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1 RYAN J. PATTERSON (SBN 277971)
EMILY L. BROUGH (SBN 284943)
2 ZACKS, FREEDMAN & PATTERSON, PC
235 Montgomery Street, Suite 400
3 San Francisco, CA 94104
Tel: (415) 956-8100
4 Fax: (415) 288-9755
5 Attorneys for Petitioners
California Renters Legal Advocacy and
6 Education Fund, Victoria Fierce, and John Moon
7 SUPERIOR COURT OF THE STATE OF CALIFORNIA
8 COUNTY OF SAN MATEO – UNLIMITED JURISDICTION
9
SAN FRANCISCO BAY AREA RENTERS CASE NO. 18CIV02105
10 FEDERATION, CALIFORNIA RENTERS
LEGAL ADVOCACY AND EDUCATION CALIFORNIA RENTERS LEGAL
11 FUND, VICTORIA FIERCE, and JOHN MOON, ADVOCACY AND EDUCATION
ZACKS, FREEDMAN & PATTERSON, PC
12 FUND, VICTORIA FIERCE, AND
Petitioners,
235 MONTGOMERY STREET, SUITE 400
JOHN MOON’S RE-NOTICE OF
SAN FRANCISCO, CALIFORNIA 94104
MOTION AND MOTION TO STRIKE,
13 vs. OR ALTERNATIVELY, TO
TAX COSTS
14
CITY OF SAN MATEO, SAN MATEO CITY
15 COUNCIL, and CITY OF SAN MATEO Date __________________,
JULY 30
2020
PLANNING COMMISSION, Time: 2:00 p.m.
16 Dept: 28
Respondents, Judge: Hon. George A. Miram
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18 TONY MEHMET GUNDOGDU and AYNUR V.
GUNDOGDU,
19
Real Parties in Interest.
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28 RE-NOTICE OF MOTION AND MOTION TO STRIKE, OR ALTERNATIVELY, TO TAX COSTS
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1 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:
2 PLEASE TAKE NOTICE 1 that on _________________, 2020, at 2:00 p.m., in Dept. 28,
3 Courtroom 2F of the San Mateo Superior Court, located at 400 County Center, Redwood City, CA,
4 Petitioners CALIFORNIA RENTERS LEGAL ADVOCACY AND EDUCATION FUND,
5 VICTORIA FIERCE, AND JOHN MOON, will hereby move this Court, pursuant to Code of Civ.
6 Proc. sections 1095 and 1033.5, Gov. Code section 65589.5, and CA Rule of Court 3.1700, for an
7 order striking and/or taxing costs of Respondents, which were sought in their memorandum of costs
8 filed on December 20, 2019. Petitioners seek an order striking the entire costs bill, or alternatively,
taxing the entire claimed administrative record costs in the amount of $18,717.50 or alternatively
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reducing the claimed administrative record costs to $2,264.70, in addition to taxing other claimed costs
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in the amount of $2,713.00.
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ZACKS, FREEDMAN & PATTERSON, PC
This Motion is based on this Re-notice, the Memorandum of Points and Authorities filed and
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235 MONTGOMERY STREET, SUITE 400
SAN FRANCISCO, CALIFORNIA 94104
served on January 31, 2020 (and re-served herewith), the Request for Judicial Notice filed and served
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on January 31, 2020 (and re-served herewith), and any additional evidence and argument to be filed
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or presented at the hearing on this motion.
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16 Dated: May 4, 2020 ZACKS, FREEDMAN & PATTERSON, PC
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18 ____________________________
Emily L. Brough
19 Attorney for Petitioners
CALIFORNIA RENTERS LEGAL
20 ADVOCACY AND EDUCATION
FUND, VICTORIA FIERCE, and
21 JOHN MOON
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26 This Re-Notice supersedes the Notice of this motion filed and served on January 31, 2020, which
originally noticed this hearing for March 19, 2020, but was thereafter removed from the calendar via
27 Court order due to the Covid-19 crisis. Per the Court’s order filed on March 19, 2020, Petitioner
hereby re-notices this motion.
