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1 LAW OFFICE OF DAMIEN MOROZUMI
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Damien Morozumi #148554 ~
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870 Market Street, Suite 824 JUL 2 j
San Francisco, CA 94102
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Telephone: 415.434.1449
Facsimile: 415.434.8317 ‘~
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Attorney for Defendant
JYOTSNA AKULA
SUPERIOR COURT, STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN MATEO
UNLIMITED JURISDICTION
13 I Case No. 16C|V02275
I
14 ) DEFENDANT'S EX PARTE
KEVIN POKIPALA, I APPLICATION FOR AN ORDER
15 ) CONTINUING THE CURRENT TRIAL
'
I DATE AND MANDATORY
16 Plaintiff, ) SETTLEMENT CONFERENCE
I HEARING DATE, OR IN THE
17 I ALTERNATIVE, FOR AN ORDER
V. ) SHORTENING TIME TO FILE AND
18 ) SERVE NOTICE OF MOTION AND
I MOTION TO CONTINUE TRIAL AND
19 JYOTSNA AKULA, and Does 1 to 10, I MOTION TO COMPEL ANSWERS TO
I DISCOVERY AND FURTHER
I RESPONSES TO INTERROGATORIES
I
I Date: July 27, 2018
I
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Trial Date: September 4, 2018
24
25 Defendant, JYOTSNA AKULA, by and through her attorney, hereby applies to
26 this Court, Ex-Parte, for an order continuing the trial in the above-entitled action,
27 from September 4, 2018, to December 10, 2018, or to a date that is more
28 convenient for the Court, and to continue the Mandatory Settlement Conference
DEFENDANT'S EX PARTE APPLICATION FOR AN ORDER CONTINUING THE CURRENT TRIAL DATE AND
Lawomceomamaeami MANDATORY SETTLEMENT CONFERENCE HEARING DATE, OR IN THE ALTERNATIVE, FOR AN ORDER
87°s“::;:‘;‘23"w SHORTENING TIME TO FILE AND SERVE NOTICE OF MOTION AND MOTION TO CONTINUE TRIAL
San Francisco, CA 94102
Page '1 '
—|
currently scheduled for August 16, 2018, to a date to be determined by the Court.
In the alternative, defendant requests that the Court shorten the time to
serve notice of defendant’s motion to continue trial, and defendant’s motion to
compel further responses to discovery, and answers to discovery, and production of
plaintiff’s vehicle for inspection.
OLOCDNQO'l-POON
Defendant’s ex parte application is based on this Application, the Stipulation
between plaintiff’s and defendant’s counsel to continue the trial and mandatory
settlement conference, attached to the Declaration of Damien Morozumi, and
Court's finding that there is good cause to grant defendant's request to continue
the trial date,.in that there is an, an excused inability to obtain essential testimony,
documents or other material evidence despite diligent efforts (Rule 3.1332(c)(6));
there has been a significant change in the status of the case resulting in the case
being not ready for trial (Rule 3.1332(c)(7)); and, that the interests of justice are
best served by a continuance of the trial. (Rule 3.1332(d)(10)).
This is the first trial continuance requested by either party in this case.
MEMORANDUM IN SUPPORT OF EX PARTE APPLICATION FOR AN ORDER
CONTINUING TRIAL OR IN THE ALTERNATIVE SHORTENING TIME FOR MOTION
TO CONTINUE TRIAL AND MOTION TO COMPEL DISCOVERY
A. Facts of the Case:
This case arises out of a motor vehicle accident that occurred on November
13, 2014, in a private parking lot in San Mateo, California. Plaintiff filed his
complaint on November 8, 2016. Trial is currently set for September 4, 2018, and
a mandatory settlement conference is scheduled for August 16, 2018. Mediation
was to be completed by July 1 1, 2018, but has not been conducted.
Defendant seeks to continue the trial date in this action to complete
discovery and submit this case to mediation before trial.
