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KELLY LITIGATION GROUP, INC.
NJ—I RICHARD M. KELLY, ESQ. (SBN 154504)
MICHAEL MENGARELLI ESQ. (SBN 215000)
306 Lorton Avenue
CA 94010
U.)
Burlingame,
Tel: 650-591-2282
Q
Fax: 650-591-2292
U‘I
Attorneys for Plaintiff/Cross Defendant,
LOUIS PAYCHECK dba EUROPEAN ENTERPRISES
ON
& Cross Defendant
00
KO
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN MATEO
UNLIMITED CIVIL JURISDICTION
LOUIS PAYCHECK dba EUROPEAN Case No.: 19 CIV 02595
ENTERPRISES,
. _
STIPULATION OF PARTIES RE
Plamtlff, TRIAL DATES/PROCEDURE;
VS' ORDER
PUNIT K. SARNA, et a1.,
Defendants_ Date: May 12 & 26 2021
Time: 9:00 a.m.; 2:00 p.m., resp.
Dept: 4; Hon. Nancy L. Fineman, Judge
AND RELATED CROSS-ACTION
COMES NOW, LOUIS PAYCHECK dba EUROPEAN'ENTERPRISES (“Plaintiff/
Cross Defendant”) and PUNIT K. SARNA and PUJA SARNA (“Defendants”) and PUNIT
K. SARNA (“Cross-Complainant”) and SURETEC INDEMNITY COMPANY (“Cross
Defendant”) by and through their respective counsel, stipulate and agree as follows:
l. Regarding the “Licensing Claims Trial” held May 12 & 26, 2021 the
parties agree
to a seven (7) court day time frame1n which to le/serve anyobj ectlons to the
decision once it comes out [i.e., June 10 or other time].
28
Kelly Liligation Group
PC
STIPULATION OF PARTIES RE TRIAL DATES/PROCEDURE; ORDER
R E C E I V E D
SAN MATEO counw
JUN 1 0 2021
Clerk of the Su
perior mun
v k)
2. The parties agree that the August “Construction Claims Trial” (part 2), currently set
for August 4-6; 11—13, should be vacated and re—set to one of the following dates
amenable to the court:
a. October 25, 28 and 29, 2021; or,
b. Week ofNovember 1, 2021; or,
c. Week ofNovember 8, 2021.
3. The Court shall vacate the pre-trial conference #2 set for July l9, 2021, and issue a
new pre-trial conference date; however the MSC of June 24, 2021 shall remain.
4. The purpose ofthese changes is to allow a time ‘ame for procedures post “Licensing
Claims Trial” and allow time for which'civil jury trials may be more active post
Covid.
SO AGREED.
Dated: June 4, 2021 Kelly Litigation Group, Inc.
By: /s/Richard M Kelly
Richard M. Kelly, Esq.
Michael Mengarelli, Esq.;
Attorneys for Plaintiff & Cross Defendant,
LOUIS PAYCHECK dba
EUROPEAN ENTERPRISES
Dated June 4, 2021 Anderson, McPharlin & Conners LLP
By: /s/ Elmira R. Howard
Elmira R. Howard, Esq.;
Attorneys for Cross Defendant,
SURETEC INDEWTY COMPANY
Dated: June 4, 2021 Ragghianti Freitas LLP
By: /s/Matthew A. Haulk
Matthew A. Haulk, Esq.
Attorneys for Defendants PUNIT K.
SARNA and PUJA SARNA & Cross
Complainant PUNTT K. SARNA
Kelly Litigation Group
APc
-2-
STIPULATION OF PARTIES RE TRIAL DATES/PROCEDURE; ORDER
\_
‘kr/
1
PROOF OF SERVICE
I am a citizen of the United States. My business address is 306 Lorton Avenue
2
Burlingame, CA 94010. I am employed in the County of San Mateo Where this mailing
3
occurs. I am over the age of eighteen years and not a party to the within cause.
4
I served the following document:
5
STIPULATION OF PARTIES RE TRIAL DATES/PROCEDURE; ORDER
6
7 on the parties in said action, by E—MAILING for service as designated below:
,
8
Defendant/Cross Complainant Sarna Cross Defendant Suretec Ind. Co.
Matthew A. Haulk, Esq. Elmira R. Howard, Esq.
9 Ragghianti Freitas LLP Anderson, McPharlin & Connors LLP
1101 5th Ave Ste 100 707 Wilshire Blvd., Suite 4000
10
San Rafael, CA 94901 Los Angeles, California 90017
E: mhaulk@rawllp.com E: erh@amclaw.com
1 1
12 D By First Class Mail - I caused each such envelope with rst-class postage
thereon fully pre aid, to be deposited in the United States mail at Redwood City,
13
California to sai address(es) Without known e-mails.
14
D By Hand Delivery - I caused such envelope, to be hand delivered to said
addressee(s).
1 5
Ex
D By Federal Express - I caused each such envelope to be delivered by Federal
ress Corporation at Redwood, California, with whom we have a direct billing account,
16
to e delivered to the ofce of the addressee(s) on the next business day.
.
l7
D By
the fax numbers
Facsimile
identied
- I personally served
with the persons
the document
served listed above.
named herein by facsimile to
18 % By Email —
I personally served the document named herein by email through
One Legal Services to the email addresses identied with the persons served listed above
with e—mail addresses.
