Preview
5/14/2019
CHRIS BAKFR, State Bar No. 181557
DEBORAH SCHWARTZ, State Bar No. 208934
BAKER CURTIS li'c SCHWARTZ, P.C.
I California Street, Suite 1250
San Francisco, CA 94111
Telephone: (415) 433-1064
Fax: (415) 366-2525
Attorneys for [Proposed] Intervenor
PAOLA CORREA
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN MATEO
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RACHEL MONIZ, on behalf of the State of Case No. 17CIV01736
12 California and aggrieved employees,
NOTICE OF ERRATA RE INCORRECT
13 CAPTION ON PROPOSED INTERVENOR
Plaintiff, PAOLA CORREA'S SECOND
14 MOTION FOR LEAVE TO INTERVENE
vs. PAPERS
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Assigned for all purposes to
16 ADECCO USA, INC., and DOES 1-50, Hon. Marie Weiner
inclusive,
17 DATE: May 24, 2019
Defendants. TIME: 10;00 a.m.
18 DEPT.: 2
19 Complaint Filed: April 18, 2017
Trial Date: September 4, 2018
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22 TO THE COURT, ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
23 PLEASE TAKE NOTICE THAT Proposed Intervenor Paola Correa hereby files the
24 following errata with the Court. On May I, 2019, Proposed Intervenor Correa filed a noticed
25 Motion for Leave to Intervene in the above-captioned matter. The body of the noticed motion
26 correctly identifies the time of the Mav 24, 2019 hearing as 10:00 a.m.
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NOTICE OF ERRATA RE INCORRECT CAPTION ON CORREA'S SECOND
MOTION FOR LEAVE TO INTERVENE PAPFRS
However, the caption on (I) Proposed Intervenor Paolo Correa's Notice of Motion and
Second Motion for Leave to Intervene; Memorandum of Points and Authorities in Support and
(2) the Declaration of Chris Baker in Support of Second Motion for Leave to Intervene gives the
incorrect hearing time as 2:00 p.m. and 10 p.m., respectively.
In addition, the caption on the above Baker Declaration and on the (3) Request for Judicial
Notice in Support of Motion for Leave to Intervene states the hearing date is on May 24, 2018.
Instead, the ~ca tion on all three of these pleadings should read that the May 24, 2019
hearing is at 10:00 a.m.
Correa's counsel apologizes for the error and any inconvenience it may have caused the
10 Court and Parties.
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DATED: May 14, 2019
13 Respectfully submitted,
14 BAKER CURTIS k SCH+ARTZ, P.C.
15 jr~ r','' ' /,
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By:',
Chris Baker.
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17 Attorneys for Proposed Intervenor
PAOLA CORREA
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NOTICE OF ERRATA RE INCORRECT CAPTION ON CORREA'S SECOND
MOTION FOR LEAVE TO INTERVENE PAPERS
I PROOF OF SERVICE
2 I am a resident of the State of California, over the age of eighteen years, and not a party to
3 the within action. My business address is 1 California Street, Suite 1250, San Francisco,
4 California. On May 14, 2019, I served the following document(s):
NOTICE OF ERRATA RE INCORRECT CAPTION ON PROPOSED INTERVENOR
PAOLA CORREA S SECOND MOTION FOR LEAVE TO INTERVENE PAPERS
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by facsimile transmission on that date. This document was transmitted by using a facsimile
machine that complies with California Rules of Court Rule 2003(3). The hansmission was
reported as complete and without error. The names and facsimile numbers of the person(s)
served are as set forth below.
10 by placing a true copy of the document(s) listed above for collection and mailing following
the firm's ordinary business practice in a sealed envelope with postage thereon fully
prepaid for deposit in the United States mail at San Francisco, California addressed as set
forth below.
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by depositing a true copy of the same enclosed in a sealed envelope, with delivery fees
13 provided for, in an overnight delivery service pick up box or office designated for
overnight delivery, and addressed as set forth below.
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by personally delivering a copy of the document(s) listed above to the person(s) at the
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address(es) set forth below.
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Carolyn Cottrell Scott Jang
Kyle Bates Mia Farber
18 SCHNEIDER WALLACECOTTRELL Adam Siegel
2000 Powell St., Suite 1400 JACKSON LEWIS P.C.
19 Emeryville, CA 94608 50 California Street, 9u Floor
Counsel for Plaintiff Rachel Moniz San Francisco, CA 94111
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Counsel for Defendant Adecco USA, Inc.
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Hon. Marie Weiner
22 San Mateo Superior Court
Dept. 2, Courtroom 2E
23 400 County Center
Redwood City, CA 94063
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Complex Dept. Judge
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PROOF OF SERVICE
1 am readily familiar with the firm's practice of collection and processing correspondence
for mailing and for shipping via overnight delivery service. Under that practice, itwould be
deposited with the U.S. Postal Service or if an overnight delivery service shipment, deposited in
an overnight delivery service pick-up box or office on the same day with postage or fees thereon
fully prepaid in the ordinary course of business.
1 declare under penalty of perjury under the laws of the State of California that the above
is true and correct. Executed on May 14, 2019, at San Francisco, California.
