Preview
-
TERESA LI (SBN 278779)
LAW OFFICES OF TERESA LI, PC
FILED
SAN MATEO COUNTY
Mailing Address:
548 Market St. APR 1.7 2024
PMB 24496
San Francisco, California 94104-5401 Cc lerk of tl erior Court
Physical Address: By,
2542 S. Bascom Avenue, Ste. 250
Campbell, CA 95008
Telephone: (415) 423-3377
Facsimile: (888) 646-5493
Email: teresa@lawofficesofteresali.com
Attorneys for Plaintiffs
FRANKCO LEE AND CHING LEE
10
SUPERIOR COURT - STATE OF CALIFORNIA
11
COUNTY OF SAN MATEO - UNLIMITED JURISDICTION
12
13 FRANKCO LEE and CHING LEE, Case No- 22-CIV-05292
14 Plaintiffs, ORDER GRANTING
UNOPPOSED EX PARTE APPLICATIO N
15 Vv. FOR ORDER TO SHORTEN TIME TO
HEAR THE MOTION TO DISQUALIFY
16 MILWAUKEE ELECTRIC TOOL DEFENSE FIRM AND TO FILE
CORPORATION and ADAM TAYLOR DOCUMENTS UNDER SEAL IN
17 KERREL aka ADAM KERZEL, and DOES SUPPORT OF THE MOTION PURSUANT:
1-15, TO STIPULATION
18
Defendants. ASSIGNED TO FOR ALL PURPOSES: THE
19 HON. RAYMOND V. SWOPE
20 Complaint Filed: 12/16/2022
Ex Parte: 04/17/2024
21 Time: 1:30 pm
Dept: 23
22
23 Plaintiffs FRANKCO LEE and CHING LEE’s unopposed ex parte application came on
24 calendar on April 17, 2024 at 1:30 pm in Department 23. The Unopposed Ex Parte Application
25 For Order To Shorten Time to Hear the Motion to Disqualify and to File A Redacted Declaration
26 of Teresa Li in Support of the Motion to Disqualify pursuant to Stipulation is GRANTED. IT IS
27 HEREBY ORDERED that
28 1 The hearing for Plaintiffs’ Motion to Disqualify Defense Law Firm is moved
‘aab0¢16- Pane Apliatin fr Order to Fle Redcat Daton of Tre Li ISO Mason to ically -Propre Ofer doce
{PROPOSED] ORDER GRANTING UNOPPOSED EX PARTE APPLICATION
from September 16, 2024 to June 3, 2024 at 2:00 p.m. in Department 23;
2. Under California Rules of Court Rule 2.5550 good cause exists that the Exhibit 2
of Frankco Lee’s deposition which is Exhibit J and Exhibit O to Declaration of Teresa Li in
Support of the Motion to Disqualify Defense Firm shall be filed under seal. The attached
redacted version of Exhibit J and oO are ordered to be included in the public record.
Date: APR 17 2024
Hon: mond V. Swope
v. RAYtheMONSupe
D SWOPE
rior Court
Judge of
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
20240414 ExPae Aplin fx Ordre Rata Datars feet i S0 Maton ois =r Ore doc
[BROROSED] ORDER GRANTING UNOPPOSED EX PARTE APPLICATION
Lee v. Milwaukee Electric Tool Corporation
San Mateo County Superior Court Case No. 22-CIV-05292
Our File No. 00167-Lee
AFFIDAVIT OF SERVICE
STATE OF CALIFORNIA, CITY OF CAMPBELL, COUNTY OF SANTA CLARA
I, Teresa Li, declare
lam a citizen of the United States, over 18 years of age and not a party to the within
action. I am employed in.the City of Campbell, County of Santa Clara; my business address is
2542 S. Bascom Avenue, Suite 250, Campbell, CA 95008
On April 17, 2024, I served the attached and/or enclosed:
PLAINTIFFS’ UNOPPOSED EX PARTE APPLICATION FOR ORDER TO SHORTEN
TIME TO HEAR THE MOTION TO DISQUALIFY DEFENSE FIRM AND TO FILE
DOCUMENTS UNDER SEAL IN SUPPORT OF THE MOTION PURSUANT TO
STIPULATION
10 STIPLUATION RE FILING MEDICAL RECORDS UNDER SEAL AND MOVING
THE HEARING DATE FOR MOTION TO DISQUALIFY DEFENSE LAW FRIM
ll FROM SEPTEMBER 16, 2024 TO JUNE 5, 2024
12 [PROPOSED] ORDER GRANTING UNOPPOSED EX PARTE APPLICATION FOR
ORDER TO SHORTEN TIME TO HEAR THE MOTION TO DISQUALIFY DEFENSE
13 FIRM AND TO FILE DOCUMENTS UNDER SEAL IN SUPPORT OF THE MOTION
PURSUANT TO STIPULATION
14 on all parties in this action, at the following address(es):
15 Brett T. Moroney (SBN 199795)
Melissa M. Fairbrother (SBN 149787)
16 Gordon Rees Scully Mansukhani, LLP
275 Battery Street, Suite 2000
17 San Francisco, CA 9411
Email: bmoroney@grsm.com
18 jpadilla@grsm.com
mfairbrother@grsm.com
19 Attorney for Defendants
Milwaukee Electric Tool Corporation and Adam Taylor Kerrel, aka Adam Kerzel
20
21 Service was accomplished by causing either an original or a true copy of the above-
referenced document(s) to be distributed as follows:
22
Oo BY MAIL: I caused such document(s) to be placed in a sealed envelope, addressed as
23 indicated above, with prepaid first-class postage thereon, and then placed the envelope(s) for
collection and mailing, in accordance with the firm’s ordinary business practice. I'am readily
24 familiar with the firm's ordinary business practice for collection and processing of
correspondence for-mailing with the United States Postal Service. Under that practice
25 correspondence for mailing is deposited with United States Postal Service on the date indicated
for service, with prepaid first-class postage thereon.
