On May 27, 2021 a
Party Discovery
was filed
involving a dispute between
Cirillo, Catherine,
and
All City Management Services, Inc.,
Does 1-100,
Kalifornia Business Staffing, Inc.,
Kbs Staffing,
Patton, Sherri,
Personnel Staffing Group Llc,
for Wrongful Termination Unlimited
in the District Court of San Bernardino County.
Preview
. . . SUP
F LEDl
Nlck Ladln-Slenne (SBN 322071) CoEtfi‘Scfigggm CALIFORNIA
3E
SAN BERNARDINO
nick@ascent-employmentlaw.com ggfii‘fio
Ascent Law, PC
"'"
6130 Oswego Street
S.
L
I
Q 11'} * -"" w- MAR 1 5 2023
Greenwood Village, CO 80111‘
h AH“:
\OWNOUIADJNI—I
T: 978.457.5918
BY. .
Cesar
W R. Lep ,
Deputy
Attorneys for Defendants ALL CITY
MANAGEMENT SERVICES, INC. and
SHERI PATTON
flaxvzl
SUPERIOR COURT 0F THE STATE 0F CALIFORNIA
COUNTY 0F SAN BERNARDINO
p—t
CATHERINE CIRILLO, Case No. CIVSB 2115237
1
Plaintiff, EX PARTE APPLICATION FOR ORDER
SHORTENING TIME T0 HEAR APPLICATION
PC
vs. FOR ADMISSION 0F COLIN L. BARNACLE T0
THE BAR 0F THIS COURT PRO HAC VICE;
Law,
ALL CITY MANAGEMENT SERVICES, INC., MEMORANDUM 0F POINTS AND AUTHORI-
Ascent
PERSONNEL STAFFING GROUP LLC, KBS TIES; [PR0P0SED]ORDER
STAFFING, SHERRI PATTON, and DOES 1
Np—II—‘g—np—Ip—nn—IHp—I
through 100, inclusive, NOTICE 0F REMOTE APPEARANCE
Defendants. [Declaration of Nick Ladin-Sienne filed con-
currently]
ooqom-nmwflooooxloxMAmNSO
Hearing Date: March 16, 2023
Time: 8:30 a.m.
Dept.: 527
Judge: Hon. Thomas S. Garza
Complaint: June 7, 2021
Trial Date: May 15, 2023
NNNNNNN
Defendants’ Ex Parte Application for Order Shortening Time on
Application for Admission of Colin L. Barnacle Pro Hac Vice
NOTICE 0F EX PARTE APPLICATION FOR AN ORDER CONTINUING TRIAL
TO ALL PARTIES AND THEIR COUNSEL OF RECORD:
PLEASE TAKE NOTICE that on March 16, 2023, at 8:30 a.m., the matter will be heard by
remote means only in Department $27 of the above-entitled court, located at 247 West Third Street
©WNOU1¥OJNH
in San Bernardino, California, Defendants A11 City Management Services, Inc. (“M”) and Sheri
Patton (“Ping”), appearing telephonically, Will apply to the Court for an order shortening the time
to hear the Application for Admission of Colin L. Barnacle to the Bar of this Court Pro Hac Vice on
behalf of All City and Patton.
This ex parte application and the related application for admission are based upon Cal. Rules
p—A
of Court, rule 9.40 (c)(l) and rule 3.1300(b), which provides that the Superior Court has authority t0
prescribe a shorter period of notice for such a hearing.
p—A
This application is further based on this notice, the attached Memorandum of Points and Au-
PC
thorities, the Declaration of Nick Ladin-Sienne filed herewith, the records and files in this action, and
Law,
on such further evidence and argument as may be presented before or at the time of hearing on the
Ascent
application, if any.
