On November 23, 2016 a
Proof of Service
was filed
involving a dispute between
Ahmed Jr, Omar,
Guo, Xin,
Johnson, Patty,
Soares, Carolyn,
Stand Up California!,
Teixeira, Joe,
and
City Of Elk Grove,
for (Writ - Administrative Mandamus)
in the District Court of Sacramento County.
Preview
[Exempt From Filing Fee
Government Code § 6103]
1 MONA G. EBRAHIMI, State Bar No. 236550
mebrahirni@kmtg.com
2 LESLIE Z. WALKER, State Bar No., 249310
lwalker@kmtg. com ^^^NDORSED
3 KRONICK, MOSKOVITZ, TIEDEMANN & GIRARD
A Professional Corporation
4 400 Capitol Mall, 27^^ Floor MAY -3 2017
Sacramento, California 95814
5 Telephone: (916) 321-4500 ByJ.Zgi
Facsimile: (916) 321-4555 eiTSDeputy Clerk
6
JONATHAN P. HOBBS, State Bar No. 186045
7 City Attomey
jhobbs(^elkgrovecity.org
8 JENNIFER A. ALVES, State Bar No. 238723
Assistant City Attomey
9 jalves(^elkgrovecity.org
SUZANNE E. KENNEDY, State Bar No. 251339
10 Assistant City Attomey
skennedy@elkgrovecity.org
11 CITY OF ELK GROVE
Office of the City Attomey
12 8401 Laguna Palms Way
Elk Grove, Caiifomia 95758
13 Telephone: (916)683-7111
Facsimile: (916)627-4100
14
Attomeys for'Respondent and Defendant CITY
15 OF ELK GROVE
16 SUPERIOR COURT OF THE STATE OF CALIFORNIA
17 COUNTY OF SACRAMENTO
18 STAND UP CALIFORNIA!; PATTY Case No. 34-2016-80002493
JOHNSON; and JOE TEIXEIRA,
19
Petitioners and Plaintiffs,
20 PROOF OF SERVICE
V.
21
CITY OF ELK GROVE,
22 Case Filed: November 23,2016
Respondent and Defendant.
23
ELK GROVE TOWN CENTER, LP;
24 HOWARD HUGHES CORPORATION; and
DOES 1-20,
25
Real Parties in Interest and
26 Defendants.
27
28
1
PROOF OF SERVICE
PROOF OF SERVICE
2 STATE OF CALIFORNIA, COUNTY OF SACRAMENTO
3 At the time of service, I was over 18 years of age and not a party to this action. I am
employed in the County of Sacramento, State of Caiifomia. My business address is 400 Capitol
4 Mall, 27th Floor, Sacramento, CA 95814.
5 On May 3, 2017,1 served tme copies of the following document(s) described as
6 1. NOTICE OF MOTION AND MOTION ON RESPONDENT AND DEFENDANT
CITY OF E L K GROVE'S DEMURRER TO PETITIONERS AND PLAINTIFFS'
7 VERIFIED AMENDED PETITION FOR WRIT OF MANDATE AND COMPLAINT.
8 2. RESPONDENT AND DEFENDANT CITY OF E L K GROVE'S DEMURRER TO
PETITIONERS AND PLAINTIFFS' VERIFIED AMENDED PETITION FOR WRIT OF
9 MANDATE AND COMPLAINT FOR DECLARATORY R E L I E F .
10 3. MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF
RESPONDENT AND DEFENDANT CITY OF E L K GROVE'S DEMURRER TO
11 PETITIONERS AND PLAINTIFFS' VERIFIED AMENDED PETITION FOR WRIT OF
MANDATE AND COMPLAINT FOR DECLARATORY R E L I E F .
12
4. DECLARATION OF MONA G. EBRAHIMI IN SUPPORT OF RESPONDENT
13 AND DEFENDANT CITY OF E L K GROVE'S DEMURRER TO PETITIONERS AND
PLAINTIFFS' VERIFIED AMENDED PETITION FOR WRIT OF MANDATE AND
14 COMPLAINT FOR DECLARATORY RELIEF.
15 5. RESPONDENT AND DEFENDANT CITY OF E L K GROVE'S REQUEST FOR
JUDICIAL NOTICE ON DEMURRER TO PETITIONERS AND PLAINTIFFS'
16 VERIFIED AMENDED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR
DECLARATORY RELIEF.
