On October 04, 2018 a
Motion-Secondary
was filed
involving a dispute between
Friends Of The Willow Glen Trestle,
Willow Glen Trestle Conservancy,
and
California Department Of Fish And Wildlife,
City Of San Jose,
City Of San Jose Department Of Public Works,
for Environmental/Toxic Tort Unlimited (30)
in the District Court of Santa Clara County.
Preview
1 Susan Brandt Hawley/SBN 75907
BRANDT HAWLEY LAW GROUP
2
P.O. Box 1659
3 Glen Ellen, CA 95442
707.938.3900, fax 707.938.3200
4 susanbh@preservationlawyers.com
5
6
Attorney for Petitioners
7
8
SUPERIOR COURT OF THE STATE OF CALIFORNIA
9
FOR THE COUNTY OF SANTA CLARA
Willow Glen Trestle Conservancy
an unincorporated association, and
Friends of the Willow Glen
Trestlean unincorporated Petitioners’ Objection to
association; Late-Filed Pleadings
Petitioners,
Honorable Thomas E. Kuhnle
City of San Jos City of San Jos
Department of Public Works;
California Department of Fish
and Wildlife; and Does 1 to 10;
Respondents;
/
Does 11 20
Real Parties in Intere
/
Petitioners’ Objections to Late Filed Pleadings 1
1
2 . The
3
appellat emedy ould ttend alterationand petitioner
4
5
respondisunauthorized mobilizi material site.
6 Petitioners thus object to the Courts consideration of the late filed pleadings
7
before the preliminary injunction hearing, or otherwise request a comparable extension
8
of time to file and amend their supplemental brief
9
xplai Court transmittal mailthis afternoonunexpected
circuminvolv ing ll by etitioners counsel mother law iverted er
workingsolo,could and would mor full briefedissues lating
discretionarnatur 1602greementlead and responsibl agencies
relevant SupremCourtlaw regardi CDFW responsibilities,
discussion,clarifications,improvements rief
If the Court may consider the citys late pleadings before Wedne day, petitioners
request permission to extend their deadline for supplemental brief noon tomorrow.
ctober 5, 2018 Respectfully submitted,
Susan Brandt Hawley
Petitioners’ Objections to Late Filed Pleadings 2
Willow Glen Trestle Conservancy v. City of San Jose
Santa Clara Superior Court
PROOF OF SERVICE
I am a citizen of the United States and a resident of the County of Sonoma. I am
over the age of eighteen years and not a party to this action. My business address is
P.O. Box 1659, Glen Ellen, California 95442.
On October 5, 2018, I served one true copy of:
Objections to Late Filed Pleadings
emailing to
Margo Laskowska Margo.Laskowska@sanjoseca.gov
Sara Van Loh Sara.VanLoh@doj.ca.gov
Attorneys for Respondents
I declare under penalty of perjury that the foregoing is true and is executed on
October 5, 2018, at San Francisco, California.
Susan Brandt Hawley
Document Filed Date
October 09, 2018
Case Filing Date
October 04, 2018
Category
Environmental/Toxic Tort Unlimited (30)
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Preview
1 Susan Brandt Hawley/SBN 75907 BRANDT HAWLEY LAW GROUP 2 P.O. Box 1659 3 Glen Ellen, CA 95442 707.938.3900, fax 707.938.3200 4 susanbh@preservationlawyers.com 5 6 Attorney for Petitioners 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF SANTA CLARA Willow Glen Trestle Conservancy an unincorporated association, and Friends of the Willow Glen Trestlean unincorporated Petitioners’ Objection to association; Late-Filed Pleadings Petitioners, Honorable Thomas E. Kuhnle City of San Jos City of San Jos Department of Public Works; California Department of Fish and Wildlife; and Does 1 to 10; Respondents; / Does 11 20 Real Parties in Intere / Petitioners’ Objections to Late Filed Pleadings 1 1 2 . The 3 appellat emedy ould ttend alterationand petitioner 4 5 respondisunauthorized mobilizi material site. 6 Petitioners thus object to the Courts consideration of the late filed pleadings 7 before the preliminary injunction hearing, or otherwise request a comparable extension 8 of time to file and amend their supplemental brief 9 xplai Court transmittal mailthis afternoonunexpected circuminvolv ing ll by etitioners counsel mother law iverted er workingsolo,could and would mor full briefedissues lating discretionarnatur 1602greementlead and responsibl agencies relevant SupremCourtlaw regardi CDFW responsibilities, discussion,clarifications,improvements rief If the Court may consider the citys late pleadings before Wedne day, petitioners request permission to extend their deadline for supplemental brief noon tomorrow. ctober 5, 2018 Respectfully submitted, Susan Brandt Hawley Petitioners’ Objections to Late Filed Pleadings 2 Willow Glen Trestle Conservancy v. City of San Jose Santa Clara Superior Court PROOF OF SERVICE I am a citizen of the United States and a resident of the County of Sonoma. I am over the age of eighteen years and not a party to this action. My business address is P.O. Box 1659, Glen Ellen, California 95442. On October 5, 2018, I served one true copy of: Objections to Late Filed Pleadings emailing to Margo Laskowska Margo.Laskowska@sanjoseca.gov Sara Van Loh Sara.VanLoh@doj.ca.gov Attorneys for Respondents I declare under penalty of perjury that the foregoing is true and is executed on October 5, 2018, at San Francisco, California. Susan Brandt Hawley