On September 27, 2007 a
Request,Application
was filed
involving a dispute between
Xxxxxx Xxxxxxx,
Xxxxxxxxxxxxxx,
Xxxxx Xxxxxxx,
and
Arun Ravidran,
for civil
in the District Court of Santa Clara County.
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ASIT PANWALA
S.
LAW OFFICE
(SBN: 224] l8)
OF ASIT PANWALA
F' LED
4 Embarcadero Center, Ste 1400 ‘
San Francisco, California 941 l l
FEB 2 6 2018
Telephone: (41 5) 766-3526
Fax: (4l5) 402-0058
asit@panwalalaw.com BY
Attorney for Plaintiffs xxxxx xxxxxxx, xxxxxxxxxxxxxx, and xxxxxx xxxxxxx
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SANTA CLARA
xxxxx xxxxxxx, as an individual
and successor in intereston behalfofthe estate CASE NUMBER: 15CV287890
ofNATVARLAL xxxxxxx, xxxxxx
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xxxxxxx, as an individual, and xxxxxx DECLARATION OF ASIT S. PANWALA
ll
xxxxxxx, as an individual IN SUPPORT OF EX-PARTE
Plaintiffs, APPLICATION TO CONTINUE TRIAL
12 vs.
l3 ARUN RAVIDRAN, an individual; and DOES $\l FIL\X
1 throu g h 25 inclusive ,
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Defendants.
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I,ASIT S. PANWALA, hereby state that Ihave personal knowledge ofthe facts set forth herein,
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and ifcalled as a witness would testify competently to the following:
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Iam the attorney of record for Plaintiffs, and filed a civil complaint in this matter 0n N0-
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vember 10,2015. The trial date is currently set for April 2, 201 8.
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The parties appeared for mediation with William Strickland on January 25, 2018. Given
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that the plaintiffs are requesting an amount greater than the policy limit, the parties believe it
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would be fruitful t0 exchange documents prior to a second day of mediation to take place 0n April
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10, 2018. See Exhibit One, Letter from William R. Strickland. The parties therefore stipulated to
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postpone the trial by sixty days to allow further mediation to take place before either side incurs
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greater costs in preparing for trial.See Stipulation to Continue filed concurrently.
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Declaration ot‘Asit Panwala inSupport ofEx-Partc Application t0Continue Trial
I declare under penalty ofperjury under the State ofCalifomia that the foregoing istrue
and correct. Executed in San Francisco, California on February 10, 201 8.
é
Asit S. Panwala
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Declaration ofAsit Panwala inSupport ofEx—Parte Application toContinue Trial
Exhibit One
WILLIAM R. STRICKLAND, P.C.
MEDIATION
MAILING ADDRESS:
OFFIce- -
54 RED HILL CIRCLE
1939 HARRISON STREET TIBURON. CA 94920
gagLEAsgsculFoamA 415-435-8460
.
415- 435-9029 (FAX)
January31,2018'
Asit S. Panwala, Esq.
Law Office of Asit Panwala
4 Embarcadero Center, Suite 1400
San Francisco, CA 941 l 1
Tel: 415/766-3526
Michael F. Brown, Esq.
Law Offices of Michael F. Brown
2010 Crow Canyon Place, Suite 100
San Ramon, CA 94583
Tel: 925/824—3 1 Ol
Re: xxxxxxx v. Ravidran, eta1.
Dear Counsel:
This confirms our mediation plan coordinated at the January 25, 201 8 session.
It became clear that it was necessary to conduct further analysis of defendant’s
ability to respond to a demand over and above the tendered policy limit. The parties
therefore agreed to exchange related documentation to be discussed at a second mediation
session scheduled for April 10, 2018.
It was also agreed that the parties would request that the Court continue the present tria1
date of April 2, 201 8 to a date at least 60 days from the scheduled second session to allow
ample time for pretrial discovery and preparation in the unlikely event the case does not
settle at that time.