17
6. EX PARTE APPLICATION FOR LEAVE TO E X C E E D PAGE LIMIT FOR
18 RESPONDENT AND DEFENDANT CITY OF E L K GROVE'S MEMORANDUM OF
POINTS AND AUTHORITIES IN SUPPORT OF DEMURRER TO PETITIONERS AND
19 PLAINTIFFS' VERIFIED AMENDED PETITION FOR WRIT OF MANDATE AND
COMPLAINT FOR DECLARATORY RELIEF.
20
7. MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF EX
21 PARTE APPLICATION FOR LEAVE TO EXCEED PAGE LIMIT FOR RESPONDENT
AND DEFENDANT CITY OF E L K GROVE'S MEMORANDUM OF POINTS AND
22 AUTHORITIES IN SUPPORT OF DEMURRER TO PETITIONERS AND PLAINTIFFS'
VERIFIED AMENDED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR
23 DECLARATORY RELIEF.
24 8. DECLARATION OF MONA G. EBRAHIMI IN SUPPORT OF EX PARTE
APPLICATION FOR LEAVE TO EXCEED PAGE LIMIT FOR RESPONDENT AND
25 DEFENDANT CITY OF E L K GROVE'S MEMORANDUM OF POINTS AND
AUTHORITIES IN SUPPORT OF DEMURRER TO PETITIONERS AND PLAINTIFFS'
26 VERIFIED AMENDED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR
DECLARATORY RELIEF.
27
28
1565519.1 10784-236
PROOF OF SERVICE
1 9. [PROPOSED] ORDER GRANTING EX PARTE APPLICATION FOR LEAVE
TO EXCEED PAGE LIMIT FOR RESPONDENT AND DEFENDANT CITY OF ELK
2 GROVE'S MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF
DEMURRER TO PETITIONERS AND PLAINTIFFS' VERIFIED AMENDED PETITION
3 FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF,
on the interested parties in this action as follows:
4
SEE ATTACHED SERVICE LIST
5
BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the
6 document(s) to be sent from e-mail address emay@kmtg.com to the persons at the e-mail
addresses listed in the Service List. The document(s) were transmitted at or before 5:00 p.m. I did
7 not receive, within a reasonable time after the transmission, any electronic message or other
indication that the transmission was unsuccessful.
8
BY MAIL: I enclosed the document(s) in a sealed envelope or package addressed to the
9 persons at the addresses listed in the Service List and placed the envelope for collection and
mailing, following our ordinary business practices. I am readily familiar with the practice of
10 Kronick, Moskovitz, Tiedemann «fe Girard for collecting and processing correspondence for
mailing. On the same day that correspondence is placed for collection and mailing, it is deposited
11 in the ordinary course of business with the United States Postal Service, in a sealed envelope with
postage fiilly prepaid. I am a resident or employed in the county where the mailing occurred. The
12 envelope was placed in the mail at Sacramento, Caiifomia.
13 I declare under penalty of perjury under the laws of the State of Caiifomia that the
foregoing is tme and correct.
14
Executed on May 3, 2017, at Sacramento, Caiifomia.
