On January 25, 2019 a
Party Notice
was filed
involving a dispute between
California Fire Protection Coalition,
Del Toro Trejo, Juan Carlos,
Filed By: Fire Guard Corporation,
Fire Guard Corporation,
Shahangian, Bahman Brian,
and
California Department Of Forestry And Fire Protection,
California Office Of The State Fire Marshal,
Dennis Mathisen In His Official Capacity As State Fire Marshal,
Does 1-10,
Jeffery Schwartz In His Official Capacity As Deputy State Fire Marshall,
Mike Richwine In His Official Capacity As State Fire Marshal,
for (Civil Rights/Discrimination)
in the District Court of Sacramento County.
Preview
1 ROB BONTA
Attorney General of California
2 RUSSELL B. HILDRETH
Supervising Deputy Attorney General
3 ANDREA M. KENDRICK
Deputy Attorney General
4 State Bar No. 225688
1300 I Street, Suite 125
5 P.O. Box 944255
Sacramento, CA 94244-2550
6 Telephone: (916) 210-7821
Fax: (916) 327-2319
7 E-mail: Andrea.Kendrick@doj.ca.gov
Exempt from Filing Fees
8 Attorneys for Defendants Pursuant to Gov. Code § 6103
9
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10
COUNTY OF SACRAMENTO
11
12
13
14 FIRE GUARD CORPORATION; Case No. 34-2019-00249221-CU-CR-GDS
BAHMAN BRIAN SHAHANGIAN, an
15 individual; CALIFORNIA FIRE NOTICE OF ORDER GRANTING JOINT
PROTECTION COALITION, a California EX PARTE APPLICATION TO
16 Corporation; and JUAN CARLOS DEL CONTINUE TRIAL DATE
TORO TREJO, an individual,
17
Plaintiffs,
18
v.
19
20 CALIFORNIA DEPARTMENT OF
FORESTRY AND FIRE PROTECTION;
21 CALIFORNIA OFFICE OF THE STATE
FIRE MARSHAL; MIKE RICHWINE, in
22 his official capacity as State Fire Marshal;
JEFFERY SCHWARTZ, in his official
23 capacity as Deputy State Fire Marshal; and
DOES 1 through 10, inclusive,
24
Defendants.
25
26
27
28
1
Notice of Order Granting Joint Ex Parte Application to Continue Trial Date (34-2019-00249221-CU-CR-GDS)
1 TO ALL PLAINTIFFS AND THEIR COUNSEL OF RECORD:
2 PLEASE TAKE NOTICE that on April 10, 2024, the Court issued the attached order
3 granting the parties’ Joint Ex Parte Application to Continue Trial Date.
4
5 Dated: April 11, 2024 ROB BONTA
Attorney General of California
6 RUSSELL B. HILDRETH
7 Supervising Deputy Attorney General
8
By: ____________________________________
9 ANDREA M. KENDRICK
Deputy Attorney General
10
Attorneys for Defendants
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
2
Notice of Order Granting Joint Ex Parte Application to Continue Trial Date (34-2019-00249221-CU-CR-GDS)
SUPERIOR COURT OF CALIFORNIA COUN'TY OF SACRAMENTO
ORDER-
STIPULATION YES..i::=-No
OPPOSITION YES _ _ N O ~
TRIAL DATE MSC DATE
Case Name case Number
f
i~ 4
EX PARTEAPPL~: ~
~ST&MOT _ •
~ame of Appearing Party Representing
The Cou , having <;onsldered he above entitled . â–¡ without a hearing â–¡ after hearing with appearance(s) as noted
• above, rules as follows:
f Request for OST/Application is Granted. â–¡ Request for OST/Application Is Denied.
fi Trial date Is vacated. •
1
I
Mandatory Settlement Conference date Is vacat.ed.
...S-, at 8:30 a.m. {VlaZoom)
L.
~ The Mandatory Settlement Conference date is reset for 12 f
I -t 9:30
-- a ./1:30 p.m. In Department 59.
