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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
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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
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Complaint filed: March 04, 2020
18 Trial Date: May 10, 2021
Dept.: 403
19 Judge: Hon. Kristi C Kapetan
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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
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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.
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12 Dated: March 15, 2021 LAW OFFICE 9 PENNY S. MOORE
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KEVIN
Uy Lp
PIEK
CL 2
Le
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Attomeys for Defendant, FRESH VALLEY
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INC. dba FRESHCO FOOD CENTER
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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.
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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
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—_____
—_____
FAX telecopied (followed br
Via Email to the Addresses I istFirstBelow
Class Mail)
Pro Se:
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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.
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23 essica
ee
‘
D) eee
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Jessica Domin guez
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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
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