///
28
DEFENDANT'S EX PARTE APPLICATION FOR AN ORDER CONTINUING THE CURRENT TRIAL DATE AND
Law Office of Damien Morozumi MANDATORY SETTLEMENT CONFERENCE HEARING DATE, OR IN THE ALTERNATIVE, FOR AN ORDER
870 Market Street
Suite 824 SHORTENING TIME TO FILE AND SERVE NOTICE OF MOTION AND MOTION TO CONTINUE TRIAL
San Francisco. CA 94102
'Page -2-
B. Plaintiff has not yet responded to defendant's discovery:
On December 14, 2017, defendant’s attorney served plaintiff’s counsel with
Defendant's First Set of Form lnterrogatories and First Set of Requests for
Production of Documents. (See copy of proof of service of defendant's first set of
OQCX)\IODCJ'l-I>-(A)I\J—'i
form interrogatories and requests for production of documents attached as Exhibit 1
to the Declaration of Damien Morozumi.) Plaintiff’s responses to defendant’s first
set of form interrogatories and first set of requests for production of documents
were due on January 18, 2018.
On January 16, 2018, Plaintiff's counsel requested an extension of time to
respond to defendant’s discovery. The requested extension was granted, and
plaintiff was to respond by February 1, 2018. (See email confirming the
aforementioned extension attached to the Declaration of Damien Morozumi as
Exhibit 2).
On January 31, 2018, Plaintiff's counsel requested another extension of time
to respond to said discovery. Plaintiff was granted a second extension of time to
respond to discovery up to February 16, 2018. (See Exhibit 3, attached to the
Declaration of Damien Morozumi.) On December 14, 2017, defendant served a
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demand to inspect plaintiff’s vehicle that was involved in the subject accident. The
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inspection was scheduled for January 18, 2018. (See Exhibit 4, attached to the
Declaration of Damien Morozumi.) On January 31, 2018, plaintiff’s counsel
requested that the aforementioned vehicle inspection be continued to another date.
No alternate dates were ever provided. (See Exhibit 5, attached to the Declaration
of Damien Morozumi.)
On February 16, 2018, plaintiff’s co‘unsel served partial and unverified
written responses to defendant’s first set of Form lnterrogatories. Although
plaintiff answered some of thelinterrogatories, several went unanswered, or were
only partially answered. Plaintiff did not respond to defendant’s request for
28 production of documents, and has not produced the vehicle involved in the subject
DEFENDANT'S EX PARTE APPLICATION FOR AN ORDER CONTINUING THE CURRENT TRIAL DATE AND
LawOffice of Damien Morozumi MANDATORY SETTLEMENT CONFERENCE HEARING DATE, OR IN THE ALTERNATIVE, FOR AN ORDER
870 Market Street
Suite 824 SHORTENING TIME TO FILE AND SERVE NOTICE OF MOTION AND MOTION TO CONTINUE TRIAL
San Francisco, CA 94102
Page -3-
accident for inspection.
On April 13, 2018, defendant's attorney sent a letter to plaintiff's counsel
requesting that plaintiff provide dates certain for plaintiff's vehicle inspection. (See
Exhibit 6, attached to the Declaration of Damien Morozumi.)
On May 30, 2018, defendant's attorney sent a meet and confer letter to
OGDCDNCDO'i-kCJON‘
plaintiff's counsel requesting that plaintiff provide further responses and responses
to form interrogatories and to respond to defendant’s request for production of
documents. Defendant again asked that plaintiff’s vehicle be produced for
inspection, and that verifications to discovery be provided no later than June 7,
2018. (See Exhibit 8, attached to the Declaration of Damien Morozumi.)
By email dated June 20, 2018, defendant’s attorney asked plaintiff’s counsel
to contact defendant’s attorney if there was an issue preventing plaintiff from
providing responses to defendant’s interrogatories or requests for production of
documents. (See Exhibit 8, attached to the Declaration of Damien Morozumi.)
To date, no further responses other than the partial unverified responses to
defendant’s first set of form interrogatories have been received.
Prior Continuances:
There have been no prior requests to continue the trial date in this case by
NNNNNNNNAAAA—AAAAAA
plaintiff or defendant.
\IOUUT-POON—‘OCOGJNCDU'i-POON—‘l
Stipulation to Continue Trial:
As stated above, the parties, by and through their respective counsel, have
stipulated to continue the current trial date to December 10, 2018, or to a date
more convenient for the Court. The parties have also stipulated to continue the
date for the mandatory settlement conference. The parties also request an
opportunity to submit this case to a private mediation to hopefully resolve this case
through settlement. (See Original Stipulation submitted with this Application.)