Respectfully submitted,
M
Nr—Ir—lp—AHHH
Dated: March 15, 2023 ASCENT LAW, PC
oouoxm-anb’ooooxncxmA'SNEO
By: Z—m
Nick Ladin-Sienne
Attorneys for ALL CITY MANAGEMENT SER—
VICES, INC. and SHERI PATTON
NNNNNNN
Ex Parte Application to Shorten Time CIVSB2115237
for Barnacle Application for Admission
Document Filed Date
March 15, 2023
Case Filing Date
May 27, 2021
Category
Wrongful Termination Unlimited
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. . . SUP F LEDl Nlck Ladln-Slenne (SBN 322071) CoEtfi‘Scfigggm CALIFORNIA 3E SAN BERNARDINO nick@ascent-employmentlaw.com ggfii‘fio Ascent Law, PC "'" 6130 Oswego Street S. L I Q 11'} * -"" w- MAR 1 5 2023 Greenwood Village, CO 80111‘ h AH“: \OWNOUIADJNI—I T: 978.457.5918 BY. . Cesar W R. Lep , Deputy Attorneys for Defendants ALL CITY MANAGEMENT SERVICES, INC. and SHERI PATTON flaxvzl SUPERIOR COURT 0F THE STATE 0F CALIFORNIA COUNTY 0F SAN BERNARDINO p—t CATHERINE CIRILLO, Case No. CIVSB 2115237 1 Plaintiff, EX PARTE APPLICATION FOR ORDER SHORTENING TIME T0 HEAR APPLICATION PC vs. FOR ADMISSION 0F COLIN L. BARNACLE T0 THE BAR 0F THIS COURT PRO HAC VICE; Law, ALL CITY MANAGEMENT SERVICES, INC., MEMORANDUM 0F POINTS AND AUTHORI- Ascent PERSONNEL STAFFING GROUP LLC, KBS TIES; [PR0P0SED]ORDER STAFFING, SHERRI PATTON, and DOES 1 Np—II—‘g—np—Ip—nn—IHp—I through 100, inclusive, NOTICE 0F REMOTE APPEARANCE Defendants. [Declaration of Nick Ladin-Sienne filed con- currently] ooqom-nmwflooooxloxMAmNSO Hearing Date: March 16, 2023 Time: 8:30 a.m. Dept.: 527 Judge: Hon. Thomas S. Garza Complaint: June 7, 2021 Trial Date: May 15, 2023 NNNNNNN Defendants’ Ex Parte Application for Order Shortening Time on Application for Admission of Colin L. Barnacle Pro Hac Vice NOTICE 0F EX PARTE APPLICATION FOR AN ORDER CONTINUING TRIAL TO ALL PARTIES AND THEIR COUNSEL OF RECORD: PLEASE TAKE NOTICE that on March 16, 2023, at 8:30 a.m., the matter will be heard by remote means only in Department $27 of the above-entitled court, located at 247 West Third Street ©WNOU1¥OJNH in San Bernardino, California, Defendants A11 City Management Services, Inc. (“M”) and Sheri Patton (“Ping”), appearing telephonically, Will apply to the Court for an order shortening the time to hear the Application for Admission of Colin L. Barnacle to the Bar of this Court Pro Hac Vice on behalf of All City and Patton. This ex parte application and the related application for admission are based upon Cal. Rules p—A of Court, rule 9.40 (c)(l) and rule 3.1300(b), which provides that the Superior Court has authority t0 prescribe a shorter period of notice for such a hearing. p—A This application is further based on this notice, the attached Memorandum of Points and Au- PC thorities, the Declaration of Nick Ladin-Sienne filed herewith, the records and files in this action, and Law, on such further evidence and argument as may be presented before or at the time of hearing on the Ascent application, if any. Respectfully submitted, M Nr—Ir—lp—AHHH Dated: March 15, 2023 ASCENT LAW, PC oouoxm-anb’ooooxncxmA'SNEO By: Z—m Nick Ladin-Sienne Attorneys for ALL CITY MANAGEMENT SER— VICES, INC. and SHERI PATTON NNNNNNN Ex Parte Application to Shorten Time CIVSB2115237 for Barnacle Application for Admission