Motion,Ex Parte: xxxx xxxx et al vs CITY OF MILPITAS et al

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TIMOTHY D. MCMAHON, ESQ. (SBN 117024)
CORSIGLIA MCMAHON & ALLARD LLP
96 N. 8rd Street, Suite 620

San Jose, CA 95112

Telephone: (408) 289-1417

Facsimile: (408) 289-8127

Email; tim@cmalaw.net

Attorneys for Plaintiffs
xxxx xxxx, et.al

SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SANTA CLARA

xxxx xxxx, NEHA xxxx, GORI xxxx, Case No. 18CV325365
SHALU xxxx, :RAKHI xxxx, AND ANJU

 

xxxx PLAINTIFFS’ RESPONSE TO
PACIFIC GAS AND ELECTRIC
COMPANY’S NOTICE OF NON-
Plaintiff OPPOSITION TO DEMURRER
vs. i Date: January 31, 2019
‘ Time: 9:00 a.m.
Dept.: 9
Judge: Hon. Mary E. Arand
CITY OF MILPITAS, LORELAY
ROBLES-PARTIDA, PACIFIC GAS Action Filed: March 23, 2018
AND ELECTRIC COMPANY, and Trial Date: None Set
DOES 1 TO 40, Inclusive,
Defendants
Defendant Pacific Gas and Electric Company (PG&E) has incorrectly filed
notice of non-opposition to its demurrer set for hearing on January 31, 2019. In fact,
plaintiffs timely filed opposition to the demurrer on January 17, 2019, with a
courtesy copy was taken to Dept. 9 of this court that same day. The opposition was
also served on counsel for PG&E by overnight mail on January 17, 2019, with
delivery on defense counsel verified by Federal Express on January 18, 2019, at 9:44

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RESPONSE TO NOTICE OF NON-OPPOSITION
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a.m. (see attached Declaration of Legal Assistant Julia Pereyra.) Timely opposition
was filed and served.

Respectfully submitted,

CORSIGLIA, McMAHON & ALLARD, LLP

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DATED: January 29, 2019 By:

TIMOTHY D. MCMAHON ESQ.
Attorneys for Plaintiffs

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RESPONSE TO NOTICE OF NON-OPPOSITION
TO DEMURRER BY PACIFIC GAS & ELECTRIC COMPANYCaMorRN AAR wON

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xxxx xxxx, et al. vs. City of Milpitas, et al.

Santa Clara Superior Court Case No. 18CV325365

PROOF OF SERVICE

I am a citizen of the United States. My business address is 96 North Third Street,
Suite 620, San Jose, CA 95112. I am employed in the County of Santa Clara, where

this mailing occurs.

I am over the age of 18 years, and not a party to the within

cause. On the date set forth below, I served the attached document(s) described as:

PLAINTIFFS’ RESPONSE TO PACIFIC GAS AND ELECTRIC
COMPANY’S NOTICE OF NON-OPPOSITION TO DEMURRER

on the following person(s) in this action by placing a true copy thereof enclosed in a

sealed envelope addressed as follows:

Attorneys for Defendant
CITY OF MILPITAS

Todd H. Master, Esq.

Lisa K. Rauch, Esq.

HOWARD ROME MARTIN & RIDLEY
1900 O’Farrell:Street, Suite 280
San Mateo, CA 94403

Tel: (650) 865-7715

Fax: (650) 364-5297

Email: lrauch@hrmrlaw.com

Attorneys for Defendant,

PACIFIC GAS: & ELECTRIC
Charles Sheldon, Esq.
WALSWORTH WFBM, LLP

601 Montgomery Street, Ninth Floor
San Francisco, CA 94111

Tel: (415) 781-7072 x 2817

Direct: (415) 544-7117

Fax: (415) 391-6258

Email: csheldon@wfbm.com

[]

Attorneys for Defendant,
LORELAY ROBLES-PARTIDA

Douglas A. Sears, Esq.

LAW OFFICES OF MATHENY
SEARS LINKERT & JAIME, LLP
3638 American River Drive
Sacramento, CA 95864

Tel: (916) 978-3434

Fax: (916) 978-3430

Email: dsears@mathenysears.com

Attorneys for HMH Engineers
Catherine A. Salah, Esq.
GORDON & REES

SCULLY MANSUKHANI

275 Battery Street, Suite 2000
San Francisco, CA 94111

Tel: (415) 986-5900

Fax: (415) 986-8054

Email: csalah@gordonrees.com

(BY MAIL) I am readily familiar with my firm's practice for collection and

processing of correspondence for mailing with the United States Postal Ser-
vice, to wit, that correspondence will be deposited with the United States Post-
al Service this same day in the ordinary course of business. I sealed said enve-
lope and placed it for collection and mailing on January 29, 2019, following

ordinary. business practices.

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(BY PERSONAL SERVICE) I caused such envelope(s) to be delivered by hand

this date to the offices of the addressee(s).

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(BY FACSIMILE) I caused such document(s) to be delivered via facsimile this
date to the offices of the addressee(s).

(BY OVERNIGHT MAIL) I enclosed the documents in an envelope or package
provided by an overnight delivery carrier and addressed to the person(s) at the
address(es) listed above. I placed the envelope or package for collection and
overnight delivery at an office or a regularly utilized drop box of the overnight
delivery carrier.

(BY EMAIL OR ELECTRONIC TRANSMISSION) Based on a court order or
an agreement of the parties to accept service by e-mail or electronic transmis-
sion, I caused the documents to be sent to the persons at the following e-mail
addresses [OR at the e-mail addresses listed above]. I did not receive, within a
reasonable time after the transmission, any electronic message or other indica-
tion that the 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 true and correct. Executed on January 29, 2019 at San Jose, California.

 

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RESPONSE TO NOTICE OF NON-OPPOSITION
TO DEMURRER BY PACIFIC GAS & ELECTRIC COMPANY