26
& BY EMAIL: I caused such documents to be transmitted via email to the parties indicated
27 above, at their respective email addresses.
28 oO BY HAND DELIVERY: I caused such documents to be hand delivered to the addresses
rosdex 1
Proof of Service
Lee v, Milwaukee Electric Tool Corporation
San Mateo County Superior Court Case No. 22-CIV-05292
Our File No. 00167-Lee
indicated above.
oO VIA FACSIMILE: I caused such documents to be transmitted via facsimile to the parties
indicated above, at their respective facsimile numbers.
oO VIA EXPRESS CARRIER: I caused such documents to be collected by an agent for the
United States Postal Service, United Parcel Service, Federal Express or other overnight carrier,
to be delivered by way of overnight mail to the addresses indicated above.
Oo BY E-SERVICE: I caused such documents to be transmitted via email through the One
Legal website as part of the e-filing process, to the parties indicated above, at their respective
email addresses.
I declare under penalty of perjury under the laws of the State of California, that the
foregoing is true and correct.
Executed on April 17, 2024, at Campbell, California.
_Aas
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
2
Proof of Service
Preview
- TERESA LI (SBN 278779) LAW OFFICES OF TERESA LI, PC FILED SAN MATEO COUNTY Mailing Address: 548 Market St. APR 1.7 2024 PMB 24496 San Francisco, California 94104-5401 Cc lerk of tl erior Court Physical Address: By, 2542 S. Bascom Avenue, Ste. 250 Campbell, CA 95008 Telephone: (415) 423-3377 Facsimile: (888) 646-5493 Email: teresa@lawofficesofteresali.com Attorneys for Plaintiffs FRANKCO LEE AND CHING LEE 10 SUPERIOR COURT - STATE OF CALIFORNIA 11 COUNTY OF SAN MATEO - UNLIMITED JURISDICTION 12 13 FRANKCO LEE and CHING LEE, Case No- 22-CIV-05292 14 Plaintiffs, ORDER GRANTING UNOPPOSED EX PARTE APPLICATIO N 15 Vv. FOR ORDER TO SHORTEN TIME TO HEAR THE MOTION TO DISQUALIFY 16 MILWAUKEE ELECTRIC TOOL DEFENSE FIRM AND TO FILE CORPORATION and ADAM TAYLOR DOCUMENTS UNDER SEAL IN 17 KERREL aka ADAM KERZEL, and DOES SUPPORT OF THE MOTION PURSUANT: 1-15, TO STIPULATION 18 Defendants. ASSIGNED TO FOR ALL PURPOSES: THE 19 HON. RAYMOND V. SWOPE 20 Complaint Filed: 12/16/2022 Ex Parte: 04/17/2024 21 Time: 1:30 pm Dept: 23 22 23 Plaintiffs FRANKCO LEE and CHING LEE’s unopposed ex parte application came on 24 calendar on April 17, 2024 at 1:30 pm in Department 23. The Unopposed Ex Parte Application 25 For Order To Shorten Time to Hear the Motion to Disqualify and to File A Redacted Declaration 26 of Teresa Li in Support of the Motion to Disqualify pursuant to Stipulation is GRANTED. IT IS 27 HEREBY ORDERED that 28 1 The hearing for Plaintiffs’ Motion to Disqualify Defense Law Firm is moved ‘aab0¢16- Pane Apliatin fr Order to Fle Redcat Daton of Tre Li ISO Mason to ically -Propre Ofer doce {PROPOSED] ORDER GRANTING UNOPPOSED EX PARTE APPLICATION from September 16, 2024 to June 3, 2024 at 2:00 p.m. in Department 23; 2. Under California Rules of Court Rule 2.5550 good cause exists that the Exhibit 2 of Frankco Lee’s deposition which is Exhibit J and Exhibit O to Declaration of Teresa Li in Support of the Motion to Disqualify Defense Firm shall be filed under seal. The attached redacted version of Exhibit J and oO are ordered to be included in the public record. Date: APR 17 2024 Hon: mond V. Swope v. RAYtheMONSupe D SWOPE rior Court Judge of 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 20240414 ExPae Aplin fx Ordre Rata Datars feet i S0 Maton ois =r Ore doc [BROROSED] ORDER GRANTING UNOPPOSED EX PARTE APPLICATION Lee v. Milwaukee Electric Tool Corporation San Mateo County Superior Court Case No. 22-CIV-05292 Our File No. 00167-Lee AFFIDAVIT OF SERVICE STATE OF CALIFORNIA, CITY OF CAMPBELL, COUNTY OF SANTA CLARA I, Teresa Li, declare lam a citizen of the United States, over 18 years of age and not a party to the within action. I am employed in.the City of Campbell, County of Santa Clara; my business address is 2542 S. Bascom Avenue, Suite 250, Campbell, CA 95008 On April 17, 2024, I served the attached and/or enclosed: PLAINTIFFS’ UNOPPOSED EX PARTE APPLICATION FOR ORDER TO SHORTEN TIME TO HEAR THE MOTION TO DISQUALIFY DEFENSE FIRM AND TO FILE DOCUMENTS UNDER SEAL IN SUPPORT OF THE MOTION PURSUANT TO STIPULATION 10 STIPLUATION RE FILING MEDICAL RECORDS UNDER SEAL AND MOVING THE HEARING DATE FOR MOTION TO DISQUALIFY DEFENSE LAW FRIM ll FROM SEPTEMBER 16, 2024 TO JUNE 5, 2024 12 [PROPOSED] ORDER GRANTING UNOPPOSED EX PARTE APPLICATION FOR ORDER TO SHORTEN TIME TO HEAR THE MOTION TO DISQUALIFY DEFENSE 13 FIRM AND TO FILE DOCUMENTS UNDER SEAL IN SUPPORT OF THE MOTION PURSUANT TO STIPULATION 14 on all parties in this action, at the following address(es): 15 Brett T. Moroney (SBN 199795) Melissa M. Fairbrother (SBN 149787) 16 Gordon Rees Scully Mansukhani, LLP 275 Battery Street, Suite 2000 17 San Francisco, CA 9411 Email: bmoroney@grsm.com 18 jpadilla@grsm.com mfairbrother@grsm.com 19 Attorney for Defendants Milwaukee Electric Tool Corporation and Adam Taylor Kerrel, aka Adam Kerzel 20 21 Service was accomplished by causing either an original or a true copy of the above- referenced document(s) to be distributed as follows: 22 Oo BY MAIL: I caused such document(s) to be placed in a sealed envelope, addressed as 23 indicated above, with prepaid first-class postage thereon, and then placed the envelope(s) for collection and mailing, in accordance with the firm’s ordinary business practice. I'am readily 24 familiar with the firm's ordinary business practice for collection and processing of correspondence for-mailing with the United States Postal Service. Under that practice 25 correspondence for mailing is deposited with United States Postal Service on the date indicated for service, with prepaid first-class postage thereon. 26 & BY EMAIL: I caused such documents to be transmitted via email to the parties indicated 27 above, at their respective email addresses. 28 oO BY HAND DELIVERY: I caused such documents to be hand delivered to the addresses rosdex 1 Proof of Service Lee v, Milwaukee Electric Tool Corporation San Mateo County Superior Court Case No. 22-CIV-05292 Our File No. 00167-Lee indicated above. oO VIA FACSIMILE: I caused such documents to be transmitted via facsimile to the parties indicated above, at their respective facsimile numbers. oO VIA EXPRESS CARRIER: I caused such documents to be collected by an agent for the United States Postal Service, United Parcel Service, Federal Express or other overnight carrier, to be delivered by way of overnight mail to the addresses indicated above. Oo BY E-SERVICE: I caused such documents to be transmitted via email through the One Legal website as part of the e-filing process, to the parties indicated above, at their respective email addresses. I declare under penalty of perjury under the laws of the State of California, that the foregoing is true and correct. Executed on April 17, 2024, at Campbell, California. _Aas 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 Proof of Service