‘
M
28 ///
DEFENDANT'S EX PARTE APPLICATION FOR AN ORDER CONTINUING THE CURRENT TRIAL DATE AND
Law Office of Damien Morozumi MANDATORY SETTLEMENT CONFERENCE HEARING DATE, OR IN THE ALTERNATIVE, FOR AN ORDER
870 Market Street
Suite 824 SHORTENING TIME TO FILE AND SERVE NOTICE OF MOTION AND MOTION TO CONTINUE TRIAL
San Francisco. CA 94102
Page -4-
Good Cause Exists for Grantinq a Trial Continuance:
There is good cause for granting defendant’s ex parte request for a trial
continuance. Plaintiff’s extensive and unexplained delay in providing responses to
defendant's discovery requests has prejudiced defendant from preparing her defense
omoowoucnbooN—I»
to this case for trial. After multiple extensions were granted, defendant’s counsel
has only received unverified answers to some of the form interrogatories
propounded to his attorney, with no response to defendant’s first set of requests
for production of documents, and no alternate date to produce plaintiff’s vehicle for
inspection.
Rule 3.1332 of the California Rules of Court provides the circumstances that
constitute Good Cause for the Court to consider when a party makes an ex parte
request to continue the trial date. Rule 3.1332(c)(6) - A party’s excused inability to
obtain essential testimony, documents or other material evidence despite diligent
efforts constitutes good cause to continue the trial date. Rule 3.1332(c)(7) a
significant, unanticipated change in the status of the case resulting in the case
being not ready for trial constitutes good cause. Rule 3.1332(d)(10) allows the
Court to grant a continuance when the interests of justice are best served by a
NNNNNNNN—‘A—‘dd—‘AA—xa
continuance of the trial.
\IGO'I-POON—‘OQWNCDO'I-POONA
Conclusion:
Defense counsel’s effort to extend a professional courtesy to plaintiff’s
counsel by allowing him time to obtain the necessary information from his client to
provide answers to interrogatories, requests for production of documents, and to
produce his vehicle, should not serve as an incentive or benefit to plaintiff’s counsel
in regard to presenting his client’s case at trial. Defendant should be allowed the
benefit of a short continuance of the trial date to December 10, 2018, that would
allow defense counsel to complete discovery, or have defendant’s motion to compel
ruled on and enforced by the Court, and an opportunity to submit this matter to
28 mediation, with the benefit of completing discovery, and a fair analysis of the value
DEFENDANT'S EX PARTE APPLICATION FOR AN ORDER CONTINUING THE CURRENT TRIAL DATE AND
Law Office of Damien Morozumi MANDATORY SETTLEMENT CONFERENCE HEARING DATE, OR IN THE ALTERNATIVE, FOR AN ORDER
870 Market Street
Suite 824 SHORTENING TIME TO FILE AND SERVE NOTICE OF MOTION AND MOTION TO CONTINUE TRIAL
San Francisco, CA 94102
Page -5-
of this case. Defendant’s motion to compel was filed with the Clerk’s office, but
due to an error at the Clerk’s office, the original hearing date of August 14, 2018,
was changed to August 24, 2018, just 1 1 days before the current trial date.
Based on the foregoing, Defendant, JYOTSNA AKULA, respectfully requests
OCCJCD\IO)(J'|->(»Ji\3—‘|
that this Court grant her ex parte application for an order continuing the trial date of
September 4, 2018, to December 10, 2018, and continuing the date of the
mandatory settlement conference to a date that is convenient and available to the
Court.
In the alternative, if the Court does not grant defendant’s ex parte application
to continue the trial date and mandatary settlement conference date, then
defendant requests that the Court grant defendant’s request to shorten the time for
service of defendant’s motion to continue trial and motion to compel further
responses, and responses to discovery.
