arrow left
arrow right 
						
                                
Preview

                                ln i
                                                        owes aa Agi ono REY TIT JA


                                                i
                        -



AR NO.        148916)

78160)                              F I L ECODUNTY
                              AL    AMEDA
4AN and SCHELEY
                                      SEP 13 2021
                            CLERK    OF TH
                            By
                                                    Deputy




ES, INC
S, LP
  LP
Y, LLC

 RTY,    LLC and OAK-1428 JACKSON,               LLC

IF THE STATE OF CALIFORNIA

— UNLIMITED CIVIL JURISDICTION



              Case No. RG21100261
zhalf
ated          Case Assigned to Hon. Evelio Grillo in
              Dept. 21 for all Purposes


              STIPULATION AND [PROPOSED]
              ORDER TO EXTEND DEFENDANTS
              NEVEO MOSSER, MOSSER
              COMPANIES, INC., 553 SYCAMORE
              STREET ASSOCIATES, LP
                                                                            3
              1428 JACKSON STREET ASSOCIATES
              LP, OAK 406 VAN BUREN AVE                                     js
              PROPERTY, LLC, OAK-553
                                                                            cm
r,            SYCAMORE, LLC, OAK 1425                                       Cc
              HARRISON STREET PROPERTY, LLC
 Y,           AND OAK-1428 JACKSON, LLC’S TIME
              TO RESPOND TO THE FIRST
              AMENDED COMPLAINT

‘DI           Complaint filed:      05/25/2021
              First Amended Complaint filed: 06/28/2021
igh
              Trial date:    None set




          ]
) DEFENDANTS’     TIME TO RESPOND TO THE FIRST AMENDED COMPLAINT
Aosser, The Mosser Companies, Inc., 553 Sycamore

: Associates, LP, Oak 406 Van Buren Ave Property,

Harrison Street Property, LLC and Oak-1428 Jackson,

Plaintiffs, the "Parties"), jointly, by and through their

ate and agree as follows:

‘omplaint in this case on May 25, 2021, and their First

18, 202) (the “Complaints");

2ndants to be served with the summons and Complaints



ntly obtained outside counsel;

2xtended Defendants’ deadline to respond to the First

last day to respond to the Complaint is September 13,



sd to extend Defendants’ deadline to respond to the First

od of time, through and including October 4, 2021;

the Court to extend Defendants’ deadline to respond to
fendants sufficient time to assess and analyze the claims



tober 4, 2021, will not cause undue delay or prejudice to
y because there are no immediate case related deadlines

dline;

California Rule of Court 3.110, the Parties hereby

rich Defendants must respond to the First Amended

4, 2021.




           2
) DEFENDANTS’ TIME TO RESPOND TO THE FIRST AMENDED COMPLAINT
CLAPP, MORONEY, VUGINICH, BEEMAN
        and SCHELEY
                                         |

        By
               L. THEODORE SCHELEY I, ESQ
               X. JACKSON ZHOU, ESQ
                Attorneys for Defendants
                NEVEO MOSSER, MOSSER
                COMPANIES, INC.,
                553 SYCAMORE STREET
                ASSOCIATES, LP,
                1428 JACKSON STREET
                ASSOCIATES, LP,
                OAK 406 VAN BUREN AVE
                PROPERTY, LLC,
                OAK-553 SYCAMORE, LLC,
                OAK 1425 HARRISON STREET
                PROPERTY, LLC and 'OAK-1428
                JACKSON, LLC


        SALINAS LAW GROUP




        ALLL    RGBERT SALINAS
                ROCIO TORIZ
                                             |

                ANNIE B. BANH
                Attomeys for Plaintiffs |




         3
2 DEFENDANTS’ TIME TO RESPOND TO THE Fi RST      AMENDED COMPLAINT
|
JPOSED] ORDER
                                      ‘

AND GOOD CAUSE APPEARING THEREFORE:
                                          ‘


nts Neveo Mosser, The Mosser Companies,           Inc., 553

ickson Street Associates, LP, Oak 406 Van Buren Ave

Oak 1425 Harrison Street Property, LLC and Oak-1428
nded Complaint is extended to October 4, 2021.

