATION 21 Date: August 5, 2022 22 Time: 9:00am Dept.: 53 23 Trial Date: September 12, 2022 24 TO DEFENDANT LIQUI-BOX CORPORATION AND ITS ATTORNEY OF RECORD: 25 NOTICE IS HEREBY GIVEN that on August 5, 2022 at 9:00a.m., or as soon thereafter as 26 the matter may be heard, in Department 53 this court, located at the Hall of Justice, 813 6th Stteet 27 28 NOTICE OF EX PARTE APPLICATION FOR ORDER (1) SPECIALLY SETTING HEARINGS ON DISCOVERY MOTIONS; (2) CONTINUING MOTION FOR SUMMARY JUDGMENT/SUMMARY ADJUDICATION HEARING; AND (3) FOR LEAVE TO FILE ADDITIONAL EVIDENCE IN OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT/SUMMARY ADJUDICATION 1 n f l 1 Sacramento, Califomia 95814, Plaintiff Sajida Zaman ("Plaintiff') will, and hereby does, apply to 2 the Court ex parte for an order 3 (1) specially setting hearings on Plaintiffs (i) Motion to Deem Admitted Requests foi 4 Admissions, Set One; (ii) Motion to Compel Responses to Form Interrogatories—General, Set 5 Two; (iii) Motion to Compel Further Responses to Special Interrogatories, Set Three; (iv) Motion 6 to Compel Further Responses to Special Interrogatories, Set Four; (v) Motion to Compel 7 Responses to Special Interrogatories, Set Five; (vi) Motion to Compel Further Responses to 8 Requests for Production of Documents, Set Four; and (vii) Motion to Compel Further Responses 9 to Requests for Production of Documents, Set Five; on or before September 1, 2022. 10 (2) continuing the hearing date on Defendant Liqui-Box Corporation's ("Defendant") 11 Motion for Summary Judgment and/or Summary Adjudication of Issues ("MSJ") sixty (60) days 12 from August 10, 2022 to October 10, 2022; and 13 (3) granting leave for Plaintiffto file a supplemental brief in opposition to the MSJ. 14 Altematively, Plaintiff requests an order specially setting the discovery motions referenced in (1), 15 (i)-(vii) above for a hearing on September 1, 2022. 16 This application for relief is made on the grounds that Plaintiff suffers irreparable harm il 17 she is not allowed access to additional outstanding discovery Defendant withheld during her time 18 to oppose the MSJ. Good cause exists for Plaintiff to be provided additional time to have bet 19 discovery motions heard, review the discovery provided after this Court mles on Plaintiffs 20 motions, and rely on said discovery to provide supplemental briefing in opposition to the MSJ 21 (Code Civ. Proc. § 437c(h); Chavez v. 24 Hour Fitness USA, Inc. (2015) 238 Cal.App.4th 632; 22 Lerma v. County of Orange (2004) 120 Cal.App.4th 709.) 23 The application will be based on this Notice, Declaration of Arash S. Khosrowshahi, the 24 Memorandum of Points and Authorities, on the records and file herein, and on such evidence as 25 may be presented at the hearing of the motion. 26 Pursuant to Local Rule 1.06 (A), the court will make a tentative mling on the merits ofthis 27 matter by 2:00 p.m., the court day before the hearing. The complete text ofthe tentative mlings 28 NOTICE OF EX PARTE APPLICATION FOR ORDER (1) SPECIALLY SETTING HEARINGS ON DISCOVERY MOTIONS; (2) CONTINUING MOTION FOR SUMMARY JUDGMENT/SUMMARY ADJUDICATION HEARING; AND (3) FOR LEAVE TO FILE ADDITIONAL EVIDENCE IN OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT/SUMMARY ADJUDICATION 2 of 3 1 for the department may be downloaded off the court's website. If the party does not have online 2 access, they may call the dedicated phone number