On May 25, 2021 a Trial was filed involving a dispute between Nguyen, Phuong T. P.O. Box, and Azam, Abdul, Azam, Zameer Riaz, Berger, Chaska, Borovina, Michael, Breed, London, Choi, Jennifer Eunjin, City And County Of San Francisco, City Of San Francisco, Coaker, William J., Crashpadz Inc, Dc Crashpad, Llc, Does 1 Through 100, Excalibur Trading Llc, Guaiumi, Jim, Guy, Kevin, Jain, Sharad, Masry, Omar M, Mayor Of San Francisco, Miyamoto, Paul M., Pacific Gas And Electric Company, Pg & E Corporation, Rahaim, John, Recology East Bay, Recology Sunset Scavenger, Ruiz, Juan S., San Francisco Public Utilities Commission, Sfc Crashpad Llc, Sf Crashpadz Llc, Sfo Crashpad Llc, Tam, Tina T., Teague, Corey, Teague, Cory A., The San Francisco Public Utilities Commission, Voelker, Jason Paul, Patterson, Ryan James, for FRAUD in the District Court of San Francisco County.
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1 DENNIS J. HERRERA, State Bar #139669 City Attorney 2 MEREDITH B. OSBORN, State Bar #250467 ELECTRONICALLY Chief Trial Deputy F I L E D 3 NATASSIA KWAN, State Bar #294322 Superior Court of California, County of San Francisco Deputy City Attorney 4 Fox Plaza 09/30/2021 1390 Market Street, Sixth Floor Clerk of the Court BY: EDWARD SANTOS 5 San Francisco, California 94102-5408 Deputy Clerk Telephone: (415) 554-4272 6 Facsimile: (415) 554-3837 E-Mail: natassia.kwan@sfcityatty.org 7 8 Attorneys for Defendant CITY AND COUNTY OF SAN FRANCISCO 9 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA 11 COUNTY OF SAN FRANCISCO 12 UNLIMITED JURISDICTION 13 PHUONG T. NGUYEN, Case No. CGC-21-591803 14 Plaintiff, DEFENDANT CITY AND COUNTY OF SAN FRANCISCO’S OBJECTION TO COURT 15 vs. COMMISSIONER ACTING AS JUDGE PRO TEMPORE AT TRIAL PURSUANT TO 16 LONDON BREED; MAYOR OF SAN LOCAL RULE 3.3(A) FRANCISCO; CITY AND COUNTY OF 17 SAN FRANCISCO; PG&E CORPORATION; Date Action Filed: May 25, 2021 PACIFIC GAS AND ELECTRIC Trial Date: Not Set 18 COMPANY, A CORPORATION; RECOLOGY SUNSET SCAVENGER, A 19 BUSINESS FORM UNKNOWN; SAN FRANCISCO PUBLIC UTILITIES 20 COMMISSION; PAUL M. MIYAMOTO AKA SAN FRANCISCO COUNTY 21 SHERIFF; ZAMEER RIAZ ASAM; ABDUL AZAM; JASON PAUL VOELKER; JUAN S. 22 R UIZ AKA JUAN SALVADOR RUIZ; SHARAD JAIN; CRASHPAD LLC; 23 CRASHPADZ INC; EXCALIBUR TRADING LLC; SF CRASHPAD LLC; SF 24 CRASHPADZ LLC; SFC CRAZHPAD LLC; SFO CRASHPAD LLC; DC CRASHPAD, 25 LLC; AND DOES 1 THROUGH 100, 26 Defendants. 27 28 1 Def. CCSF’s Objection to Judge Pro Tempore; SFSC Case No. CGC-21-591803 n:\lit\li2021\210916\01557483.docx 1 PLEASE TAKE NOTICE that, pursuant to Local Rule 3.3(A), Defendant CITY AND 2 COUNTY OF SAN FRANCISCO hereby objects to a Court Commissioner acting as a Judge Pro 3 Tempore for the purposes of presiding over the trial in the above-captioned case. At this time, 4 defendant will not stipulate to a Court Commissioner acting as a Judge Pro Tempore for the purposes 5 of presiding over the trial. 6 Defendant reserves the right to consider this option and to enter such a stipulation at a later 7 time. 8 9 Dated: September 30, 2021 10 DENNIS J. HERRERA City Attorney 11 MEREDITH B. OSBORN Chief Trial Deputy 12 NATASSIA KWAN 13 Deputy City Attorney 14 By: /s/ Natassia Kwan 15 NATASSIA KWAN 16 Attorneys for Defendant CITY AND COUNTY OF SAN FRANCISCO 17 18 19 20 21 22 23 24 25 26 27 28 2 Def. CCSF’s Objection to Judge Pro Tempore; SFSC Case No. CGC-21-591803 n:\lit\li2021\210916\01557483.docx PROOF OF SERVICE 1 I, ANNAMARIE DAVIS, declare as follows: 2 I am a citizen of the United States, over the age of eighteen years and not a party to the above- 3 entitled action. I am employed at the City Attorney’s Office of San Francisco, Fox Plaza Building, 1390 Market Street, Sixth Floor, San Francisco, CA 94102. 4 On September 30, 2021, I served the following document(s): 5 DEFENDANT CITY AND COUNTY OF SAN FRANCISCO’S OBJECTION TO COURT 6 COMMISSIONER ACTING AS JUDGE PRO TEMPORE AT TRIAL PURSUANT TO LOCAL RULE 3.3(A) 7 8 on the following persons at the locations specified: Phuong T. Nguyen 9 P.O. Box 585 Brisbane, CA 94005 10 drfaith37@gmail.com 11 Plaintiff in Pro Per 12 (650) 228-6880 (Telephone) 13 in the manner indicated below: 14 BY UNITED STATES MAIL: Following ordinary business practices, I sealed true and correct copies of the above documents in addressed envelope(s) and placed them at my workplace for collection and mailing with 15 the United States Postal Service. I am readily familiar with the practices of the San Francisco City Attorney's Office for collecting and processing mail. In the ordinary course of business, the sealed envelope(s) that I placed 16 for collection would be deposited, postage prepaid, with the United States Postal Service that same day. 17 BY ELECTRONIC MAIL: Based on a court order or an agreement of the parties to accept electronic service, I caused the documents to be sent to the person(s) at the electronic service address(es) listed above. Such 18 document(s) were transmitted via electronic mail from the electronic address: annamarie.davis@sfcityatty.org in portable document format ("PDF") Adobe Acrobat. 19 I declare under penalty of perjury pursuant to the laws of the State of California that the 20 foregoing is true and correct. 21 Executed September 30, 2021, at San Francisco, California. 22 ANNAMARIE DAVIS 23 24 25 26 27 28 3 Def. CCSF’s Objection to Judge Pro Tempore; SFSC Case No. CGC-21-591803 n:\lit\li2021\210916\01557483.docx