                                              |

   JUDGE OF THE SUPERIOR COURT




        4
) DEFENDANTS’ TIME TO RESPOND TO THE FIRST AMENDED COMPLAINT
‘tal. vy. NEVEO MOSSER, et al.
yerior Court Case No. RG21 100261


‘OF SERVICE - Civil
2. §§ 1011, 1013, 1031a, 2015.5) '
                                         ‘
1OD OF SERVICE:

            o By Overnight Delivery
nile          By E-Mail/Electronic Transmission

 and am employed in the County of San Mateo, State of
3 years and not a party to the within action.

3ayhill Drive, Suite 300, San Bruno, CA 94066.

ed to be served a true and correct copy of the document
                                             ‘



SED] ORDER TO EXTEND DEFENDANTS
JIMPANIES, INC., 553 SYCAMORE STREET
i\ACKSON STREET ASSOCIATES, LP,
OPERTY, LLC, OAK-553 SYCAMORE, LLC,
OPERTY, LLC AND OAK-1428 JACKSON, LLC'S
THE FIRST AMENDED COMPLAINT

rsons below, as follows:



            Leah F. Simon-Weisberg, Esq.
            Jacqueline E. Zaneri, Esq.
            Ethan L. Silverstein, Esq.
                                                 '
            ACCE Institute
            P.O. Box 7226
            Oakland, CA 94601
            Tel: (510) 916-2034
            email: lsw@calorganize.org
            email: jzaneri@calorganize.org
            email: esilverstein@calorganize.org
            Attorneys for PLAINTIFFS and Putative
ive         Class




        1
ROOF OF SERVICE
Anna McLean, Esq.
            Joseph Sakai, Esq.
            Sheppard Mullin Richter & Hampton LLP
            4 Embarcadero Center, 17'* Floor
            San Francisco, CA 94111
            Tel: (415) 434-9100
            Fax: (415) 434-3947
ve          email: amclean@sheppardmullin.com
            email: jsakai@sheppardmullin.com
            Attorneys for Defendants
            OAK9 PORTFOLIO OWNER, LP and
            PACH AFFORDABLE HOLDINGS, LLC



dllowing means (specify):

JERVICE. | personally delivered the documents to the
addresses listed in item 4. (1) For a party represented by
zlivery was made to the attorney or at the attorney's office
: documents in an envelope or package clearly labeled to
torney being served with a receptionist or an individual
re Office. (2) For a party, delivery was made to the party
 the documents at the party's residence with some person
  8 years of age between the hours of eight in the morning
 evening.

ATES   MAIL. I enclosed       the documents     in a sealed
ackage addressed to the persons at the addresses in item 4
me):

sealed envelope with the United States Postal Services,
ge fully prepaid.

/elope for collection and mailing, following our ordinary
tices. | am readily familiar with this business's practice
and processing correspondence for mailing. On the same
espondence is placed for collection and mailing, it is
the ordinary course of business with the United States
:, ina sealed envelope with postage fully prepaid.

 County where the mailing occurred.         The envelope or
ino, California, County of San Mateo.

‘DELIVERY. | enclosed the documents in an envelope
‘d by an overnight delivery carrier and addressed to the
resses in item 4. | place the envelope or package for
night delivery at an office or a regularly utilized drop box
livery carrier.
                                        '

SERVICE. | served the documents by placing them in
kage addressed to the persons at the addresses listed in
ig them to a professional messenger service for service.


        2
ROOF OF SERVICE
IISSION. Based on an agreement of the parties to accept
mission, | faxed the documents to, the persons at the fax
em 4. No error was reported by the fax machine that I
e record of the fax transmission, which I printed out, is


ELECTRONIC             TRANSMISSION.         Based on a court
:nt of the parties to accept service by e-mail or electronic
sed the documents to be sent to the persons at the email
item 4.       I did not receive, within a reasonable time after
any   electronic      message   or other   indication   that the
isuccessful.

([RONIC TRANSMISSION. Only by e-mailing the
persons at the e-mail address(es) listed based on notice
z the Coronavirus (Covid-19) pandemic, this office will
y, not able to send physical mail as usual, and is
‘ electronic mail. No electronic message or other
ransmission was unsuccessful was received within a
*r the transmission,

perjury under the laws of the State of California that the

oyed in the offices of a member of the bar of this court at
declare under penalty of perjury that the foregoing is true


at San Bruno, California.


                            LindaM. Carcamo- /3/
                         Linda M. Carcamo




          3
X%OOF OF SERVICE