On October 28, 2016 a
Order
was filed
involving a dispute between
Anna King,
and
Hyundai Motor America,
for civil
in the District Court of Placer County.
Preview
Prepared By:
Soheyl Tahsildoost (Bar No. 271294) SUPERIOR
FILED
COURTOF CALIFORNIA
Kainoa Aliviado (Bar No. 308382) COUNTY OF PLACER
THETA LAW FIRM, LLP
15901 Hawthorne Blvd., Suite 270 JAN 15 2019
Lawndale, CA 90260 JAKE CHATTERS
Telephone: (424) 297-3103 EXECUTIVE OFFICER & CLERK
Facsimile: (424) 286-2244 RR
{nN
Attorneys for defendant Hyundai Motor America =
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF PLACER
ANNA P. KING, Case No.: S-CV-0038637
10
a
ES
Plaintiff, [PROPOSED] ORDER
11
vs. aS
Nee Dept.: 42 a
12 Date: January 14, 2019
HYUNDAI MOTOR AMERICA, a Time: 8:00 a.m.
13 California Corporation, and DOES 1
through 10, inclusive, Complaint Filed: October 28, 2016
14 Trial Date: February 4, 2019
Defendants.
15
16 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
17 The Court having read, considered and heard argument on Defendant Hyundai Motor
18 America’s ex parte application to continue the trial date by stipulation of the parties, Defendants
19 Pw rt application
lication is
is: / / Jey Sve 5 1
20 [ | Granted. Trial shall be continued to ? /7 ( q in Department
21 at a.m./p.m. All associated deadlines shall be calculated as set forth by the
22 parties intheir stipulation (attached to Defendant’s ex parte application as ae A),Y yl g
23 [OR] CTO
| 6/20/15) f- 120
3 ( Q) -YL
Â¥Y 2D }; INS
log tcc f°
24 [ ] Denied. fs Tey SI
25 IT IS SO ORDERED.
26
DATED:
jan 15 2018
27
OF THE SUPERIOR COURT
28
M:\KING,
ANNA\MOTIONS\EX
PARTETOCONTINUETRIAL\EX
PARTETO CONTINUE TRIALBYSTIP.DOCX
DEFENDANT HYUNDAI MOTOR AMERICA’S EX PARTE APPLICATION TO CONTINUE TRIAL BY STIPULATION OF THE
PARTIES; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF KAINOA ALIVIADO; [PROPOSED] ORDER
PROOF OF SERVICE
(Code Civ. Proc., § 1013a(3) Revised 5-1-88)
I am over the age of 18, not a party to this action, and employed inthe county where this mailing
occurred. My business address is 15901 Hawthorne Blvd., Suite 270, Lawndale, CA 90260. On
January 14, 2019 | served the following documents described as DEFENDANT HYUNDAI
MOTOR AMERICA’S EX PARTE APPLICATION TO CONTINUE TRIAL BY
STIPULATION OF THE PARTIES; MEMORANDUM OF POINTS AND
AUTHORITIES; DECLARATION OF KAINOA ALIVIADO; [PROPOSED] ORDER on
interested parties inthis action by placing original/true copies thereof in sealed envelopes
addressed as follows:
Amy Morse (amym@knightlaw.com) Bryan C. Altman
Russell Higgins (russellh@knightlaw.com) Michael Morris-Nussbaum (m.morris-
Knight Law Group nussbaum@altmanlawgroup.net)
10250 Constellation Blvd. #2500 Altman Law Group
Los Angeles, CA 90067 10250 Constellation Blvd. #2500
(310) 552-2250 Phone Los Angeles, CA 90067
(310) 552-7973 Fax (310) 277-8481 Phone
(310) 277-8483 Fax
C] BY MAIL: I deposited such envelope inthe mail atLawndale, California. The envelope
was mailed with proper postage thereon fully prepaid. Iam "readily familiar" with the firm's
practice of collection and processing correspondence for mailing. Said mailing isdeposited with
the United States Postal Service on that same day in the ordinary course of business and there is
delivery service by United States mail atthe place so addressed. |am aware that on motion of
the party served, service is presumed invalid if postal cancellation date or postage meter date is
more than one day after date of deposit for mailing in affidavit.
C] BY PERSONAL SERVICE: | delivered such envelope by hand to the individual(s) listed
on the above service list.
x BY ELECTRONIC TRANSMISSION: I caused to be electronically transmitted such
document referenced above to the individual(s) listed on the above service list.
[] BY FACSIMILE TRANSMISSION: I transmitted the facsimile to the individual(s)
listed on the above service list atthe facsimile number listed thereon. The telephone number on
the facsimile machine | used is (424) 286-2244. The facsimile machine | used complied with
Rule 2.306 and no error was reported by the machine. Pursuant to Rule 2.306, Icaused the
machine to print a transmission record of the transmission, a copy of which isattached to this
declaration.
L] BY OVERNIGHT DELIVERY: I enclosed the documents in an envelope or package
provided by an overnight delivery carrier and addressed to the person at the above-address. |
placed the envelope or package for collection and overnight delivery at an office or a regularly
utilized drop box of the overnight delivery carrier.