â–¡ This case Is referred to the COVID-19 Trial Setting Process (TSP) f selection of trial and Mandatory Settlement Conference
dates. Available dates can be obtained on the court's web site at http://www.saccourt.ca.gov. All counsel (Including parties
appearing in pro per) shall confer and agree upon trial and settlement conference dates. Plaintiffs counsel must notify the
court qf the selection of Mandatory Settlement Conference and T-rlal dates no later than ___/ 60 days from the date of
this order, by completing the request form at http://www.saccourt.ca.gov/cMl/trial-settlng.aspx. If the parties have not
agreed on dates before the due date, court staff shall assign Mandatory Settlement Conference and Trial dates that are next
available, unless an extension of time has been granted by the appropriate Case Management Program Judge.
D The matter is set for Short Cause Trial on _ _ _ _ _at 9:30 a.m. in Department 47 for assignment via remote
appearances.
â–¡ The matter will be heard on _ _ _ _ _at 9:30 a.m. in Department 47. Moving papers to be filed and served on/or
before____. Responding Party's oppositions to be filed and served on/or before_ _ _. Reply waived.
A tentative ruling will be Issued 2 court days prior to hearing. To request oral argument, you must call Dept. 47 at (916} 874-5487 and
opposing party by 12:00 p.m. the court day before the hearing. No in-person appearances are allowed until further notice. Department 47
Zoom Unk: https://saccourt-ca-gov.zoomgov.com/tny/sscdept47. To appear on Zoom by phone, call (833) 568-8864 (toll free) and enter
the Zoom ID: 16173813009.
â–¡ The moving party must proceed by noticed motion.
â–¡ The application is denied on the merits of the papers presented to the Court.
Other_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
l
â–¡
All trial related and discovery deadlines are to be based upon the new trial date.
Counsel ls directed to serve a copy of~!ilrfA
II other parties.
Counsel for the ·;·;:;;i d to prepare a form order.
□ See a_)faihedJ°rder. ~
4_10 I Z:,'f \~;.!~•';;:::: - ~--~__._-1-JJ+.,pijC.~~r-----
c;;I·~
ATE JUDGE
l'IW'-"!1----------------+-~-----------"1
~::-:-:,c------:c-::-::--:-:-:--:-:---=--=-=-=-:c:-c-:=-=-===-:-
'- ~Q~ B
Cl-150 as modified 3/21/22 {SAVED IN D47 FOLD ==~- RDER DAY OF TRIAL OR lAW AND MOTION-BLANK Cl-150)
DECLARATION OF SERVICE BY E-MAIL AND U.S. MAIL
Case Name: Fire Guard Corporation, et al. v. California Department of Forestry and
Fire Protection, et al.
No.: Sacramento Superior Court Case No. 34-2019-00249221-CU-CR-GDS
I declare:
I am employed in the Office of the Attorney General, which is the office of a member of the
California State Bar, at which member's direction this service is made. I am 18 years of age or
older and not a party to this matter. I am familiar with the business practice at the Office of the
Attorney General for collection and processing of correspondence for mailing with the United
States Postal Service. In accordance with that practice, correspondence placed in the internal
mail collection system at the Office of the Attorney General is deposited with the United States
Postal Service with postage thereon fully prepaid that same day in the ordinary course of
business.
On April 11, 2024, I served the attached NOTICE OF ORDER GRANTING JOINT EX
PARTE APPLICATION TO CONTINUE TRIAL DATE by transmitting a true copy via
electronic mail. In addition, I placed a true copy thereof enclosed in a sealed envelope, in the
internal mail system of the Office of the Attorney General, addressed as follows:
Timothy V. Kassouni, Esq. Margaret Esquiroz, Esq.