Respectfully Submitted:
Dated: July 25, 2018 LAW OFFICE OF IE OROZUMI
NMNNNNNN—l—‘A—l—l—‘Ad—l—I
By:
Damien r i
\lmm-PQJN—‘OLOGJNOm-P-OJN—‘l
Attorn r D ndant
JESUS SOTO
28
DEFENDANT'S EX PARTE APPLICATION FOR AN ORDER CONTINUING THE CURRENT TRIAL DATE AND
Law Office of Damien Mornzumi MANDATORY SETTLEMENT CONFERENCE HEARING DATE, OR IN THE ALTERNATIVE, FOR AN ORDER
870 Market Street
Suite 824 SHORTENING TIME TO FILE AND SERVE NOTICE ‘OF MOTION AND MOTION TO CONTINUE TRIAL
San Francisco. CA 94102
Page -6-
Preview
1 LAW OFFICE OF DAMIEN MOROZUMI NEED g1WMATEO(>t.'IIII~'rv-‘ Damien Morozumi #148554 ~ ‘ 870 Market Street, Suite 824 JUL 2 j San Francisco, CA 94102 ' ,fl Telephone: 415.434.1449 Facsimile: 415.434.8317 ‘~ 0». Attorney for Defendant JYOTSNA AKULA SUPERIOR COURT, STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN MATEO UNLIMITED JURISDICTION 13 I Case No. 16C|V02275 I 14 ) DEFENDANT'S EX PARTE KEVIN POKIPALA, I APPLICATION FOR AN ORDER 15 ) CONTINUING THE CURRENT TRIAL ' I DATE AND MANDATORY 16 Plaintiff, ) SETTLEMENT CONFERENCE I HEARING DATE, OR IN THE 17 I ALTERNATIVE, FOR AN ORDER V. ) SHORTENING TIME TO FILE AND 18 ) SERVE NOTICE OF MOTION AND I MOTION TO CONTINUE TRIAL AND 19 JYOTSNA AKULA, and Does 1 to 10, I MOTION TO COMPEL ANSWERS TO I DISCOVERY AND FURTHER I RESPONSES TO INTERROGATORIES I I Date: July 27, 2018 I “Dug: gggggrygtgiofig 5!... IIIIIIIIIIIIII IIIIIIIIIII’J Trial Date: September 4, 2018 24 25 Defendant, JYOTSNA AKULA, by and through her attorney, hereby applies to 26 this Court, Ex-Parte, for an order continuing the trial in the above-entitled action, 27 from September 4, 2018, to December 10, 2018, or to a date that is more 28 convenient for the Court, and to continue the Mandatory Settlement Conference DEFENDANT'S EX PARTE APPLICATION FOR AN ORDER CONTINUING THE CURRENT TRIAL DATE AND Lawomceomamaeami MANDATORY SETTLEMENT CONFERENCE HEARING DATE, OR IN THE ALTERNATIVE, FOR AN ORDER 87°s“::;:‘;‘23"w SHORTENING TIME TO FILE AND SERVE NOTICE OF MOTION AND MOTION TO CONTINUE TRIAL San Francisco, CA 94102 Page '1 ' —| currently scheduled for August 16, 2018, to a date to be determined by the Court. In the alternative, defendant requests that the Court shorten the time to serve notice of defendant’s motion to continue trial, and defendant’s motion to compel further responses to discovery, and answers to discovery, and production of plaintiff’s vehicle for inspection. OLOCDNQO'l-POON Defendant’s ex parte application is based on this Application, the Stipulation between plaintiff’s and defendant’s counsel to continue the trial and mandatory settlement conference, attached to the Declaration of Damien Morozumi, and Court's finding that there is good cause to grant defendant's request to continue the trial date,.in that there is an, an excused inability to obtain essential testimony, documents or other material evidence despite diligent efforts (Rule 3.1332(c)(6)); there has been a significant change in the status of the case resulting in the case being not ready for trial (Rule 3.1332(c)(7)); and, that the interests of justice are best served by a continuance of the trial. (Rule 3.1332(d)(10)). This is the first trial continuance requested by either party in this case. MEMORANDUM IN SUPPORT OF EX PARTE APPLICATION FOR AN ORDER CONTINUING TRIAL OR IN THE ALTERNATIVE SHORTENING TIME FOR MOTION TO CONTINUE TRIAL AND MOTION TO COMPEL DISCOVERY A. Facts of the Case: This case arises out of a motor vehicle accident that occurred on November 13, 2014, in a private parking lot in San Mateo, California. Plaintiff filed his complaint on November 8, 2016. Trial is currently set for September 4, 2018, and a mandatory settlement conference is scheduled for August 16, 2018. Mediation was to be completed by July 1 1, 2018, but has not been conducted. Defendant seeks to continue the trial date in this action to complete discovery and submit this case to mediation before trial. /// 28 DEFENDANT'S EX PARTE APPLICATION FOR AN ORDER CONTINUING THE CURRENT TRIAL DATE AND Law Office of Damien Morozumi MANDATORY SETTLEMENT CONFERENCE HEARING DATE, OR IN THE ALTERNATIVE, FOR AN ORDER 870 Market Street Suite 824 SHORTENING TIME TO FILE AND SERVE NOTICE OF MOTION AND MOTION TO CONTINUE TRIAL San Francisco. CA 