On January 25, 2019 a
Stipulation,Agreement
was filed
involving a dispute between
California Fire Protection Coalition,
Del Toro Trejo, Juan Carlos,
Filed By: Fire Guard Corporation,
Fire Guard Corporation,
Shahangian, Bahman Brian,
and
California Department Of Forestry And Fire Protection,
California Office Of The State Fire Marshal,
Dennis Mathisen In His Official Capacity As State Fire Marshal,
Does 1-10,
Jeffery Schwartz In His Official Capacity As Deputy State Fire Marshall,
Mike Richwine In His Official Capacity As State Fire Marshal,
for (Civil Rights/Discrimination)
in the District Court of Sacramento County.
Preview
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1 TIMOTHY V. KASSOUNI, SBN 142907
KASSOUNI LAW 2019 APR 19 AH 9:1*5
2 621 Capitol Mall, Suite 2025
3 Sacramento, CA 95814
Telephone: (916)930-0030
4 Facsimile: (916)930-0033
E-Mail: Tunothy@KassouniIaw.com
5
Attorneys for Plaintiffs Fire Guard Corporation, Bahman Brian Shahangian, and Califomia Fire
6 Protection Coalition
7
SUPERIOR COURT OF THE STATE OF CALIFORNIA
CITY AND COUNTY OF SACRAMENTO
o 10
9
o FERE GUARD CORPORATION; Case No: 34-2019-00249221 -CU-CR-GDS
PROTECTION COALITION, a Califomia PLAINTIFFS' FIRST AMENDED
J w ^
13 Corporation, COMPLAINT AND FOR THE FILING OF
? =3 4(JU
•
O ^€ o THE RESPONSE THERETO
CO ^ C 14 Plaintifife,
"'^ 1 os 15 BY FAX
— M I
o 16
CALIFORNIA DEPARTMENT OF
(2 17 FORESTRY AND FIRE PROTECTION;
CALIFORNIA OFFICE OF THE STATE
18 FIRE MARSHAL; DENNIS MATHISEN, in
19 his o£Gcial edacity as State Fire Marshal;
JEFFERY SCHWARTZ, in his ofBcial
20 cJ5)acity as Deputy State Fire Marshall; and
DOES 1-10, inclusive,
21
22 Defendants.
23
24
25
26
27
28
STIPULATION
1 Pursuant to Califomia Rules of Court, Rule 3.110, subd.(e), Plaintiffs Fire Guard
2 Corporation, Bahman Brian Shahangian, and Califomia Fire Protection Coalition (Plaintiffs),
and Defendants Califomia Department of Forestry and Fire Protection, Califomia Office of the
State Fire Marshal, and Jeffer>' Schwartz (Defendants), do hereby stipulate that the Court grant
5 leave as follows in light of the communications between their respective counsel regarding the
6 filing of a First Amended Complaint:
7 1. That Plaintiffs be granted leave to file on or before May 2. 2019 a First Amended
8 Complaint in the above-entitled matter;
9 2. That Defendants be granted leave to file a response within 30 days of serxHce of the
O
10 First Amended Complaint.
o
IT, 11
IN — vo
^ w 12 DATED: April 17,2019 KASSOUNI LAW
< "5 o ^
if S 13
2 I <= * 14
T H ^ T y ^ i ^ KASSOUNI
O - c 2 Attomeys for Plaintiffs
52 -5, i §
-CN Ji?s\o^
15
VO
16 DATED: April 17,2019 XAVIER BECERRA
Attomey General of Califomia
17 TRACY L. WINSOR
18 Supervising Deputy Attomey General
19 By:
COURTNEYjPOVINGl
20 Attomeys for Defendants Califomia Department of
21 Forestry- and Fire Protection, Califomia Office of
the State Fire Marshal, and Jeffer}- Schwartz
22
23 The above Stipulation is approved and ordered.
24
25 Dated: APR 1 9 2019
26 Judge of the Superior Court
DAVID I. EROWN
27
28
-2-
STIPULATION
1 PROOF OF SERVICE
2
I am employed in the Coimty of Sacramento, State of Califomia. I am over the age of 18
3
years and not a party to the v«thin action. My business address is 621 Capitol Mall, Suite 2025,
4
Sacramento, CA 95814. On the date indicated below I served via U.S. Mail, in a sealed envelope
5
with postage prepaid, a copy of the following:
6
7 STIPULATION FOR THE FILING OF PLAINTIFFS' FIRST AMENDED COMPLAINT
AND FOR THE FILING OF THE RESPONSE THERETO
8
9 Courtney S. Covington
• < ^ «^
0 Office of the Attomey General
13001 street
o 1 Sacramento, CA 95814
> tN 00
2
I declare under penalty of perjury under the laws of the State of Califomia that the
- =3 < 3
Z 73 O
foregoing is tme and correct.
