On January 07, 2020 a
Peremptory Challenge Under CCP 170.6 Filed - PEREMPTORY CHALLENGE UNDER CCP 170.6 AS TO DAVID COHN.
was filed
involving a dispute between
Zhang, Meijuan,
Zhang, Shilun,
and
Eccp, Inc A California Corporation,
Ecpp Inc.,
Gong, Guduan,
Gong, Haixia,
Gong, Zhigang,
Liu, Dan,
Zhao, Jerry,
for Employment-Other-Complex
in the District Court of San Bernardino County.
Preview
SAM X J WU SBN 183098
RONALD Z GOMEZ SBN 229708
VICTOR RUSSAME SBN 236851
2 LAW OFFICES OF SAM X J WU APC
8600 Utica Ave Building 100 SUPERIORouR
3 Rancho Cucamonga CA 91730
COUNTYOFSqNpE
Sp N BERN ARDINO
4RDINp STRICT
TEL 626 588 2388
AN 1
4 FAX 626 656 8088 2020
EMAIL ron lawofficeofsamwu com
5 Attorneys for laintiffs SHILUN ZHANG and By
MEIJUAN ZHANG p AN A
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Q 6
EPU1y
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s SUPERIOR COURT OF THE STATE OF CALIFORNIA
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ci 9 COUNTY OF SAN BERNARDINO
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o SHILUN ZHANG individual and MEIJUAN Case No CIVDS2000417
an
ZHANG an individual on behalf of themselves
11
0 and all similarly situated current and former
pLAINTIFFS NOTICE OF MOTION AND
employees
12
MOTION TO DISQUALIFY THE
HONORABLE DAVID COHN UPON
m 3 Plaintiffs
PEREMPTORY CHALLENGE
14 PURSUANT TO C C P 170 6
y MEMORANDUM OF POINTS AND
15
ECCP INC a California Corporation ZHIGANG AUTHORITIES IN SUPPORT
GONG an individual GUDUAN GONG aka
DECLARATION OF RONALD Z GOMEZ
16
IN SUPPORT
GORDON GONG an individual HAIXIA GONG
Q 7 an individual JERRY ZHAO an individual DAN
LIU an individual and DOES 1 through 20
inclusive
X
19
Defendants
20
0
2
Date Filed January 7 2020
0
22
TO THE CLERK OF THE COURT THE HONORABLE JUDGE OF THE ABOVE
J
23
ENTITLED COURT AND TO ALL PART IES AND THEIR COUNSEL OF RECORD IF ANY
24
PLEASE TAKE NOTICE that Plaintiffs SHILUN ZHANG and MEIJUAN ZHANG
25
hereinafter collectively referred to as Plaintiffs by and through their attorneys of record
26
hereby move pursuant to Code of Civil Procedure section 170 6 a 2 to disqualify the
27
Honorable David Cohn Judge of the Superior Court of the State of California County of San
2s
1
PLAINTIFFS NOTICE OF MOTION AND MOTION TO DISQUALIFY THE HONORABLE
DAVID COHN UPON PEREMPTORY CHALLENGE PURSUANT TO C C P 170 6
or trial in this Pfaintiffs
any further proceeding action
Bernardino from presiding at hearing
2 make this motion on the ground that the Judge the Honorable David Cohn is prejudiced
3 against Plaintiffs their attorneys or their or their attorneys interests such that Plaintiffs
4 believe they cannot have a fair and impartial hearing or trial before the Judge the Honorable
5 David Cohn See Declaration of Ronald Z Gomez Gomez Decl at 6 Plaintiffs have not
Q6 previously filed a peremptory challenge under Code Civ Proc 170 6 in this action Gomez
U
Decl at 5 This Motion and the supporting Declaration are presented well within the statutory
8 period of Plaintiffs having received notice of Judge Cohn s all purpose assignment when the
U
s assignment was ordered on January 7 2020
0
o This Motion is based on Code of Civil Procedure section 170 6 the matters contained
0 11 herein the attached Memorandum of Points and Authorities the attached Declaration of
0
2 Ronald Z Gomez all pleadings and papers on file in this and any related action and any
m
a
13 argument of counsel that may be presented in court
Dated January 9 2020
U 14 LAW FFICES OF SA X J WU APC
15
0
o
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16
a 17 R NALD Z GO EZ
VI TOR RUSSAME
At orneys for Plaintiffs
SHILUN ZHANG and MEIJUAN ZHANG
X 19