I declare under penalty of perjury under the laws of the State of California that the above
is true and correct. Executed on January 14, 2019 at Lawndale, California.
po
Steven Correa
M:\KING,
ANNA\MOTIONS\EX
PARTETOCONTINUETRIAL\EX
PARTETO QCONTINUETRIALBYSTIP.DOCX
DEFENDANT HYUNDAI MOTOR AMERICA’S EX PARTE APPLICATION TO CONTINUE TRIAL BY STIPULATION OF THE
PARTIES; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF KAINOA ALIVIADO; [PROPOSED] ORDER
Document Filed Date
January 15, 2019
Case Filing Date
October 28, 2016
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Prepared By: Soheyl Tahsildoost (Bar No. 271294) SUPERIOR FILED COURTOF CALIFORNIA Kainoa Aliviado (Bar No. 308382) COUNTY OF PLACER THETA LAW FIRM, LLP 15901 Hawthorne Blvd., Suite 270 JAN 15 2019 Lawndale, CA 90260 JAKE CHATTERS Telephone: (424) 297-3103 EXECUTIVE OFFICER & CLERK Facsimile: (424) 286-2244 RR {nN Attorneys for defendant Hyundai Motor America = SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF PLACER ANNA P. KING, Case No.: S-CV-0038637 10 a ES Plaintiff, [PROPOSED] ORDER 11 vs. aS Nee Dept.: 42 a 12 Date: January 14, 2019 HYUNDAI MOTOR AMERICA, a Time: 8:00 a.m. 13 California Corporation, and DOES 1 through 10, inclusive, Complaint Filed: October 28, 2016 14 Trial Date: February 4, 2019 Defendants. 15 16 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 17 The Court having read, considered and heard argument on Defendant Hyundai Motor 18 America’s ex parte application to continue the trial date by stipulation of the parties, Defendants 19 Pw rt application lication is is: / / Jey Sve 5 1 20 [ | Granted. Trial shall be continued to ? /7 ( q in Department 21 at a.m./p.m. All associated deadlines shall be calculated as set forth by the 22 parties intheir stipulation (attached to Defendant’s ex parte application as ae A),Y yl g 23 [OR] CTO | 6/20/15) f- 120 3 ( Q) -YL ¥Y 2D }; INS log tcc f° 24 [ ] Denied. fs Tey SI 25 IT IS SO ORDERED. 26 DATED: jan 15 2018 27 OF THE SUPERIOR COURT 28 M:\KING, ANNA\MOTIONS\EX PARTETOCONTINUETRIAL\EX PARTETO CONTINUE TRIALBYSTIP.DOCX DEFENDANT HYUNDAI MOTOR AMERICA’S EX PARTE APPLICATION TO CONTINUE TRIAL BY STIPULATION OF THE PARTIES; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF KAINOA ALIVIADO; [PROPOSED] ORDER PROOF OF SERVICE (Code Civ. Proc., § 1013a(3) Revised 5-1-88) I am over the age of 18, not a party to this action, and employed inthe county where this mailing occurred. My business address is 15901 Hawthorne Blvd., Suite 270, Lawndale, CA 90260. On January 14, 2019 | served the following documents described as DEFENDANT HYUNDAI MOTOR AMERICA’S EX PARTE APPLICATION TO CONTINUE TRIAL BY STIPULATION OF THE PARTIES; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF KAINOA ALIVIADO; [PROPOSED] ORDER on interested parties inthis action by placing original/true copies thereof in sealed envelopes addressed as follows: Amy Morse (amym@knightlaw.com) Bryan C. Altman Russell Higgins (russellh@knightlaw.com) Michael Morris-Nussbaum (m.morris- Knight Law Group nussbaum@altmanlawgroup.net) 10250 Constellation Blvd. #2500 Altman Law Group Los Angeles, CA 90067 10250 Constellation Blvd. #2500 (310) 552-2250 Phone Los Angeles, CA 90067 (310) 552-7973 Fax (310) 277-8481 Phone (310) 277-8483 Fax C] BY MAIL: I deposited such envelope inthe mail atLawndale, California. The envelope was mailed with proper postage thereon fully prepaid. Iam "readily familiar" with the firm's practice of collection and processing correspondence for mailing. Said mailing isdeposited with the United States Postal Service on that same day in the ordinary course of business and there is delivery service by United States mail atthe place so addressed. |am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. C] BY PERSONAL SERVICE: | delivered such envelope by hand to the individual(s) listed on the above service list. x BY ELECTRONIC TRANSMISSION: I caused to be electronically transmitted such document referenced above to the individual(s) listed on the above service list. [] BY FACSIMILE TRANSMISSION: I transmitted the facsimile to the individual(s) listed on the above service list atthe facsimile number listed thereon. The telephone number on the facsimile machine | used is (424) 286-2244. The facsimile machine | used complied with Rule 2.306 and no error was reported by the machine. Pursuant to Rule 2.306, Icaused the machine to print a transmission record of the transmission, a copy of which isattached to this declaration. L] BY OVERNIGHT DELIVERY: I enclosed the documents in an envelope or package provided by an overnight delivery carrier and addressed to the person at the above-address. | placed the envelope or package for collection and overnight delivery at an office or a regularly utilized drop box of the overnight delivery carrier. I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on January 14, 2019 at Lawndale, California. po Steven Correa M:\KING, ANNA\MOTIONS\EX PARTETOCONTINUETRIAL\EX PARTETO QCONTINUETRIALBYSTIP.DOCX DEFENDANT HYUNDAI MOTOR AMERICA’S EX PARTE APPLICATION TO CONTINUE TRIAL BY STIPULATION OF THE PARTIES; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF KAINOA ALIVIADO; [PROPOSED] ORDER