On January 02, 2019 a
Motion-Secondary
was filed
involving a dispute between
and
for Eminent Domain/Inv Cond Unlimited (14)
in the District Court of Santa Clara County.
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Scott E. Jenny, Esq. — State Bar No. 166111
JENNY & JENNY, LLP
736 Ferry Street
Martinez, California 94553
Telephone: — (925) 228-1265
Facsimile: (925) 228-2841
Attorney for Defendant
D.E. II RESTAURANTS, INC.
IN THE SUPERIOR COURT OF THE STATE CALIFORNIA
IN AND FOR THE COUNTY OF SANTA CLARA
UNLIMITED JURISDICTION
CITY OF SANTA CLARA, a California
Charter City
Case No.: 19CV340508
OBJECTION TO EVIDENCE OF
PLAINTIFF IN SUPPORT OF
PLAINTIFF’S MOTION FOR
PREJUDGMENT POSSESSION
Plaintiff,
vs.
D.E. II RESTAURANTS, INC., a California
corporation; and DOES 1-50, Hon. Peter H. Kirwan
Defendants.
D.E. IL RESTAURANTS, INC. Date: October 31, 2019
Time: 9:00 a.m.
Dept.: 19
Cross-Complainant,
vs.
CITY OF SANTA CLARA, a California
Charter City and ROES 1 through 10,
inclusive,
Cross-Defendants.
=
OBJECTION TO EVIDENCE OF PLAINTIFF IN SUPPORT OF PLAINTIFF'S
MOTION FOR PREJUDGMENT POSSESSION20
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Defendant and Cross-Complainant D.E. II RESTAURANTS, INC.objects to the evidence
of plaintiff in support of its Motion for Prejudgment Possession as follows:
EVIDENCE
OBJECTION TO EVIDENCE
Declaration of Ruth Shikada, Paragraph 2,
First Sentence.
Hearsay. No foundation. Lacks personal
knowledge. Calls for speculation.
Declaration of Ruth Shikada, Paragraph 4 in
its entirety.
Hearsay. No foundation. Lacks personal
knowledge. Calls for speculation.
Declaration of Ruth Shikada, Paragraph 5 in
its entirety.
Hearsay. No foundation. Lacks personal
knowledge. Calls for speculation.
Declaration of Ruth Shikada, Paragraph 6,
sentence beginning on Line 18 to 20
(timing).
Hearsay. No foundation. Lacks personal
knowledge. Calls for speculation.
Exhibit A to the Declaration of Ruth
Shikada.
Hearsay. No foundation. Lacks personal
knowledge.
Exhibit B to the Declaration of Ruth
Shikada.
Hearsay. No foundation. Lacks personal
knowledge. Calls for speculation.
Exhibit C to the Declaration of Ruth
Shikada.
Hearsay. No foundation. Lacks personal
knowledge. Calls for speculation.
Exhibit D to the Declaration of Ruth
Shikada.
Hearsay. No foundation. Lacks personal
knowledge. Calls for speculation.
DATED: Sept. 9, 2019
D.E. II RESTAURANTS, INC.
205:
OBJECTION TO EVIDENCE OF PLAINTIFF IN SUPPORT OF PLAINTIFFS
MOTION FOR PREJUDGMENT POSSESSION
Document Filed Date
September 13, 2019
Case Filing Date
January 02, 2019
Category
Eminent Domain/Inv Cond Unlimited (14)
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20 21 22 23 24 25 26 27 28 Scott E. Jenny, Esq. — State Bar No. 166111 JENNY & JENNY, LLP 736 Ferry Street Martinez, California 94553 Telephone: — (925) 228-1265 Facsimile: (925) 228-2841 Attorney for Defendant D.E. II RESTAURANTS, INC. IN THE SUPERIOR COURT OF THE STATE CALIFORNIA IN AND FOR THE COUNTY OF SANTA CLARA UNLIMITED JURISDICTION CITY OF SANTA CLARA, a California Charter City Case No.: 19CV340508 OBJECTION TO EVIDENCE OF PLAINTIFF IN SUPPORT OF PLAINTIFF’S MOTION FOR PREJUDGMENT POSSESSION Plaintiff, vs. D.E. II RESTAURANTS, INC., a California corporation; and DOES 1-50, Hon. Peter H. Kirwan Defendants. D.E. IL RESTAURANTS, INC. Date: October 31, 2019 Time: 9:00 a.m. Dept.: 19 Cross-Complainant, vs. CITY OF SANTA CLARA, a California Charter City and ROES 1 through 10, inclusive, Cross-Defendants. = OBJECTION TO EVIDENCE OF PLAINTIFF IN SUPPORT OF PLAINTIFF'S MOTION FOR PREJUDGMENT POSSESSION20 21 22 23 24 25 26 27 28 Defendant and Cross-Complainant D.E. II RESTAURANTS, INC.objects to the evidence of plaintiff in support of its Motion for Prejudgment Possession as follows: EVIDENCE OBJECTION TO EVIDENCE Declaration of Ruth Shikada, Paragraph 2, First Sentence. Hearsay. No foundation. Lacks personal knowledge. Calls for speculation. Declaration of Ruth Shikada, Paragraph 4 in its entirety. Hearsay. No foundation. Lacks personal knowledge. Calls for speculation. Declaration of Ruth Shikada, Paragraph 5 in its entirety. Hearsay. No foundation. Lacks personal knowledge. Calls for speculation. Declaration of Ruth Shikada, Paragraph 6, sentence beginning on Line 18 to 20 (timing). Hearsay. No foundation. Lacks personal knowledge. Calls for speculation. Exhibit A to the Declaration of Ruth Shikada. Hearsay. No foundation. Lacks personal knowledge. Exhibit B to the Declaration of Ruth Shikada. Hearsay. No foundation. Lacks personal knowledge. Calls for speculation. Exhibit C to the Declaration of Ruth Shikada. Hearsay. No foundation. Lacks personal knowledge. Calls for speculation. Exhibit D to the Declaration of Ruth Shikada. Hearsay. No foundation. Lacks personal knowledge. Calls for speculation. DATED: Sept. 9, 2019 D.E. II RESTAURANTS, INC. 205: OBJECTION TO EVIDENCE OF PLAINTIFF IN SUPPORT OF PLAINTIFFS MOTION FOR PREJUDGMENT POSSESSION