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3 22
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23
24
25
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2
PLAINTIFFS NOTICE OF MOTION AND MOTION TO DISQUALIFY THE HONORABLE
DAVID COHN UPON PEREMPTORY CHALLENGE PURSUANT TO C C P 170 6
Document Filed Date
January 10, 2020
Case Filing Date
January 07, 2020
Category
Employment-Other-Complex
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Preview
SAM X J WU SBN 183098 RONALD Z GOMEZ SBN 229708 VICTOR RUSSAME SBN 236851 2 LAW OFFICES OF SAM X J WU APC 8600 Utica Ave Building 100 SUPERIORouR 3 Rancho Cucamonga CA 91730 COUNTYOFSqNpE Sp N BERN ARDINO 4RDINp STRICT TEL 626 588 2388 AN 1 4 FAX 626 656 8088 2020 EMAIL ron lawofficeofsamwu com 5 Attorneys for laintiffs SHILUN ZHANG and By MEIJUAN ZHANG p AN A nR Q 6 EPU1y U c 7 m s SUPERIOR COURT OF THE STATE OF CALIFORNIA o U ci 9 COUNTY OF SAN BERNARDINO 0 o SHILUN ZHANG individual and MEIJUAN Case No CIVDS2000417 an ZHANG an individual on behalf of themselves 11 0 and all similarly situated current and former pLAINTIFFS NOTICE OF MOTION AND employees 12 MOTION TO DISQUALIFY THE HONORABLE DAVID COHN UPON m 3 Plaintiffs PEREMPTORY CHALLENGE 14 PURSUANT TO C C P 170 6 y MEMORANDUM OF POINTS AND 15 ECCP INC a California Corporation ZHIGANG AUTHORITIES IN SUPPORT GONG an individual GUDUAN GONG aka DECLARATION OF RONALD Z GOMEZ 16 IN SUPPORT GORDON GONG an individual HAIXIA GONG Q 7 an individual JERRY ZHAO an individual DAN LIU an individual and DOES 1 through 20 inclusive X 19 Defendants 20 0 2 Date Filed January 7 2020 0 22 TO THE CLERK OF THE COURT THE HONORABLE JUDGE OF THE ABOVE J 23 ENTITLED COURT AND TO ALL PART IES AND THEIR COUNSEL OF RECORD IF ANY 24 PLEASE TAKE NOTICE that Plaintiffs SHILUN ZHANG and MEIJUAN ZHANG 25 hereinafter collectively referred to as Plaintiffs by and through their attorneys of record 26 hereby move pursuant to Code of Civil Procedure section 170 6 a 2 to disqualify the 27 Honorable David Cohn Judge of the Superior Court of the State of California County of San 2s 1 PLAINTIFFS NOTICE OF MOTION AND MOTION TO DISQUALIFY THE HONORABLE DAVID COHN UPON PEREMPTORY CHALLENGE PURSUANT TO C C P 170 6 or trial in this Pfaintiffs any further proceeding action Bernardino from presiding at hearing 2 make this motion on the ground that the Judge the Honorable David Cohn is prejudiced 3 against Plaintiffs their attorneys or their or their attorneys interests such that Plaintiffs 4 believe they cannot have a fair and impartial hearing or trial before the Judge the Honorable 5 David Cohn See Declaration of Ronald Z Gomez Gomez Decl at 6 Plaintiffs have not Q6 previously filed a peremptory challenge under Code Civ Proc 170 6 in this action Gomez U Decl at 5 This Motion and the supporting Declaration are presented well within the statutory 8 period of Plaintiffs having received notice of Judge Cohn s all purpose assignment when the U s assignment was ordered on January 7 2020 0 o This Motion is based on Code of Civil Procedure section 170 6 the matters contained 0 11 herein the attached Memorandum of Points and Authorities the attached Declaration of 0 2 Ronald Z Gomez all pleadings and papers on file in this and any related action and any m a 13 argument of counsel that may be presented in court Dated January 9 2020 U 14 LAW FFICES OF SA X J WU APC 15 0 o 00 16 a 17 R NALD Z GO EZ VI TOR RUSSAME At orneys for Plaintiffs SHILUN ZHANG and MEIJUAN ZHANG X 19 c 0 20 21 O 3 22 c J 23 24 25 26 27 28 2 PLAINTIFFS NOTICE OF MOTION AND MOTION TO DISQUALIFY THE HONORABLE DAVID COHN UPON PEREMPTORY CHALLENGE PURSUANT TO C C P 170 6