Document for MICHAEL RAHNI VS SANTA MONICA COMMUNITY COLLEGE DISTRICT

• 
• 

						
                                
Preview
                                I   LOUIS R. DUMONT - State Bar No. 130198
     JOHNNY RUNDELL - State Bar No. 289480
2    CARPENTER, ROTHANS & DUMONT LLP
3    500 South Grand Avenue, 19 th Floor
     Los Angeles, CA 90071                                     FEE EXEMPT
4    (213) 228-0400
     (213) 228-0401 [Fax]                                   GOV'T CODE§ 6103
5    ldumont@crdlaw.com I jrundell@crdlaw.com
6    Attorneys for Defendant, SANTA MONICA COMMUNITY COLLEGE DISTRICT, a public
     entity
 7

 8                     SUPERIOR COURT OF THE STATE OF CALIFORNIA

 9                      COUNTY OF LOS ANGELES - CENTRAL DISTRICT

10

11   MICHAEL RAHN!,                                  ) Case No. !9STCV04338
                                                     ) [Assigned to the Hon. Mel Red Recana, Dept.
12                 Plaintiff,                        ) 45]

                                                     ~
     V.
13                                                       EX PARTE APPLICATION FOR
     SANTA MONICA COMMUNITY COLLEGE)
     DISTRICT, and DOES I to 25, inclusive, )            CONTINUANCE OF THE FSC AND
14                                                       TRIAL DATES, AND RELATED DATES;
                                            )
                 Defendants.                )            MEMORANDUM OF POINTS AND
15                                                       AUTHORITIES; DECLARATION OF
                                            )
                                            )            JOHNNY RUNDELL
16
                                            )
17                                          )            Trial Date:              May 4, 2020
                                            )            Final Status Conference: April 28, 2020
18                                          )
                                            )
19                                          )
                                            )            Complaint Filed: February 8, 2019
20

21          PLEASE TAKE NOTICE that on January 17, 2020, at 8:30 a.m., or as soon thereafter as
22   counsel may be heard, in Department "45" of the above-entitled court located at 111 North Hill
23   Street, Los Angeles, California 90012, Defendant, SANTA MONICA COMMUNITY COLLEGE
24   DISTRICT ("SMCCD"), a public entity, will apply, Ex Parte, before this Honorable Court for an
25   Order continuing the Final Status Conference [currently scheduled for April 28, 2020] and Trial
26   Date [currently scheduled for May 4, 2020] to dates convenient for this Court and the parties in
27   early October of 2020. Good cause exists for this request for the following reasons:
28          I.      The present lawsuit arises out of allegations that Plaintiff, Michael Rahni, a former


                                                     -I-
                           EX PARTE APPLICATION FOR CONTINUANCE OF THE FSC
                                     AND TRIAL AND RELATED DA TES