KASSOUNI LAW Email address: esquiroz@pm.me
455 Capitol Mall, Suite 604 Attorney for Defendant California Fire
Sacramento, CA 95814 Protection Coalition
Email address: timothy@kassounilaw.com Via Electronic Mail only
Attorney for Plaintiffs
Fire Guard Corporation, Bahman Brian
Shahangian, and Juan Carlos Del Toro Trejo
Via Electronic Mail and U.S. Mail
I declare under penalty of perjury under the laws of the State of California and the United States
of America the foregoing is true and correct and that this declaration was executed on April 11,
2024, at Sacramento, California.
Kristi Dykstra
Declarant Signature
SA2019300028
38007343.docx
Document Filed Date
April 11, 2024
Case Filing Date
January 25, 2019
Category
(Civil Rights/Discrimination)
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
1 ROB BONTA Attorney General of California 2 RUSSELL B. HILDRETH Supervising Deputy Attorney General 3 ANDREA M. KENDRICK Deputy Attorney General 4 State Bar No. 225688 1300 I Street, Suite 125 5 P.O. Box 944255 Sacramento, CA 94244-2550 6 Telephone: (916) 210-7821 Fax: (916) 327-2319 7 E-mail: Andrea.Kendrick@doj.ca.gov Exempt from Filing Fees 8 Attorneys for Defendants Pursuant to Gov. Code § 6103 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF SACRAMENTO 11 12 13 14 FIRE GUARD CORPORATION; Case No. 34-2019-00249221-CU-CR-GDS BAHMAN BRIAN SHAHANGIAN, an 15 individual; CALIFORNIA FIRE NOTICE OF ORDER GRANTING JOINT PROTECTION COALITION, a California EX PARTE APPLICATION TO 16 Corporation; and JUAN CARLOS DEL CONTINUE TRIAL DATE TORO TREJO, an individual, 17 Plaintiffs, 18 v. 19 20 CALIFORNIA DEPARTMENT OF FORESTRY AND FIRE PROTECTION; 21 CALIFORNIA OFFICE OF THE STATE FIRE MARSHAL; MIKE RICHWINE, in 22 his official capacity as State Fire Marshal; JEFFERY SCHWARTZ, in his official 23 capacity as Deputy State Fire Marshal; and DOES 1 through 10, inclusive, 24 Defendants. 25 26 27 28 1 Notice of Order Granting Joint Ex Parte Application to Continue Trial Date (34-2019-00249221-CU-CR-GDS) 1 TO ALL PLAINTIFFS AND THEIR COUNSEL OF RECORD: 2 PLEASE TAKE NOTICE that on April 10, 2024, the Court issued the attached order 3 granting the parties’ Joint Ex Parte Application to Continue Trial Date. 4 5 Dated: April 11, 2024 ROB BONTA Attorney General of California 6 RUSSELL B. HILDRETH 7 Supervising Deputy Attorney General 8 By: ____________________________________ 9 ANDREA M. KENDRICK Deputy Attorney General 10 Attorneys for Defendants 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 Notice of Order Granting Joint Ex Parte Application to Continue Trial Date (34-2019-00249221-CU-CR-GDS) SUPERIOR COURT OF CALIFORNIA COUN'TY OF SACRAMENTO ORDER- STIPULATION YES..i::=-No OPPOSITION YES _ _ N O ~ TRIAL DATE MSC DATE Case Name case Number f i~ 4 EX PARTEAPPL~: ~ ~ST&MOT _ • ~ame of Appearing Party Representing The Cou , having <;onsldered he above entitled . □ without a hearing □ after hearing with appearance(s) as noted • above, rules as follows: f Request for OST/Application is Granted. □ Request for OST/Application Is Denied. fi Trial date Is vacated. • 1 I Mandatory Settlement Conference date Is vacat.ed. ...S-, at 8:30 a.m. {VlaZoom) L. ~ The Mandatory Settlement Conference date is reset for 12 f I -t 9:30 -- a ./1:30 p.m. In Department 59. □ This case Is referred to the COVID-19 Trial Setting Process (TSP) f selection of trial and Mandatory Settlement Conference dates. Available dates can be obtained on the court's web site at http://www.saccourt.ca.gov. All counsel (Including parties appearing in pro per) shall confer and agree upon trial and settlement conference dates. Plaintiffs counsel must notify the court qf the selection of Mandatory Settlement Conference and T-rlal dates no later than ___/ 60 days