for the department as referenced in the local 3 telephone directory between the hours of 2:00 p.m. and 4:00 p.m. on the court day before the 4 hearing and receive the tentative mling. If you do not call the court and the opposing party by 4:00 5 p.m. the court day before the hearing, no hearing will be held. 6 Dated: August 4, 2022 LIBERTY MAN LAW, P.C. FALAKASSA LAW, P.C. 7 8 Bv:^ 9 Arash S. Khosrowshahi 10 Joshua S. Falakassa Attomeys for Plaintiff Sajida Zaman 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NOTICE OF EX PARTE APPLICATION FOR ORDER (1) SPECIALLY SETTING HEARINGS ON DISCOVERY MOTIONS; (2) CONTINUING MOTION FOR SUMMARY JUDGMENT/SUMMARY ADJUDICATION HEARING; AND (3) FOR LEAVE TO FILE ADDITIONAL EVIDENCE IN OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT/SUMMARY ADJUDICATION 3 of 3 1 TABLE OF CONTENTS 2 I. INTRODUCTION 3 IL STATEMENT OF FACTS 3 4 A. Plaintiff Sustained Work-Related Injuries and Disabilities to her Knee While on 5 the Job but was Terminated for Allegedly Not Reporting Immediately 3 6 B. Defendant's Counsel Seeks Ex Parte Relief at the Last Minute to Set a Hearing 7 for Defendant's Motion for Summary Judgment 3 8 C. Plaintiff Diligently Served Discovery Regarding Essential Issues to be 9 Adjudicated in the MSJ, But Defendant Stonewalled Production of Anv 10 Discovery During PlaintifPs Time to Oppose the MSJ 4 11 1. OSHA Logs, Related Documents, and Witness/Factual Information 12 Regarding Their Drafting and Storage 4 13 2. "Me Too" Evidence as to Iniured Employees Reprimanded or Terminated 14 for Violating Defendant's CSB Policv 5 15 3. Defendant's Safety Training/Injury Reporting Practices; Steps to 16 Accommodate Plaintiff; Defective Trolleys; Employees Missing Work from 17 Cumulative Trauma Injuries; and Diagnoses of PlaintifPs Injuries 6 18 4. Immediate Reporting of Work-Related Injuries; Training on Recognizing 19 Cumulative Trauma Injuries versus Pain/Soreness; PlaintifPs Injury; 20 Discussion of PlaintifPs Rights Under FEHA; and Work Restrictions 7 21 D. Defendant Had Possession of Responses to the Requests for Admissions But 22 Waited Five Days After Plaintiff Filed Her Opposition to Serve Them 8 23 m. ARGUMENT 8 24 A. Plaintiff Had Minimal Time to Oppose the MSJ and No Prior Continuances Have 25 Been Sought 10 26 B. The Outstanding Discoverv Go to Essential Issues to be Adjudicated in the 27 MSJ 10 28 TABLE OF CONTENTS lof 2 1 1. OSHA Logs. Related Documents, and Witness/Factual Information 2 Regarding Their Drafting and Storage 10 3 2. "Me Too" Evidence as to Injured Employees Reprimanded or Terminated 4 for Violating Defendant's CSB Policy 11 5 3. Defendant's Safety Training/Injury Reporting Practices; Steps to 6 Accommodate Plaintiff; Defective Trolleys; Employees Missing Work from 7 Cumulative Trauma Injuries; and Diagnoses of PlaintifPs Injuries 12 8 4. Defendant's Responses to Requests for Admissions Set 1 Have Created New 9 Disputes of Fact 13 10 C. The Outstanding Discovery Justifies an Order Specially Setting Hearings on the 11 Discoverv Motions and an Order Continuing the MSJ Hearing by 60 Days for 12 Plaintiff to Provide Supplemental Briefing to Prevent Irreparable Harm 14 13 IV. CONCLUSION 15 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 TABLE OF CONTENTS 2 of 2 1 TABLE OF AUTHORITIES 2 Case Law 3 1. Chavez V. 24 Hour Fitness USA, Inc. (10\5)2'i^Ca\.A^^.Aih 6^2 9,10 4 2. Frazee V. 5ee/y (2002) 95 Cal.App.4th 627 9 5 3. Lerma v. County of Orange (2004) 120 Cal.App.4tti 709 9 6 A. San Diego Watercrafts. Inc. v. Wells Fargo Bank. N.A., (2002) 102 Cal. App. 4th 308... .9 7 5. Wiler v. Firestone Tire & Rubber Co. (1979) 95 Cal.App.3d 621 9 8 Statutes and Rules 9 1. 