5 So 4
S 28 Executed at Sacramento, California, on April 17,2019.
5
6
f2 7 TIMOfHY'V. KASSOUNI
8
9
20
21
22
23
24
25
26
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Proof of Service
Document Filed Date
April 19, 2019
Case Filing Date
January 25, 2019
Category
(Civil Rights/Discrimination)
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Preview
'•:-:s • 1 TIMOTHY V. KASSOUNI, SBN 142907 KASSOUNI LAW 2019 APR 19 AH 9:1*5 2 621 Capitol Mall, Suite 2025 3 Sacramento, CA 95814 Telephone: (916)930-0030 4 Facsimile: (916)930-0033 E-Mail: Tunothy@KassouniIaw.com 5 Attorneys for Plaintiffs Fire Guard Corporation, Bahman Brian Shahangian, and Califomia Fire 6 Protection Coalition 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA CITY AND COUNTY OF SACRAMENTO o 10 9 o FERE GUARD CORPORATION; Case No: 34-2019-00249221 -CU-CR-GDS PROTECTION COALITION, a Califomia PLAINTIFFS' FIRST AMENDED J w ^ 13 Corporation, COMPLAINT AND FOR THE FILING OF ? =3 4(JU • O ^€ o THE RESPONSE THERETO CO ^ C 14 Plaintifife, "'^ 1 os 15 BY FAX — M I o 16 CALIFORNIA DEPARTMENT OF (2 17 FORESTRY AND FIRE PROTECTION; CALIFORNIA OFFICE OF THE STATE 18 FIRE MARSHAL; DENNIS MATHISEN, in 19 his o£Gcial edacity as State Fire Marshal; JEFFERY SCHWARTZ, in his ofBcial 20 cJ5)acity as Deputy State Fire Marshall; and DOES 1-10, inclusive, 21 22 Defendants. 23 24 25 26 27 28 STIPULATION 1 Pursuant to Califomia Rules of Court, Rule 3.110, subd.(e), Plaintiffs Fire Guard 2 Corporation, Bahman Brian Shahangian, and Califomia Fire Protection Coalition (Plaintiffs), and Defendants Califomia Department of Forestry and Fire Protection, Califomia Office of the State Fire Marshal, and Jeffer>' Schwartz (Defendants), do hereby stipulate that the Court grant 5 leave as follows in light of the communications between their respective counsel regarding the 6 filing of a First Amended Complaint: 7 1. That Plaintiffs be granted leave to file on or before May 2. 2019 a First Amended 8 Complaint in the above-entitled matter; 9 2. That Defendants be granted leave to file a response within 30 days of serxHce of the O 10 First Amended Complaint. o IT, 11 IN — vo ^ w 12 DATED: April 17,2019 KASSOUNI LAW < "5 o ^ if S 13 2 I <= * 14 T H ^ T y ^ i ^ KASSOUNI O - c 2 Attomeys for Plaintiffs 52 -5, i § -CN Ji?s\o^ 15 VO 16 DATED: April 17,2019 XAVIER BECERRA Attomey General of Califomia 17 TRACY L. WINSOR 18 Supervising Deputy Attomey General 19 By: COURTNEYjPOVINGl 20 Attomeys for Defendants Califomia Department of 21 Forestry- and Fire Protection, Califomia Office of the State Fire Marshal, and Jeffer}- Schwartz 22 23 The above Stipulation is approved and ordered. 24 25 Dated: APR 1 9 2019 26 Judge of the Superior Court DAVID I. EROWN 27 28 -2- STIPULATION 1 PROOF OF SERVICE 2 I am employed in the Coimty of Sacramento, State of Califomia. I am over the age of 18 3 years and not a party to the v«thin action. My business address is 621 Capitol Mall, Suite 2025, 4 Sacramento, CA 95814. On the date indicated below I served via U.S. Mail, in a sealed envelope 5 with postage prepaid, a copy of the following: 6 7 STIPULATION FOR THE FILING OF PLAINTIFFS' FIRST AMENDED COMPLAINT AND FOR THE FILING OF THE RESPONSE THERETO 8 9 Courtney S. Covington • < ^ «^ 0 Office of the Attomey General 13001 street o 1 Sacramento, CA 95814 > tN 00 2 I declare under penalty of perjury under the laws of the State of Califomia that the - =3 < 3 Z 73 O foregoing is tme and correct. 5 So 4 S 28 Executed at Sacramento, California, on April 17,2019. 5 6 f2 7 TIMOfHY'V. KASSOUNI 8 9 20 21 22 23 24 25 26 27 28 Proof of Service