94102 'Page -2- B. Plaintiff has not yet responded to defendant's discovery: On December 14, 2017, defendant’s attorney served plaintiff’s counsel with Defendant's First Set of Form lnterrogatories and First Set of Requests for Production of Documents. (See copy of proof of service of defendant's first set of OQCX)\IODCJ'l-I>-(A)I\J—'i form interrogatories and requests for production of documents attached as Exhibit 1 to the Declaration of Damien Morozumi.) Plaintiff’s responses to defendant’s first set of form interrogatories and first set of requests for production of documents were due on January 18, 2018. On January 16, 2018, Plaintiff's counsel requested an extension of time to respond to defendant’s discovery. The requested extension was granted, and plaintiff was to respond by February 1, 2018. (See email confirming the aforementioned extension attached to the Declaration of Damien Morozumi as Exhibit 2). On January 31, 2018, Plaintiff's counsel requested another extension of time to respond to said discovery. Plaintiff was granted a second extension of time to respond to discovery up to February 16, 2018. (See Exhibit 3, attached to the Declaration of Damien Morozumi.) On December 14, 2017, defendant served a NNNNNNNNA—‘A—l—l—lA—Id—l demand to inspect plaintiff’s vehicle that was involved in the subject accident. The \Imm-PwN—‘O‘DCDVOUI-PWN‘ inspection was scheduled for January 18, 2018. (See Exhibit 4, attached to the Declaration of Damien Morozumi.) On January 31, 2018, plaintiff’s counsel requested that the aforementioned vehicle inspection be continued to another date. No alternate dates were ever provided. (See Exhibit 5, attached to the Declaration of Damien Morozumi.) On February 16, 2018, plaintiff’s co‘unsel served partial and unverified written responses to defendant’s first set of Form lnterrogatories. Although plaintiff answered some of thelinterrogatories, several went unanswered, or were only partially answered. Plaintiff did not respond to defendant’s request for 28 production of documents, and has not produced the vehicle involved in the subject DEFENDANT'S EX PARTE APPLICATION FOR AN ORDER CONTINUING THE CURRENT TRIAL DATE AND LawOffice of Damien Morozumi MANDATORY SETTLEMENT CONFERENCE HEARING DATE, OR IN THE ALTERNATIVE, FOR AN ORDER 870 Market Street Suite 824 SHORTENING TIME TO FILE AND SERVE NOTICE OF MOTION AND MOTION TO CONTINUE TRIAL San Francisco, CA 94102 Page -3- accident for inspection. On April 13, 2018, defendant's attorney sent a letter to plaintiff's counsel requesting that plaintiff provide dates certain for plaintiff's vehicle inspection. (See Exhibit 6, attached to the Declaration of Damien Morozumi.) On May 30, 2018, defendant's attorney sent a meet and confer letter to OGDCDNCDO'i-kCJON‘ plaintiff's counsel requesting that plaintiff provide further responses and responses to form interrogatories and to respond to defendant’s request for production of documents. Defendant again asked that plaintiff’s vehicle be produced for inspection, and that verifications to discovery be provided no later than June 7, 2018. (See Exhibit 8, attached to the Declaration of Damien Morozumi.) By email dated June 20, 2018, defendant’s attorney asked plaintiff’s counsel to contact defendant’s attorney if there was an issue preventing plaintiff from providing responses to defendant’s interrogatories or requests for production of documents. (See Exhibit 8, attached to the Declaration of Damien Morozumi.) To date, no further responses other than the partial unverified responses to defendant’s first set of form interrogatories have been received. Prior Continuances: There have been no prior requests to continue the trial date in this case by NNNNNNNNAAAA—AAAAAA plaintiff or defendant. \IOUUT-POON—‘OCOGJNCDU'i-POON—‘l Stipulation to Continue Trial: As stated above, the parties, by and through their respective counsel, have stipulated to continue the current trial date to December 10, 2018, or to a date more convenient for the Court. The parties have also stipulated to continue the date for the mandatory settlement conference. The parties also request an opportunity to submit this case to a private mediation to hopefully resolve this case through settlement. (See Original Stipulation submitted