28 RE-NOTICE OF MOTION AND MOTION TO STRIKE, OR ALTERNATIVELY, TO TAX COSTS
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1 RYAN J. PATTERSON (SBN 277971) EMILY L. BROUGH (SBN 284943) 2 ZACKS, FREEDMAN & PATTERSON, PC 235 Montgomery Street, Suite 400 3 San Francisco, CA 94104 Tel: (415) 956-8100 4 Fax: (415) 288-9755 5 Attorneys for Petitioners California Renters Legal Advocacy and 6 Education Fund, Victoria Fierce, and John Moon 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 COUNTY OF SAN MATEO – UNLIMITED JURISDICTION 9 SAN FRANCISCO BAY AREA RENTERS CASE NO. 18CIV02105 10 FEDERATION, CALIFORNIA RENTERS LEGAL ADVOCACY AND EDUCATION CALIFORNIA RENTERS LEGAL 11 FUND, VICTORIA FIERCE, and JOHN MOON, ADVOCACY AND EDUCATION ZACKS, FREEDMAN & PATTERSON, PC 12 FUND, VICTORIA FIERCE, AND Petitioners, 235 MONTGOMERY STREET, SUITE 400 JOHN MOON’S RE-NOTICE OF SAN FRANCISCO, CALIFORNIA 94104 MOTION AND MOTION TO STRIKE, 13 vs. OR ALTERNATIVELY, TO TAX COSTS 14 CITY OF SAN MATEO, SAN MATEO CITY 15 COUNCIL, and CITY OF SAN MATEO Date __________________, JULY 30 2020 PLANNING COMMISSION, Time: 2:00 p.m. 16 Dept: 28 Respondents, Judge: Hon. George A. Miram 17 18 TONY MEHMET GUNDOGDU and AYNUR V. GUNDOGDU, 19 Real Parties in Interest. 20 21 22 23 24 25 26 27 28 RE-NOTICE OF MOTION AND MOTION TO STRIKE, OR ALTERNATIVELY, TO TAX COSTS 1 1 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD: 2 PLEASE TAKE NOTICE 1 that on _________________, 2020, at 2:00 p.m., in Dept. 28, 3 Courtroom 2F of the San Mateo Superior Court, located at 400 County Center, Redwood City, CA, 4 Petitioners CALIFORNIA RENTERS LEGAL ADVOCACY AND EDUCATION FUND, 5 VICTORIA FIERCE, AND JOHN MOON, will hereby move this Court, pursuant to Code of Civ. 6 Proc. sections 1095 and 1033.5, Gov. Code section 65589.5, and CA Rule of Court 3.1700, for an 7 order striking and/or taxing costs of Respondents, which were sought in their memorandum of costs 8 filed on December 20, 2019. Petitioners seek an order striking the entire costs bill, or alternatively, taxing the entire claimed administrative record costs in the amount of $18,717.50 or alternatively 9 reducing the claimed administrative record costs to $2,264.70, in addition to taxing other claimed costs 10 in the amount of $2,713.00. 11 ZACKS, FREEDMAN & PATTERSON, PC This Motion is based on this Re-notice, the Memorandum of Points and Authorities filed and 12 235 MONTGOMERY STREET, SUITE 400 SAN FRANCISCO, CALIFORNIA 94104 served on January 31, 2020 (and re-served herewith), the Request for Judicial Notice filed and served 13 on January 31, 2020 (and re-served herewith), and any additional evidence and argument to be filed 14 or presented at the hearing on this motion. 15 16 Dated: May 4, 2020 ZACKS, FREEDMAN & PATTERSON, PC 17 18 ____________________________ Emily L. Brough 19 Attorney for Petitioners CALIFORNIA RENTERS LEGAL 20 ADVOCACY AND EDUCATION FUND, VICTORIA FIERCE, and 21 JOHN MOON 22 23 24 25 1 26 This Re-Notice supersedes the Notice of this motion filed and served on January 31, 2020, which originally noticed this hearing for March 19, 2020, but was thereafter removed from the calendar via 27 Court order due to the Covid-19 crisis. Per the Court’s order filed on March 19, 2020, Petitioner hereby re-notices this motion. 28 RE-NOTICE OF MOTION AND MOTION TO STRIKE, OR ALTERNATIVELY, TO TAX COSTS 2