Statement Case Management Conference

Cal. Super. - 6th Dist.May 21, 2019

V: GO \J Ch Ln 4k 00 b3 hi NNNNNNNNNHHHHHHHHHH 00 \J Ch Ln 4k OJ b) hi CD VD 00 ~J Ch Ln 4k U0 b) hi CD 1QCV348504 Santa Clara - Civil GARY L. JACOBSEN, ESQ, State Bar No. 122501 ANTHONY D. PLATT, ESQ., State Bar No. 192800 W&D LAW, LLP 5 Corporate Park, Suite 280 Irvine, CA 92606 (949) 837-8200 (949) 837-9300 - FAX giacobsen@wdlaw.com aplatt@wdlaw.com Attorneys for Cross-Defendant, GHIRARDELLI ASSOCIATES, INC. Y. Cha Electronically Filed by Superior Court of CA, County of Santa Clara, on 2/1 0/2022 1:08 PM Reviewed By: Y. Chavez Case #1 9CV348504 Envelope: 8264912 SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA BROSAMER & WALL, INC., Plaintiffs, V. TWINING, INC; and DOES 1 TO 20, CASE NO. 19CV348504 Assigned t0 Judge Drew Takaichi Dept. 2 CROSS-DEFENDANT GHIRARDELLI ASSOCIATES, INC.’S TRIAL CONFERENCE Defendants. STATEMENT TWINING, INC, DATE: February 22, 2022 TIME: 11:00 a.m. DEPT: 2Cross-Complainant, V. GHIRARDELLI ASSOCIATES, INC.; and ROES 1 t0 20, Cross-Defendants. vvvvvvvvvvvvv vvvvvvvvvv Complaint Filed: May 21, 2019 Trial Date: None Cross-Defendant Ghirardelli Associates, Inc. (“GA”) respectfully submits the following Trial Conference Statement: /// /// {0196014l;1} 1 TRIAL CONFERENCE STATEMENT GZ H SCHEDULING/GHIRARDELLLI’S MOTION FOR SUMMARY JUDGMENT GA was brought into this instant litigation late Via Twining, Inc.’s Cross-Complaint. On November 2, 2022, the court heard and ruled upon GA’S Demurrer to the Cross-Complaint of Twining. Thereafter, GA filed its Answer to Twining’s Cross-Complaint. Based upon the pleadings and limited discovery, GA contemplates and Will be bringing a Motion for Summary Judgment to the entirety of Twining’s Cross-Complaint, including all its causes 0f action. Therefore, GA requires sufficient time V: GO \J Ch Ln 4k 00 b3 NNNNNNNNNHHHHHHHHHH 00 \J Ch Ln 4k OJ b) hi CD VD 00 ~J Ch Ln 4k U0 b) hi CD prior to trial to prepare, file and serve its Motion for Summary Judgment. DATED : {0196014l;1} February 10, 2022 W&D LAW , LLP By: Gyry Jacobsen, Esq. Atto eys for Cross-Defendant, GHIRARDELLI ASSOCIATES, INC. 2 TRIAL CONFERENCE STATEMENT PROOF OF SERVICE (CCP §§ 1010.6, 101 1, 1013, 1013a and 2015.5; Cal. Rules ofCourt rules 2.251, 2.306) State of California, ) ) ss. County of Orange. ) I am employed in the County 0f Orange, California, over the age 0f 18 years and not a party t0 this action. My business address is: 5 Corporate Park, Suite 280, Irvine, California 92606. On February 10, 2022, I served the foregoing documents described as: GHIRARDELLI’S TRIAL CONFERENCE STATEMENT I served the documents 0n the person 0r persons below, as follows: SEE ATTACHED SERVICE LIST The documents were served by the following means: D (BY PERSONAL SERVICE) - I personally delivered the documents to the persons at the addresses listed in the Service List. (1) For a party represented by an attorney, delivery was made to the attorney or at the attorney’s office by leaving the documents in an envelope or package clearly labeled to identify the attorney being served, with a receptionist 0r individual in charge of the office, between the hours of nine in the morning and five in the evening. (2) For a party, delivery was made t0 the party 0r by leaving the documents at the party’s residence with some person not younger than 18 years 0f age between the hours 0f eight in the morning and six in the evening. D gBY MAIL! - I enclosed the documents in a sealed envelope 0r package addressed t0 the persons at the addresses listed in the Service List. D I deposited the sealed envelope with the United States Postage Service at Irvine, California, with the postage fully prepaid. D I placed the envelope for collection and mailing, following ordinary business practices. I am readily familiar with the firm’s practice 0f collection and processing correspondence for mailing with the United States Postal Service. The correspondence would be deposited with the United States Postal Service on that same day in the ordinary course 0fbusiness at Irvine, California, with postage thereon fully prepaid. D (BY CERTIFIED MAIL) - I caused such envelope(s) With postage thereon fully prepaid Via Certified Mail Return Receipt Requested to be placed in the United States Mail in Irvine, California. D BY OVERNIGHT DELIVERY I deposited the documents in a box 0r other facility regularly maintained by the express service carrier, 0r delivered t0 an authorized courier 0r driver authorized by the express service t0 receive documents, in an envelope 0r package designated by the express service carrier With delivery fees paid 0r provided for, addressed t0 the persons at the addresses listed 0n the Service List at Irvine, California. g (BY E-MAIL OR ELECTRONIC TRANSMISSION) - Based 0n a court order 0r an agreement 0f the parties t0 accept service by e-mail 0r electronic transmission, I served the documents electronically from e-mail address kwilliamson@wdlaw.com t0 the persons at the e-mail addresses indicated 0n the attached Service List. I declare under penalty 0fperjury under the laws 0f the State 0f California that the foregoing is true and correct. Date: February 10, 2022 /s/Kristi Williamson Kristi Williamson {01852044;1} Brosamer & Wall, Inc. v. Twining, Inc. Santa Clara Superior Court Case N0. C20-01533 Case N0. 19CV348504w Miles C. Holden Ellen K. Demson Stuart Eisler Lauren Pon. HANSON BRIDGETT LLP 425 Market Street, 26th Floor San Francisco, CA 94105 Telephone: (415) 777-3200 Facsimile: (415) 541-9366 mholden@hans0nbridgett.com edemson@hans0nbridgett.com seisler@hansonbridgett.com lpon@hansonbridgett.com BROSAMER & WALL, INC. Dion N. Cominos (SBN: 136522) J. Andrew Lawson (SBN: 197 1 76) GORDON REES SCULLY MANSUKHANI 275 Battery Street, Suite 2000 San Francisco, CA 941 1 1 Telephone: (41 5) 875-3 1 33 Facsimile: (415) 986-8054 dcominos@grsm.c0m alawson rsm.com cmackenzie@grsm.com TWINING, INC. {01852044;1}