19
20 I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct. Dated: June 4, 2021,,at Burlingame, California.
21
22
By: /s/ Richard M Kelly
23
Richard M. Kelly
24
25
26
27
28
Kelly Group
Litiiaptgm
-4-
STIPULATION or PARTIES RE TRIAL DATES/PROCEDURE; ORDER
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/ , CV \x r 4 J "2 \ x ‘\/' \ KELLY LITIGATION GROUP, INC. NJ—I RICHARD M. KELLY, ESQ. (SBN 154504) MICHAEL MENGARELLI ESQ. (SBN 215000) 306 Lorton Avenue CA 94010 U.) Burlingame, Tel: 650-591-2282 Q Fax: 650-591-2292 U‘I Attorneys for Plaintiff/Cross Defendant, LOUIS PAYCHECK dba EUROPEAN ENTERPRISES ON & Cross Defendant 00 KO IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN MATEO UNLIMITED CIVIL JURISDICTION LOUIS PAYCHECK dba EUROPEAN Case No.: 19 CIV 02595 ENTERPRISES, . _ STIPULATION OF PARTIES RE Plamtlff, TRIAL DATES/PROCEDURE; VS' ORDER PUNIT K. SARNA, et a1., Defendants_ Date: May 12 & 26 2021 Time: 9:00 a.m.; 2:00 p.m., resp. Dept: 4; Hon. Nancy L. Fineman, Judge AND RELATED CROSS-ACTION COMES NOW, LOUIS PAYCHECK dba EUROPEAN'ENTERPRISES (“Plaintiff/ Cross Defendant”) and PUNIT K. SARNA and PUJA SARNA (“Defendants”) and PUNIT K. SARNA (“Cross-Complainant”) and SURETEC INDEMNITY COMPANY (“Cross Defendant”) by and through their respective counsel, stipulate and agree as follows: l. Regarding the “Licensing Claims Trial” held May 12 & 26, 2021 the parties agree to a seven (7) court day time frame1n which to le/serve anyobj ectlons to the decision once it comes out [i.e., June 10 or other time]. 28 Kelly Liligation Group PC STIPULATION OF PARTIES RE TRIAL DATES/PROCEDURE; ORDER R E C E I V E D SAN MATEO counw JUN 1 0 2021 Clerk of the Su perior mun v k) 2. The parties agree that the August “Construction Claims Trial” (part 2), currently set for August 4-6; 11—13, should be vacated and re—set to one of the following dates amenable to the court: a. October 25, 28 and 29, 2021; or, b. Week ofNovember 1, 2021; or, c. Week ofNovember 8, 2021. 3. The Court shall vacate the pre-trial conference #2 set for July l9, 2021, and issue a new pre-trial conference date; however the MSC of June 24, 2021 shall remain. 4. The purpose ofthese changes is to allow a time ‘ame for procedures post “Licensing Claims Trial” and allow time for which'civil jury trials may be more active post Covid. SO AGREED. Dated: June 4, 2021 Kelly Litigation Group, Inc. By: /s/Richard M Kelly Richard M. Kelly, Esq. Michael Mengarelli, Esq.; Attorneys for Plaintiff & Cross Defendant, LOUIS PAYCHECK dba EUROPEAN ENTERPRISES Dated June 4, 2021 Anderson, McPharlin & Conners LLP By: /s/ Elmira R. Howard Elmira R. Howard, Esq.; Attorneys for Cross Defendant, SURETEC INDEWTY COMPANY Dated: June 4, 2021 Ragghianti Freitas LLP By: /s/Matthew A. Haulk Matthew A. Haulk, Esq. Attorneys for Defendants PUNIT K. SARNA and PUJA SARNA & Cross Complainant PUNTT K. SARNA Kelly Litigation Group APc -2- STIPULATION OF PARTIES RE TRIAL DATES/PROCEDURE; ORDER \_ ‘kr/ 1 PROOF OF SERVICE I am a citizen of the United States. My business address is 306 Lorton Avenue 2 Burlingame, CA 94010. I am employed in the County of San Mateo Where this mailing 3 occurs. I am over the age of eighteen years and not a party to the within cause. 4 I served the following document: 5 STIPULATION OF PARTIES RE TRIAL DATES/PROCEDURE; ORDER 6 7 on the parties in said action, by E—MAILING for service as designated below: , 8 Defendant/Cross Complainant Sarna Cross Defendant Suretec Ind. Co. Matthew A. Haulk, Esq. Elmira R. Howard, Esq. 9 Ragghianti Freitas LLP Anderson, McPharlin & Connors LLP 1101 5th Ave Ste 100 707 Wilshire Blvd., Suite 4000 10 San Rafael, CA 94901 Los Angeles, California 90017 E: mhaulk@rawllp.com E: erh@amclaw.com 1 1 12 D By First Class Mail - I caused each such envelope with rst-class postage thereon fully pre aid, to be deposited in the United States mail at Redwood City, 13 California to sai address(es) Without known e-mails. 14 D By Hand Delivery - I caused such envelope, to be hand delivered to said addressee(s). 1 5 Ex D By Federal Express - I caused each such envelope to be delivered by Federal ress Corporation at Redwood, California, with whom we have a direct billing account, 16 to e delivered to the ofce of the addressee(s) on the next business day. . l7 D By the fax numbers Facsimile identied - I personally served with the persons the document served listed above. named herein by facsimile to 18 % By Email — I personally served the document named herein by email through One Legal Services to the email addresses identied with the persons served listed above with e—mail addresses. 19 20 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Dated: June 4, 2021,,at Burlingame, California. 21 22 By: /s/ Richard M Kelly 23 Richard M. Kelly 24 25 26 27 28 Kelly Group Litiiaptgm -4- STIPULATION or PARTIES RE TRIAL DATES/PROCEDURE; ORDER