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1565519.1 10784-236
PROOF OF SERVICE
SERVICE LIST
2 Brigit S. Barnes Jonathan P. Hobbs, City Attomey
Aimie R. Embree Jennifer A. Alves, Asst. City Attomey
3 Brigit S. Bames & Associates, Inc. Suzanne Kermedy, Asst. City Attomey
3262 Penryn Road City of Elk Grove
4 Loomis, CA 95650 Office of the City Attomey
Telephone: (916) 660-9555 8401 Laguna Palms Way
5 Facsimile: (916)660-9554 Elk Grove, CA 95758
Email: bsbames(a),landlawbybames.com Telephone: (916) 683-7111
6 arembree@landlawbvbarnes.com Facsimile: (916)627-4100
Email: jhobbs(g),elkgrovecity.org
7 Attorneys for Petitioners and Plaintiffs jalves@elkgrovecitv.org
skennedv@elkgrovecitv.org
8
Attorneys for Respondent and
9 Defendant
10 Scott M. Pearson
Taylor R. Steinbacher
11 Zaven A. Sargsian
Ballard Spahr LLP
12 2029 Century Park East, Suite 800
Los Angeles, CA 90067-2909
13 Telephone: (424) 204-4323
Facsimile: (424) 204-4350
14 Email: pearsons@ballardspahr.com
steinbachert@ballardspahr.com
15 sargsianz@ballardspahr.com
16 Attorneys for Real Parties in Interest and
Defendants
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1565519.1 10784-236
PROOF OF SERVICE
Preview
[Exempt From Filing Fee Government Code § 6103] 1 MONA G. EBRAHIMI, State Bar No. 236550 mebrahirni@kmtg.com 2 LESLIE Z. WALKER, State Bar No., 249310 lwalker@kmtg. com ^^^NDORSED 3 KRONICK, MOSKOVITZ, TIEDEMANN & GIRARD A Professional Corporation 4 400 Capitol Mall, 27^^ Floor MAY -3 2017 Sacramento, California 95814 5 Telephone: (916) 321-4500 ByJ.Zgi Facsimile: (916) 321-4555 eiTSDeputy Clerk 6 JONATHAN P. HOBBS, State Bar No. 186045 7 City Attomey jhobbs(^elkgrovecity.org 8 JENNIFER A. ALVES, State Bar No. 238723 Assistant City Attomey 9 jalves(^elkgrovecity.org SUZANNE E. KENNEDY, State Bar No. 251339 10 Assistant City Attomey skennedy@elkgrovecity.org 11 CITY OF ELK GROVE Office of the City Attomey 12 8401 Laguna Palms Way Elk Grove, Caiifomia 95758 13 Telephone: (916)683-7111 Facsimile: (916)627-4100 14 Attomeys for'Respondent and Defendant CITY 15 OF ELK GROVE 16 SUPERIOR COURT OF THE STATE OF CALIFORNIA 17 COUNTY OF SACRAMENTO 18 STAND UP CALIFORNIA!; PATTY Case No. 34-2016-80002493 JOHNSON; and JOE TEIXEIRA, 19 Petitioners and Plaintiffs, 20 PROOF OF SERVICE V. 21 CITY OF ELK GROVE, 22 Case Filed: November 23,2016 Respondent and Defendant. 23 ELK GROVE TOWN CENTER, LP; 24 HOWARD HUGHES CORPORATION; and DOES 1-20, 25 Real Parties in Interest and 26 Defendants. 27 28 1 PROOF OF SERVICE PROOF OF SERVICE 2 STATE OF CALIFORNIA, COUNTY OF SACRAMENTO 3 At the time of service, I was over 18 years of age and not a party to this action. I am employed in the County of Sacramento, State of Caiifomia. My business address is 400 Capitol 4 Mall, 27th Floor, Sacramento, CA 95814. 5 On May 3, 2017,1 served tme copies of the following document(s) described as 6 1. NOTICE OF MOTION AND MOTION ON RESPONDENT AND DEFENDANT CITY OF E L K GROVE'S DEMURRER TO PETITIONERS AND PLAINTIFFS' 7 VERIFIED AMENDED PETITION FOR WRIT OF MANDATE AND COMPLAINT. 8 2. RESPONDENT AND DEFENDANT CITY OF E L K GROVE'S DEMURRER TO PETITIONERS AND PLAINTIFFS' VERIFIED AMENDED PETITION FOR WRIT OF 9 MANDATE AND COMPLAINT FOR DECLARATORY R E L I E F . 10 3. MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF RESPONDENT AND DEFENDANT CITY OF E L K GROVE'S DEMURRER TO 11 PETITIONERS AND PLAINTIFFS' VERIFIED AMENDED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY R E L I E F . 12 4. DECLARATION OF MONA G. EBRAHIMI IN SUPPORT OF RESPONDENT 13 AND DEFENDANT CITY OF E L K GROVE'S DEMURRER TO PETITIONERS AND PLAINTIFFS' VERIFIED AMENDED PETITION FOR WRIT OF MANDATE AND 14 COMPLAINT FOR DECLARATORY RELIEF. 