with this Application.) ‘ M 28 /// DEFENDANT'S EX PARTE APPLICATION FOR AN ORDER CONTINUING THE CURRENT TRIAL DATE AND Law Office of Damien Morozumi MANDATORY SETTLEMENT CONFERENCE HEARING DATE, OR IN THE ALTERNATIVE, FOR AN ORDER 870 Market Street Suite 824 SHORTENING TIME TO FILE AND SERVE NOTICE OF MOTION AND MOTION TO CONTINUE TRIAL San Francisco. CA 94102 Page -4- Good Cause Exists for Grantinq a Trial Continuance: There is good cause for granting defendant’s ex parte request for a trial continuance. Plaintiff’s extensive and unexplained delay in providing responses to defendant's discovery requests has prejudiced defendant from preparing her defense omoowoucnbooN—I» to this case for trial. After multiple extensions were granted, defendant’s counsel has only received unverified answers to some of the form interrogatories propounded to his attorney, with no response to defendant’s first set of requests for production of documents, and no alternate date to produce plaintiff’s vehicle for inspection. Rule 3.1332 of the California Rules of Court provides the circumstances that constitute Good Cause for the Court to consider when a party makes an ex parte request to continue the trial date. Rule 3.1332(c)(6) - A party’s excused inability to obtain essential testimony, documents or other material evidence despite diligent efforts constitutes good cause to continue the trial date. Rule 3.1332(c)(7) a significant, unanticipated change in the status of the case resulting in the case being not ready for trial constitutes good cause. Rule 3.1332(d)(10) allows the Court to grant a continuance when the interests of justice are best served by a NNNNNNNN—‘A—‘dd—‘AA—xa continuance of the trial. \IGO'I-POON—‘OQWNCDO'I-POONA Conclusion: Defense counsel’s effort to extend a professional courtesy to plaintiff’s counsel by allowing him time to obtain the necessary information from his client to provide answers to interrogatories, requests for production of documents, and to produce his vehicle, should not serve as an incentive or benefit to plaintiff’s counsel in regard to presenting his client’s case at trial. Defendant should be allowed the benefit of a short continuance of the trial date to December 10, 2018, that would allow defense counsel to complete discovery, or have defendant’s motion to compel ruled on and enforced by the Court, and an opportunity to submit this matter to 28 mediation, with the benefit of completing discovery, and a fair analysis of the value DEFENDANT'S EX PARTE APPLICATION FOR AN ORDER CONTINUING THE CURRENT TRIAL DATE AND Law Office of Damien Morozumi MANDATORY SETTLEMENT CONFERENCE HEARING DATE, OR IN THE ALTERNATIVE, FOR AN ORDER 870 Market Street Suite 824 SHORTENING TIME TO FILE AND SERVE NOTICE OF MOTION AND MOTION TO CONTINUE TRIAL San Francisco, CA 94102 Page -5- of this case. Defendant’s motion to compel was filed with the Clerk’s office, but due to an error at the Clerk’s office, the original hearing date of August 14, 2018, was changed to August 24, 2018, just 1 1 days before the current trial date. Based on the foregoing, Defendant, JYOTSNA AKULA, respectfully requests OCCJCD\IO)(J'|->(»Ji\3—‘| that this Court grant her ex parte application for an order continuing the trial date of September 4, 2018, to December 10, 2018, and continuing the date of the mandatory settlement conference to a date that is convenient and available to the Court. In the alternative, if the Court does not grant defendant’s ex parte application to continue the trial date and mandatary settlement conference date, then defendant requests that the Court grant defendant’s request to shorten the time for service of defendant’s motion to continue trial and motion to compel further responses, and responses to discovery. Respectfully Submitted: Dated: July 25, 2018 LAW OFFICE OF IE OROZUMI NMNNNNNN—l—‘A—l—l—‘Ad—l—I By: Damien r i \lmm-PQJN—‘OLOGJNOm-P-OJN—‘l Attorn r D ndant JESUS SOTO 28 DEFENDANT'S EX PARTE APPLICATION FOR AN ORDER CONTINUING THE CURRENT TRIAL DATE AND Law Office of Damien Mornzumi MANDATORY SETTLEMENT CONFERENCE HEARING DATE, OR IN THE ALTERNATIVE, FOR AN ORDER 870 Market Street Suite 824 SHORTENING TIME TO FILE AND SERVE NOTICE ‘OF MOTION AND MOTION TO CONTINUE TRIAL San Francisco. CA 94102 Page -6-