from the date of this order, by completing the request form at http://www.saccourt.ca.gov/cMl/trial-settlng.aspx. If the parties have not agreed on dates before the due date, court staff shall assign Mandatory Settlement Conference and Trial dates that are next available, unless an extension of time has been granted by the appropriate Case Management Program Judge. D The matter is set for Short Cause Trial on _ _ _ _ _at 9:30 a.m. in Department 47 for assignment via remote appearances. □ The matter will be heard on _ _ _ _ _at 9:30 a.m. in Department 47. Moving papers to be filed and served on/or before____. Responding Party's oppositions to be filed and served on/or before_ _ _. Reply waived. A tentative ruling will be Issued 2 court days prior to hearing. To request oral argument, you must call Dept. 47 at (916} 874-5487 and opposing party by 12:00 p.m. the court day before the hearing. No in-person appearances are allowed until further notice. Department 47 Zoom Unk: https://saccourt-ca-gov.zoomgov.com/tny/sscdept47. To appear on Zoom by phone, call (833) 568-8864 (toll free) and enter the Zoom ID: 16173813009. □ The moving party must proceed by noticed motion. □ The application is denied on the merits of the papers presented to the Court. Other_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ l □ All trial related and discovery deadlines are to be based upon the new trial date. Counsel ls directed to serve a copy of~!ilrfA II other parties. Counsel for the ·;·;:;;i d to prepare a form order. □ See a_)faihedJ°rder. ~ 4_10 I Z:,'f \~;.!~•';;:::: - ~--~__._-1-JJ+.,pijC.~~r----- c;;I·~ ATE JUDGE l'IW'-"!1----------------+-~-----------"1 ~::-:-:,c------:c-::-::--:-:-:--:-:---=--=-=-=-:c:-c-:=-=-===-:- '- ~Q~ B Cl-150 as modified 3/21/22 {SAVED IN D47 FOLD ==~- RDER DAY OF TRIAL OR lAW AND MOTION-BLANK Cl-150) DECLARATION OF SERVICE BY E-MAIL AND U.S. MAIL Case Name: Fire Guard Corporation, et al. v. California Department of Forestry and Fire Protection, et al. No.: Sacramento Superior Court Case No. 34-2019-00249221-CU-CR-GDS I declare: I am employed in the Office of the Attorney General, which is the office of a member of the California State Bar, at which member's direction this service is made. I am 18 years of age or older and not a party to this matter. I am familiar with the business practice at the Office of the Attorney General for collection and processing of correspondence for mailing with the United States Postal Service. In accordance with that practice, correspondence placed in the internal mail collection system at the Office of the Attorney General is deposited with the United States Postal Service with postage thereon fully prepaid that same day in the ordinary course of business. On April 11, 2024, I served the attached NOTICE OF ORDER GRANTING JOINT EX PARTE APPLICATION TO CONTINUE TRIAL DATE by transmitting a true copy via electronic mail. In addition, I placed a true copy thereof enclosed in a sealed envelope, in the internal mail system of the Office of the Attorney General, addressed as follows: Timothy V. Kassouni, Esq. Margaret Esquiroz, Esq. KASSOUNI LAW Email address: esquiroz@pm.me 455 Capitol Mall, Suite 604 Attorney for Defendant California Fire Sacramento, CA 95814 Protection Coalition Email address: timothy@kassounilaw.com Via Electronic Mail only Attorney for Plaintiffs Fire Guard Corporation, Bahman Brian Shahangian, and Juan Carlos Del Toro Trejo Via Electronic Mail and U.S. Mail I declare under penalty of perjury under the laws of the State of California and the United States of America the foregoing is true and correct and that this declaration was executed on April 11, 2024, at Sacramento, California. Kristi Dykstra Declarant Signature SA2019300028 38007343.docx