15 5. RESPONDENT AND DEFENDANT CITY OF E L K GROVE'S REQUEST FOR JUDICIAL NOTICE ON DEMURRER TO PETITIONERS AND PLAINTIFFS' 16 VERIFIED AMENDED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF. 17 6. EX PARTE APPLICATION FOR LEAVE TO E X C E E D PAGE LIMIT FOR 18 RESPONDENT AND DEFENDANT CITY OF E L K GROVE'S MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF DEMURRER TO PETITIONERS AND 19 PLAINTIFFS' VERIFIED AMENDED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF. 20 7. MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF EX 21 PARTE APPLICATION FOR LEAVE TO EXCEED PAGE LIMIT FOR RESPONDENT AND DEFENDANT CITY OF E L K GROVE'S MEMORANDUM OF POINTS AND 22 AUTHORITIES IN SUPPORT OF DEMURRER TO PETITIONERS AND PLAINTIFFS' VERIFIED AMENDED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR 23 DECLARATORY RELIEF. 24 8. DECLARATION OF MONA G. EBRAHIMI IN SUPPORT OF EX PARTE APPLICATION FOR LEAVE TO EXCEED PAGE LIMIT FOR RESPONDENT AND 25 DEFENDANT CITY OF E L K GROVE'S MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF DEMURRER TO PETITIONERS AND PLAINTIFFS' 26 VERIFIED AMENDED PETITION FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF. 27 28 1565519.1 10784-236 PROOF OF SERVICE 1 9. [PROPOSED] ORDER GRANTING EX PARTE APPLICATION FOR LEAVE TO EXCEED PAGE LIMIT FOR RESPONDENT AND DEFENDANT CITY OF ELK 2 GROVE'S MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF DEMURRER TO PETITIONERS AND PLAINTIFFS' VERIFIED AMENDED PETITION 3 FOR WRIT OF MANDATE AND COMPLAINT FOR DECLARATORY RELIEF, on the interested parties in this action as follows: 4 SEE ATTACHED SERVICE LIST 5 BY E-MAIL OR ELECTRONIC TRANSMISSION: I caused a copy of the 6 document(s) to be sent from e-mail address emay@kmtg.com to the persons at the e-mail addresses listed in the Service List. The document(s) were transmitted at or before 5:00 p.m. I did 7 not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful. 8 BY MAIL: I enclosed the document(s) in a sealed envelope or package addressed to the 9 persons at the addresses listed in the Service List and placed the envelope for collection and mailing, following our ordinary business practices. I am readily familiar with the practice of 10 Kronick, Moskovitz, Tiedemann «fe Girard for collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited 11 in the ordinary course of business with the United States Postal Service, in a sealed envelope with postage fiilly prepaid. I am a resident or employed in the county where the mailing occurred. The 12 envelope was placed in the mail at Sacramento, Caiifomia. 13 I declare under penalty of perjury under the laws of the State of Caiifomia that the foregoing is tme and correct. 14 Executed on May 3, 2017, at Sacramento, Caiifomia. 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1565519.1 10784-236 PROOF OF SERVICE SERVICE LIST 2 Brigit S. Barnes Jonathan P. Hobbs, City Attomey Aimie R. Embree Jennifer A. Alves, Asst. City Attomey 3 Brigit S. Bames & Associates, Inc. Suzanne Kermedy, Asst. City Attomey 3262 Penryn Road City of Elk Grove 4 Loomis, CA 95650 Office of the City Attomey Telephone: (916) 660-9555 8401 Laguna Palms Way 5 Facsimile: (916)660-9554 Elk Grove, CA 95758 Email: bsbames(a),landlawbybames.com Telephone: (916) 683-7111 6 arembree@landlawbvbarnes.com Facsimile: (916)627-4100 Email: jhobbs(g),elkgrovecity.org 7 Attorneys for Petitioners and Plaintiffs jalves@elkgrovecitv.org skennedv@elkgrovecitv.org 8 Attorneys for Respondent and 9 Defendant 10 Scott M. Pearson Taylor R. Steinbacher 11 Zaven A. Sargsian Ballard Spahr LLP 12 2029 Century Park East, Suite 800 Los Angeles, CA 90067-2909 13 Telephone: (424) 204-4323 Facsimile: (424) 204-4350 14 Email: pearsons@ballardspahr.com steinbachert@ballardspahr.com 15 sargsianz@ballardspahr.com 16 Attorneys for Real Parties in Interest and Defendants 17 18 19 20 21 22 23 24 25 26 27 28 1565519.1 10784-236 PROOF OF SERVICE