I look forward to working with you toward an early conclusion to this complex litigation.
Very truly yours,
William R. Strickland
WRS:1p
Document Filed Date
February 26, 2018
Case Filing Date
September 27, 2007
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ASIT PANWALA S. LAW OFFICE (SBN: 224] l8) OF ASIT PANWALA F' LED 4 Embarcadero Center, Ste 1400 ‘ San Francisco, California 941 l l FEB 2 6 2018 Telephone: (41 5) 766-3526 Fax: (4l5) 402-0058 asit@panwalalaw.com BY Attorney for Plaintiffs xxxxx xxxxxxx, xxxxxxxxxxxxxx, and xxxxxx xxxxxxx SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CLARA xxxxx xxxxxxx, as an individual and successor in intereston behalfofthe estate CASE NUMBER: 15CV287890 ofNATVARLAL xxxxxxx, xxxxxx 10 xxxxxxx, as an individual, and xxxxxx DECLARATION OF ASIT S. PANWALA ll xxxxxxx, as an individual IN SUPPORT OF EX-PARTE Plaintiffs, APPLICATION TO CONTINUE TRIAL 12 vs. l3 ARUN RAVIDRAN, an individual; and DOES $\l FIL\X 1 throu g h 25 inclusive , 14 Defendants. 15 l6 I,ASIT S. PANWALA, hereby state that Ihave personal knowledge ofthe facts set forth herein, 17 and ifcalled as a witness would testify competently to the following: 18 Iam the attorney of record for Plaintiffs, and filed a civil complaint in this matter 0n N0- 19 vember 10,2015. The trial date is currently set for April 2, 201 8. 20 The parties appeared for mediation with William Strickland on January 25, 2018. Given 21 that the plaintiffs are requesting an amount greater than the policy limit, the parties believe it 22 would be fruitful t0 exchange documents prior to a second day of mediation to take place 0n April 23 10, 2018. See Exhibit One, Letter from William R. Strickland. The parties therefore stipulated to 24 postpone the trial by sixty days to allow further mediation to take place before either side incurs 25 greater costs in preparing for trial.See Stipulation to Continue filed concurrently. 26 27 28 1 Declaration ot‘Asit Panwala inSupport ofEx-Partc Application t0Continue Trial I declare under penalty ofperjury under the State ofCalifomia that the foregoing istrue and correct. Executed in San Francisco, California on February 10, 201 8. é Asit S. Panwala 10 11 12 l3 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 Declaration ofAsit Panwala inSupport ofEx—Parte Application toContinue Trial Exhibit One WILLIAM R. STRICKLAND, P.C. MEDIATION MAILING ADDRESS: OFFIce- - 54 RED HILL CIRCLE 1939 HARRISON STREET TIBURON. CA 94920 gagLEAsgsculFoamA 415-435-8460 . 415- 435-9029 (FAX) January31,2018' Asit S. Panwala, Esq. Law Office of Asit Panwala 4 Embarcadero Center, Suite 1400 San Francisco, CA 941 l 1 Tel: 415/766-3526 Michael F. Brown, Esq. Law Offices of Michael F. Brown 2010 Crow Canyon Place, Suite 100 San Ramon, CA 94583 Tel: 925/824—3 1 Ol Re: xxxxxxx v. Ravidran, eta1. Dear Counsel: This confirms our mediation plan coordinated at the January 25, 201 8 session. It became clear that it was necessary to conduct further analysis of defendant’s ability to respond to a demand over and above the tendered policy limit. The parties therefore agreed to exchange related documentation to be discussed at a second mediation session scheduled for April 10, 2018. It was also agreed that the parties would request that the Court continue the present tria1 date of April 2, 201 8 to a date at least 60 days from the scheduled second session to allow ample time for pretrial discovery and preparation in the unlikely event the case does not settle at that time. I look forward to working with you toward an early conclusion to this complex litigation. Very truly yours, William R. Strickland WRS:1p