Ex Parte Application Notice Required

Cal. Super. - 6th Dist.August 22, 2019

_I O(DWVO’UI-bwk) NORA FRIMANN, Assistant City Attorney (#93249) CHRISTOPHCER CREECH, Deputy City Attorney (#293037) Office of the ity Attorney 200 East Santa Clara Street, 16th Floor AUG 3 0 2mg San Jose, California 95113-1905 Telephone Number: (408) 535-1900 Facsimile Number: (408) 998-3131 av E-mail Address: cao.main@sanjoseca.gov RICHARD DOYLE, City Attorney (#88625) F l LED Attorneys for People of the State of California, Ex Re|., City Attorney of the City of San Jose and the City of San Jose SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CLARA PEOPLE 0F THE STATE 0F Case NO- 190V353595 CALIFORNIA, ex re|., CITY ATTORNEY OF THE C'TY OF SAN JOSE; CITY OF NOTICE AND EX PARTE MOTION TO FILE UNDER SEAL SAN JOSE, Plaintiffs, Exempt pursuant to Govt. Code § 6103 v. Date: August 30, 2019 LE DUYEN BEAUTY CENTER, an Time: 8:15 a.m, unincorporated association; TU KHA Room: DIAZ, an individual d/b/a Le Duyen Judge: Beauty Center; L & N LIMITED PARTNERS, a limited partnership, NGA KIEU LE, an individual d/b/a L & N Limited Partners; TRUONG LE, an individual d/b/a L & N Limited Partners; HUNG LEE, an individual d/b/a L & N Limited Partners; MICHAEL LONDON DITTUS, an individual d/b/a L & N Limited Partners; and DOES 1 through 20, inclusive; Defendants. PLEASE TAKE NOTICE that on August 30, 2019, at 8:15 a.m., or as soon thereafter as the matter may be heard, in the above-entitled court, located at 191 N. First 1 NOTICE AND EX PARTE MOTION TO FILE UNDER SEAL 19CV353595 1644867 (DmNODU'l-wa-t NNNNNNNNN-l-A-I-s-A-A-LAAA memAwN-tOCDmVOUI-AwN-IO Street, San Jose, California, the CITY OF SAN JOSE (“City”) and the PEOPLE OF THE STATE OF CALIFORNIA (“People"), by and through Richard Doyle, City Attorney for the City of San José (hereinafter, collectively, “Plaintiffs") will and hereby do move the Court ex parte pursuant to Rules of Court, Rules 2.550 and 2.551 for an order to file under seal through partial redaction the following documents related to its Ex Parte Motion for Temporary Restraining Order and Order to Show Cause re Preliminary Injunction: 1. Declaration of Officer- ISO Plaintiffs' Ex Parte Motion for Temporary Restraining Order and Order to Show Cause Re: Preliminary Injunction 2. Declaration of Officer- ISO Plaintiffs’ Ex Parte Motion for Temporary Restraining Order and Order to Show Cause Re: Preliminary Injunction 3. Declaration of Officer- ISO Plaintiffs’ Ex Parte Motion for Temporary Restraining Order and Order to Show Cause Re: Preliminary |njunction 4. Memorandum of Points and Authorities ISO Plaintiffs’ Ex Parte Motion for Temporary Restraining Order and Order to Show Cause Re: Preliminary Injunction Plaintiffs’ Motion is based on this Notice, the accompanying Memorandum of Points and Authorities, the supporting Declarations of Richard Galea and Christopher Creech, as well as the records and files in the above~referenced action, oral argument, and any other material properly considered by the Court. Respectfully submitted, Dated: August 29, 2019 RICHARD DOYLE, City Attorney gyfl- CHRISTO ER CREECH Deputy ity Attorney Attorneys for CITY OF SAN JOSE 2 NOTICE AND EX PARTE MOTION TO FILE UNDER SEAL 19CV353595 1644867