29 CFR § 1904.35(b)(2) 4 10 2. Code ofCivil Procedure § 128 8 11 3. Code ofCivil Procedure § 166(a) 8 12 4. Code ofCivil Procedure § 437c 8,9 13 5. Labor Code § 3208.1 14 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 TABLE OF AUTHORITIES 1 ofl 1 JOSHUA S. FALAKASSA (SBN: 295045) FALAKASSA LAW, P.C. 2 1901 Avenue ofthe Stars Suite # 450 3 Los Angeles, Califomia 90067 Tel.: (818) 456-6168; Fax: (888) 505-0868 4 Email: josh@falakassalaw.com 5 ARASH S. KHOSROWSHAHI (SBN: 293246) 6 LIBERTY MAN LAW, P.C. 1010 F Stteet, Ste. 300 7 Sacramento, Califomia 95814 Tel.: (916) 573-0469; Fax: (866) 700-0787 8 Email: ash@libertymanlaw.com 9 Attomeys for Plaintiff, 10 SAJIDA ZAMAN 11 SUPERIOR COURT OF CALIFORNIA 12 COUNTY OF SACRAMENTO BY FAX 13 SAJIDA ZAMAN, CASE NO.: 34-2019-00252121 14 [PROPOSED] ORDER GRANTING EX Plaintiff, PARTE APPLICATION FOR ORDER (1) 15 SPECIALLY SETTING HEARINGS ON 16 vs. DISCOVERY MOTIONS; (2) CONTINUING MOTION FOR 17 LIQUI-BOX CORPORATION, and DOES 1 SUMMARY JUDGMENT/SUMMARY through 20, inclusive. ADJUDICATION HEARING; AND (3) 18 FOR LEAVE TO FILE ADDITIONAL Defendants. EVIDENCE IN OPPOSITION TO 19 DEFENDANT'S MOTION FOR 20 SUMMARY JUDGMENT/SUMMARY ADJUDICATION 21 Date: August 5,2022 22 Time: 9:00am 23 Dept.: 53 Trial Date: September 12, 2022 24 Plaintiff Sajida Zaman's ("Plaintiff') Ex Parte Applicatton for Order (1) Specially Setting 25 Hearings on Discovery Motions; (2) Continuing Motion for Summary Judgment/Summary ^ dication Hearing; and (3) for Leave to File Additional Evidence in Opposition to Defendant's 27 AUG Motion for Summary Judgment/Summary Adjudication ("Ex Parte Application") was regularly ;-4 28 [PROPOSED] ORDER 1n f y 1 heard at the above date and time. Arash S. Khosrowshahi, Esq. appeared on behalf of Plaintiff; 2 James T. Jones, Esq. appeared on behalf of Defendant Liqui-Box Corporation ("Defendant"). 3 Satisfactory proof having been made, and good cause appearing, IT IS ORDERED that: 4 1. PiaintifFs Ex Parte Applicatton is GRANTED as follows: 5 A. The Court shall specially setting hearings on Plaintiffs (i) Motion to Deem 6 Admitted Requests for Admissions, Set 1; (ii) Motion to Compel Responses to 7 Form Interrogatories—General, Set Two; (iii) Motion to Compel Further 8 Responses to Special Interrogatories, Set Three; (iv) Motion to Compel Further 9 Responses to Special Interrogatories, Set Four; (v) Motion to Compel Responses to 10 Special Interrogatories, Set Five; (vi) Motion to Compel Further Responses to 11 Requests for Production of Documents, Set Four; and (vii) Motion to Compel 12 Further Responses to Requests for Production of Documents, Set Five on 13 August/September , 2022; and/or 14 B. The Court shall continue the hearing date on Defendant's Motion for Summary 15 Judgment and/or Summary Adjudication of Issues ("MSJ") sixty (60) days from 16 August 10, 2022 to October 10, 2022; and/or 17 C. The Court shall grant Plaintiff leave to file a supplemental brief in opposition to the 18 MSJ; and 19 2. Any other relief the Court deems proper. 20 Date: 21 22 Judge of the Superior Court 23 County of Sacramento 24 25 26 27 28 [PROPOSED] ORDER 9 nf 9