EX PARTE APPLICATION FOR ORDER SHORTENING TIME AND REQUEST TO SPECIALLY SET DEFENDANT STATE OF CALIFORNIA, DEPARTMENT OF TRANSPORTATIONS MOTION TO COMPEL THE DEPOSITIONS OF PLAINTIFFS NONRETAINED EXPERT WITNESSES DR. BADGER AND DR. HARRIS; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF ROSEMARY LOVE IN SUPPORT - Sz Huang et al vs Tesla Inc. et al

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On April 26, 2019 an other pi/pd/wd unlimited (23) case was filed by Ching Fen Huang, Hsi Keng Huang, Hsi Keng Huang et al. represented by B. Mark Fong, and Doris Cheng, against Tesla Inc., Tesla, Inc., and The State Of California, Department Of Transportation, represented by Daniel C Posner, Landa Siu Low, Rosemary Iola Love, and Vincent Galvin, in the jurisdiction of Santa Clara County. Judge Sunil R. Kulkarni presiding.

                        
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ERIN E. HOLBROOK, Chief Counsel
G. MICHAEL HARRINGTON, Deputy Chief Counsel
LANDA LOW, Deputy Attorney (SBN 125121)
ROSEMARY LOVE, Deputy Attorney (SBN 257907)
ANDREW GOKOFFSKI, Deputy Attorney (SBN 321272)
111 Grand Avenue, Suite 11-100, Oakland,      94612
Mail: P.O. Box 24325, Oakland, California 94623
Telephone: (510) 433-9100, Fax: (510) 433-9167
Attorneys for Defendant STATE OF CALIFORNIA,
acting by and through the Department of Transportation (“Caltrans”)




                    SUPERIOR COURT OF THE STATE OF CALIFORNIA

                                      COUNTY OF SANTA CLARA



  SZ HUA HUANG, Individually and as                 Case No.    19CV346663
  successor in interest to WEI LUN HUANG,
  deceased; TRINITY HUANG, a minor;                Assigned for all purposes to Hon. Evette
  TRISTAN HUANG, a minor; HSI KENG                 Pennypacker; Dept. 6
  HUANG; and CHING FEN HUANG,

                        Plaintiffs,                   EX PARTE APPLICATION FOR
          …