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  • Paramjit Kaur vs. Freshco Food Center23 Unlimited - Other PI/PD/WD document preview
  • Paramjit Kaur vs. Freshco Food Center23 Unlimited - Other PI/PD/WD document preview
  • Paramjit Kaur vs. Freshco Food Center23 Unlimited - Other PI/PD/WD document preview
  • Paramjit Kaur vs. Freshco Food Center23 Unlimited - Other PI/PD/WD document preview
  • Paramjit Kaur vs. Freshco Food Center23 Unlimited - Other PI/PD/WD document preview
  • Paramjit Kaur vs. Freshco Food Center23 Unlimited - Other PI/PD/WD document preview
  • Paramjit Kaur vs. Freshco Food Center23 Unlimited - Other PI/PD/WD document preview
  • Paramjit Kaur vs. Freshco Food Center23 Unlimited - Other PI/PD/WD document preview
						
                                

Preview

E-FILED KEVIN PIEKUT (SBN 185353) 3/15/2021 8:38 AM LAW OFFICE OF PENNY S. MOORE Superior Court of California 677 West Palmdon Drive, Suite 106 County of Fresno Fresno, California 93704 Phone: (559) 436-1753 By: E Alvarado, Deputy Facsimile: (855) 866-7834 Email: piekutk@nationwide.com Attorneys for Defendant, FRESH VALLEY INC. dba FRESHCO FOOD CENTER SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF FRESNO 10 11 PARAMJIT KAUR, Case No.: 20CECG00815 12 Plaintiff, NOTICE OF APPLICATION AND 13 VS. APPLICATION OF DEFENDANT FRESH VALLEY, INC. FOR ORDER 14 FRESHCO FOOD CENTER, SHORTENING TIME FOR HEARING ON MOTION TO CONTINUE TRIAL 15 Defendants. DATE: March 18, 2021 16 TIME: 3:30 P.M. DEPT: 403 17 Complaint filed: March 04, 2020 18 Trial Date: May 10, 2021 Dept.: 403 19 Judge: Hon. Kristi C Kapetan 20 21 TO PLAINTIFF PARAMJIT KAUR: 22 YOU ARE HEREBY NOTIFIED THAT, on March 18, 2021, at 3:30 p.m., or as soon 23 thereafter as the matter can be heard, in Dept. 403 of this Court, located at 1130 O Street, Fresno, 24 California, 93721, Defendant, FRESH VALLEY INC. dba FRESHCO FOOD CENTER, will 25 move this Court for an order shortening time for hearing on a Motion to Continue Trial. 26 This application is made pursuant to Code of Civil Procedure Section 1005, which states 27 that the Court, or a judge thereof, may prescribe a shorter time for the Notice of motions and for 28 service and filing of moving and supporting papers. This application is made on the grounds that 1 Kaur v. Freshco Food Center Notice of Ex Parte Application for Case No. 20CECG00815 20-003725 Order Shortening Time good cause exists for issuing an order shortening time for a hearing on Defendant’s Motion to Continue Trial in that the trial date is May 10, 2021, but that the soonest the court can hear a regularly scheduled motion (to continue) is April 7, 2021. In the meantime, the Plaintiff's refusal to abide by her discovery obligations has forced the Defendant to come to court for the fourth time now to address the prejudice that the Plaintiffs delays are causing. At the hearing on February 24, 2021, the court said that it would vacate the May 10, 2021 trial date but no such order was forthcoming when the court’s written order was published. This A pplication is and will be based upon this Notice, the Memorandum filed and served herewith, the Declaration of Kevin Piekut filed and served herewith, and the complete files and 10 records in this action. 1 12 Dated: March 15, 2021 LAW OFFICE 9 PENNY S. MOORE 13 14 KEVIN Uy Lp PIEK CL 2 Le 15 Attomeys for Defendant, FRESH VALLEY 16 INC. dba FRESHCO FOOD CENTER 17 18 19 20 21 22 23 24 25 26 27 28 2 Kaur v. Freshoo Food Center Notice of Ex Parte Application for Case No. 20CECG00815 20-003725 Order Shortening Time PROOF OF SERVICE I, the undersigned, declare that I am, and was at the time of the service hereinafter mentioned, over the age of 18 years and not 677 West Palmdon Dnive, Suite 106, Fresno, States and employed in Fresno, Califomia. a Califo mia to the within action. My business address 93704; I am a citizen of the United is On the date indicated below, I served as follows a true copy of the foregoing: NOTICE OF APPLICATION AND APPLICATION OF DEFENDANT FRESH VALLEY, INC. FOR ORDER SHORTENING TIME FOR HEARING ON MOTION TO CONTINUE TRIAL d th BY U.S. MAIL: I laced a true co y thereof enclosed in a sealed envelope with postage thereon full prepaid, in e United States Post Office mail at Fresno, California, addresse as set forth below. By personally delivering, or causing to be delivered, a true copy thereof to the person at the address(es) set forth below. 10 1 adres ising (es) a true copy thereof to be delivered to the party or parties at the listed below, by and/or through the services of: 12 X FedEx Priority Overnight —_____ Express Mail 13 14 —_____ —_____ FAX telecopied (followed br Via Email to the Addresses I istFirstBelow Class Mail) Pro Se: 15 Paramjit Kaur 16 3165 West Shields Ave., Apt 213 Fresno, CA 93722 17 T: (559) 260-1758 18 I am familiar with the business practice of LAW OFFICE OF PENNY S. MOORE with regard to collection and processing of documents for mailing with the United States Postal Service. 19 The documents described above were sealed and placed for collection and mailing on the date stated below. Pursuant to said business practices, documents were deposited with the United States 20 Postal Service in Fresno, California, that same day in the ordinary course of business. 21 Executed on March 15, 2021, in Fresno, California. I declare under penalty of perjury under the laws of the State of California that the above is true and correct. 22 23 essica ee ‘ D) eee 24 Jessica Domin guez 25 26 27 28 3 Kaur v. Freshoo Food Center Notice of Ex Parte Application for Case No. 20CECG00815 20-003725 Order Shortening Time ORIGIN ID:TRMA (559) 436-1753 SHIP DATE: 15MAR21 JESSICA DOMIN' NATION! CAD; 109278538/INET4340 677 WEST PALMDON DRIVE, SUITE 106 FRESNO, CA 93704 BILL SENDER UNITED STATES US To PARAMJIT KAUR 3165 WEST SHIELDS AVE., APT 213 FRESNO CA 93722 i 260-1758 REF: 190401 DEPT: 20-003725 | I TAT HHMI MI WTA AY ee Il thal i} 1 bt ae i TUE - 16 MAR 12:00P PRIORITY OVERNIGHT toot] 7731 4792 2380 RES 93722 i WC TRMA VMNI CA-US FAT 56 os S= Es Ee < a6 2 ge ae 2 ge <2 aoe as53 SEs £2 Bao Ene ce ace fag coe £22 ees 5 Bo grou fon