No Value: Lisa Keith vs Celeste White et al

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                                1   John S. Rueppel (SBN: 267467)
     Angie Lam (SBN: 244719)
 2   JOHNSTON, KINNEY & ZULAICA LLP
     101 Montgomery Street, Suite 1600
 3   San Francisco, California 94104
 4   Telephone: (415) 693-0550
     Facsimile: (415) 693-0500
 5   Email: john@jkzllp.com
            angie.lam@jkzllp.com
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     Attorneys for Plaintiff,
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     Lisa Keith
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                            SUPERIOR COURT OF THE STATE OF CALIFORNIA
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                                         IN THE COUNTY OF NAPA
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11   LISA KEITH,                                             CASE NO: 22CV001269
12           Plaintiff,                                      [PROPOSED] ORDER GRANTING
13                                                           PLAINTIFF’S EX PARTE APPLICATION
             v.                                              TO CONTINUE HEARING ON
14                                                           DEFENDANTS’ MOTION FOR
     CELESTE WHITE, an individual, ROBERT                    SUMMARY JUDGMENT/
15   WHITE, an individual, the VALLEY ROCK                   ADJUDICATION AND TO CONTINUE
     FOUNDATION, aka THE BAR 49                              TRIAL DATE
16   FOUNDATION, a charitable organization, and
17   DOES 1-50, INCLUSIVE,                                   Date:            February 15, 2024
                                                             Time:            11:30 a.m.
18           Defendants.                                     Judge:           Hon. Scott R.L. Young
                                                             Dept.:           B
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                                                             Complaint Filed: October 25, 2022
20                                                           FAC Filed:       March 8, 2023
21                                                           Trial Date:      April 2, 2024

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                                             [PROPOSED] ORDER
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            The ex parte application of Plaintiff, Lisa Keith (“Plaintiff”) for an Order Continuing Hearing on
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     Defendants’ Motion for Summary Judgment/Adjudication and to Continue Trial Date (“Application”)
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     came on for hearing before the Honorable Scott R.L. Young on February 15, 2024, in Department B of
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     the Superior Court of the County of Napa.
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            Having considered the Application, supporting papers and arguments of counsel, and with good
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     cause appearing, the Court GRANTS Plaintiff’s Application and HEREBY ORDERS THAT:
                                                         1
     [PROPOSED]
     f          ORDER GRANTING EX PARTE APPLICATION
 1         (1) Defendants’    Motion     for   Summary        Judgment/Adjudication   shall   be   heard   on
 2             _______________.
 3         (2) All statutory deadlines for filing and service of Plaintiff’s Opposition to the Motion for
 4             Summary Judgment and Defendants’ Reply, if any, shall follow the new hearing date.
 5         (3) The April 2, 2024 trial in this matter is continued to _______________.
 6         (4) All pre-trial statutory deadlines shall follow the new trial date.
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 8   IT IS SO ORDERED.
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11   Dated: February ___, 2024                    By:
                                                        JUDGE OF THE SUPERIOR COURT
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                                                          2
     [PROPOSED]
     f          ORDER GRANTING EX PARTE APPLICATION
 1                                           PROOF OF SERVICE
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     STATE OF CALIFORNIA, CITY OF ANTIOCH AND COUNTY OF CONTRA COSTA
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             I am employed in the City and County of San Francisco, State of California. I am over the age of
 4   18 years and not a party to the within action; my business address is Johnston Kinney & Zulaica LLP,
     101 Montgomery Street, Suite 1600, San Francisco, California 94104. My electronic business address is
 5   carolina@jkzllp.com.
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              On February 14, 2024, I served the foregoing document(s):
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         1. [PROPOSED] ORDER GRANTING PLAINTIFF’S EX PARTE APPLICATION FOR
 8          HEARING ON SHORTENEND NOTICE TO MOTION TO CONTINUE HEARING ON
            DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT/ ADJUDICATION
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              I served the documents on the person or persons listed below as follows:
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11   Jeffrey E. Tsai
     Kathleen S. Kizer
12   DLA PIPER LLP (US)
     555 Mission Street, Suite 2400
13   San Francisco, CA 94105
     Jeff.tsai@us.dlapiper.com
14   Katy.kizer@us.dlapiper.com
     Attorneys for Defendants
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     [X]     (BY EMAIL) Pursuant to Code of Civil Procedure section 1010.6, I caused the document(s) to
16   be electronically transmitted by me to the persons listed in the above email address(es). I did not receive
     within a reasonable time after the transmission, any electronic message or other indication that the
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     transmission was unsuccessful.
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             I declare under penalty of perjury under the laws of the State of California that the foregoing is
19   true and correct.

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              Executed on February 14, 2024, at Antioch, California.
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23                                                         Carolina Ramos
     4858-5825-5525, v. 2
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                                                          3
     [PROPOSED]
     f          ORDER GRANTING EX PARTE APPLICATION