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;Deborah Schwartz
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PROOF OF SERVICE
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5/14/2019 CHRIS BAKFR, State Bar No. 181557 DEBORAH SCHWARTZ, State Bar No. 208934 BAKER CURTIS li'c SCHWARTZ, P.C. I California Street, Suite 1250 San Francisco, CA 94111 Telephone: (415) 433-1064 Fax: (415) 366-2525 Attorneys for [Proposed] Intervenor PAOLA CORREA IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN MATEO 10 11 RACHEL MONIZ, on behalf of the State of Case No. 17CIV01736 12 California and aggrieved employees, NOTICE OF ERRATA RE INCORRECT 13 CAPTION ON PROPOSED INTERVENOR Plaintiff, PAOLA CORREA'S SECOND 14 MOTION FOR LEAVE TO INTERVENE vs. PAPERS 15 Assigned for all purposes to 16 ADECCO USA, INC., and DOES 1-50, Hon. Marie Weiner inclusive, 17 DATE: May 24, 2019 Defendants. TIME: 10;00 a.m. 18 DEPT.: 2 19 Complaint Filed: April 18, 2017 Trial Date: September 4, 2018 20 21 22 TO THE COURT, ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 23 PLEASE TAKE NOTICE THAT Proposed Intervenor Paola Correa hereby files the 24 following errata with the Court. On May I, 2019, Proposed Intervenor Correa filed a noticed 25 Motion for Leave to Intervene in the above-captioned matter. The body of the noticed motion 26 correctly identifies the time of the Mav 24, 2019 hearing as 10:00 a.m. 27 -I- NOTICE OF ERRATA RE INCORRECT CAPTION ON CORREA'S SECOND MOTION FOR LEAVE TO INTERVENE PAPFRS However, the caption on (I) Proposed Intervenor Paolo Correa's Notice of Motion and Second Motion for Leave to Intervene; Memorandum of Points and Authorities in Support and (2) the Declaration of Chris Baker in Support of Second Motion for Leave to Intervene gives the incorrect hearing time as 2:00 p.m. and 10 p.m., respectively. In addition, the caption on the above Baker Declaration and on the (3) Request for Judicial Notice in Support of Motion for Leave to Intervene states the hearing date is on May 24, 2018. Instead, the ~ca tion on all three of these pleadings should read that the May 24, 2019 hearing is at 10:00 a.m. Correa's counsel apologizes for the error and any inconvenience it may have caused the 10 Court and Parties. 12 DATED: May 14, 2019 13 Respectfully submitted, 14 BAKER CURTIS k SCH+ARTZ, P.C. 15 jr~ r','' ' /, 16 By:', Chris Baker. '' / 17 Attorneys for Proposed Intervenor PAOLA CORREA 19 20 21 22 23 24 25 26 27 28 -2- NOTICE OF ERRATA RE INCORRECT CAPTION ON CORREA'S SECOND MOTION FOR LEAVE TO INTERVENE PAPERS I PROOF OF SERVICE 2 I am a resident of the State of California, over the age of eighteen years, and not a party to 3 the within action. My business address is 1 California Street, Suite 1250, San Francisco, 4 California. On May 14, 2019, I served the following document(s): NOTICE OF ERRATA RE INCORRECT CAPTION ON PROPOSED INTERVENOR PAOLA CORREA S SECOND MOTION FOR LEAVE TO INTERVENE PAPERS 6 by facsimile transmission on that date. This document was transmitted by using a facsimile machine that complies with California Rules of Court Rule 2003(3). The hansmission was reported as complete and without error. The names and facsimile numbers of the person(s) served are as set forth below. 10 by placing a true copy of the document(s) listed above for collection and mailing following the firm's ordinary business practice in a sealed envelope with postage thereon fully prepaid for deposit in the United States mail at San Francisco, California addressed as set forth below. 12 by depositing a true copy of the same enclosed in a sealed envelope, with delivery fees 13 provided for, in an overnight delivery service pick up box or office designated for overnight delivery, and addressed as set forth below. 14 by personally delivering a copy of the document(s) listed above to the person(s) at the 15 address(es) set forth below. 16 17 Carolyn Cottrell Scott Jang Kyle Bates Mia Farber 18 SCHNEIDER WALLACECOTTRELL Adam Siegel 2000 Powell St., Suite 1400 JACKSON LEWIS P.C. 19 Emeryville, CA 94608 50 California Street, 9u Floor Counsel for Plaintiff Rachel Moniz San Francisco, CA 94111 20 Counsel for Defendant Adecco USA, Inc. 21 Hon. Marie Weiner 22 San Mateo Superior Court Dept. 2, Courtroom 2E 23 400 County Center Redwood City, CA 94063 24 Complex Dept. Judge 25 26 27 28 PROOF OF SERVICE 1 am readily familiar with the firm's practice of collection and processing correspondence for mailing and for shipping via overnight delivery service. Under that practice, itwould be deposited with the U.S. Postal Service or if an overnight delivery service shipment, deposited in an overnight delivery service pick-up box or office on the same day with postage or fees thereon fully prepaid in the ordinary course of business. 1 declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on May 14, 2019, at San Francisco, California. l ) ;Deborah Schwartz 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE