Stipulation and OrderCal. Super. - 6th Dist.November 5, 2020200V373145 Santa Clara - Civil EFS-OZO ATTORNEv 0R PARTY WITHOUT ATTORNEY: STATE BAR N0-= 1 991 97 NAME: Amanda E. Manahan FIRM NAMEzMANAHAN FLASHMAN & BRANDON STREET ADDRESS=20 Enterorise Suite 375 FOR COURTUSE ONLY CIW: Aliso Viejo STATE: CA ZIP CODE: 92656 TELEPHONE No.2 949-831 -0303 FAX No.2 ' ’ on 4/26/2021 3 :29 P_M E-MAIL ADDRESS: amanahan©mfb-Iaw.com . REViewed By: F- M I I ler ATTORNEY FOR (name): Defendant Guidance Law. APC _ case #20CV3731 45 SUPERIOR COURT 0F CALIFORNIA, comm! 0F Santa Clara Envelope: 631 7530 STREETADDRESS: 1095 Homestead Road wwuuc ADDRESS: CITY ANDZIP CODEzSanta Clara. CA 95050 BRANCH NAME: Civi] CASE NUMBER: PLAINTIFF/PETITIONER:MAGNOLIADRHOMES. LLC. et aI. 20-CV373145 DEFENDANT/RESPONDENT:GUIDANCE LAW. APC. et aL JUDICIAL OFFICER: OTHER: DEPT: PROPOSED ORDER (COVER SHEET) NOTE: This cover sheet is to be Used to electronically file and submit to the court a proposed order. The proposed order sent electronically to the court must be in PDF format and must be attached to this cover sheet. In addition, a version of the proposed order in an editable word-processing format must be sent to the court at the same time as this cover sheet and the attached proposed order in PDF format are filed. 1- Name of the party submitting the proposed order: Guidance Law, APC 2- Title of the proposed order: Stipulation and [Proposed] Order to Continue Responsive Pleading Deadline 3. The proceeding to which the proposed order relates is: a. Description of prqceeding: Stipulation to Continue the deadline for Guidance Law to Respond to FAC b. Date and time: Aoril 30. 2021 c. Place: NIA 4. The proposed order was served on the other parties in the case. Amanda Manahan M (TYPE 0R PRINT NAME) v (SIGNATURE 0F PARTY 0R ATTORNEY) Page 1 of2 Form Adomed for Mandatory Use pROPOSED ORDER (COVER SHEET) Cal. Rules or Court, Judicid Counci of Cdifornia _ _ . rubs 2.252. 3.1 312 EFs-ozo [Rem February 1. 20m (Electronic Flllng) m.gomtscagov F. Miller EFS-OZO CASE NAME: CASE NUMBER: 20CV373145Magnoliadrhomes v. Guidance L PROOF OF ELECTRONIC SERVICE PROPOSED ORDER 1. | am at least 18 years old and not a party to this action. a- My residence or business address is (specify): 20 Enterprise, Suite 374, Aliso Viejo, CA 92656 b. My electronic service address is (specify): patrick@constructionriskmanagers.com 2_ | electronically served the Proposed Order (Cover Sheet) with a proposed order in PDF format attached, and a proposed order in an editable word-processing format as follows: a. On (name ofperson served) (If the person served is an attorney, the party or parties represented should also be stated): Dhaivat Shah, Grellas Shah LLP, attorney for Plaintiff b. To (electronic service address ofperson served): ds@grellas.com c. On (date): 4/26/21 E Electronic service of the Proposed Order (Cover Sheet) with the attached proposed order in PDF format and service of the proposed order in an editable word-processing format on additional persons are described in an attachment. | declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Date: 4/26/21 (TYPE OR PRINT NAME OF DECLARANT) (SIGNATURE OF DECLARANT) EFS-020 [Rev. February 1, 2017] PROPOSED ORDER (COVER SHEET) Page 2 of2 (Electronic Filing) \DOOxJQUI-P-WNr-a N N N N [\J [\J N N N I--‘ r-I r-d v--t rm 9-4 Ind w w w GO \l O‘x U1 ~R W N H O KO 00 fl O\ U1 ~P- U) N v-d O Amanda E. Manahan (SBN 199 197) MANAHAN FLASHMAN & BRANDON 20 Enterprise, Suite 375 Aliso Viej o, California 92656 Telephone: 949-831-0303 Email: amanahan@mfb-law.com Attorneys for Defendant GUIDANCE LAW, APC SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SANTA CLARA MAGNOLIADRHOMES LLC, a California Case No.‘ 20-CV373 145 limited liability corporation; and YOULIN WANG, an individual, STIPULATION AND [PROPOSED] ' ORDER TO CONTINUE Plaintiffs, RESPONSIVE PLEADING DEADLINE vs. , , Complaint Filed: Nov. 5, 2020GUIDANCE LAW, APC, a Cahforma PAC Filed: Dec. 11, 2020 professional corporation, et a1. Defendants. TO THIS HONORABLE COURT, TO ALL PARTIES HEREIN, AND TO THEIR ATTORNEYS OF RECORD: Defendant GUIDANCE LAW, APC, a dissolved California professional corporation (“GL”) and Plaintiffs MAGNOLIADRHOMES LLC, a California limited liability corporation and YOULIN WANG (collectively “Plaintiffs”) (GL and Plaintiffs are referred t0 jointly as the “Parties”) have agreed and stipulate, as follows: _ 1- STIPULATION AND {PROPOSED} ORDER TO CONTINUE GL’S RESPONSIVE PLEADING DEADLINE U1 ~Pu- W N \DOO\IO\ 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 26 27 28 WHEREAS, Plaintiffs filed their First Amended Complaint (“PAC”) naming GL, among other defendants, on December 11, 2020; WHEREAS, on or about February 8, 202 1 , Plaintiffs served GL with the FAC Via Notice and Acknowledgment of Receipt; WHEREAS, Plaintiffs granted GL an extension to respond t0 the PAC until March 29, 2021; WHEREAS, the Parties Stipulated to extend GL’s deadline t0 respond to the FAC until April 30, 2021 and the court granted said stipulation; WHEREAS, the Parties continue to engage in settlement discussions and desire to continue the deadline for GL to respond t0 the FAC so that the parties may continue their settlement efforts; THEREFORE, IT IS HEREBY STIPULATED AND AGREED by and between the Parties, through their respective counsel 0f record, that the deadline for GL to file and serve a responsive pleading t0 Plaintiffs’ FAC is hereby extended to May 17, 2021. IT IS SO STIPULATED. DATED: April 26, 2021 I MANAHAN FLASHMAN & BRANDON By: Wk ( j 4W/ Amanda E. Manal‘an Attorneys for Defendant Guidance Law, APC DATED: April 26, 2021 GRELLAS SHAH LLP E Bya Dhaivat H. Shah, Esq. Attorneys for Plaintiffs Magnoliadrhomes LLC and Youlin Wang -2- r STIPULATION AND {PROPOSED1 ORDER TO CONTINUE GL’S RESPONSIVE PLEADING DEADLINE \oooqo‘mhmmw N N [\3 N N [\J N N N r-d r-d r-A r-t l-A :--l r-d r-a r-A r-A OO \l C\ U1 4>- U) [\J r-- O \D 00 N 0“ U1 ¥- UJ N r-- O [PROPOSED] ORDER GOOD CAUSE appearing therefore, it is hereby ordered that the deadline for Defendant Guidance Law, APC to file and serve a responsive pleading to Plaintiffs Magnoliadrhomes LLC and Youlin Wang’s First Amended Complaint is hereby extended to May 17, 2021. Dated: IT IS SO ORDERED. , 2021 Superior Court Judge -1- STIPULATION AND [PROPOSED] ORDER TO CONTINUE LIBERTY’S RESPONSIVE PLEADING DEADLINE QOONOUU‘l-bOONA NNAAAAAAAAAA AOLOOONOUO‘ILOONAO 22 23 24 25 26 27 28 PROOF OF SERVICE I am employed in the County 0f Orange, State 0f California. I am over the age of eighteen and not a party t0 the Within action; my business address is 20 Enterprise, Suite 375, Aliso Viejo, CA 92656. My electronic service address is patrick@constructionriskmanagers.com. On April 26, 2021, I served the foregoing document(s) described as: STIPULATION AND [PROPOSED] ORDER TO CONTINUE GL’S RESPONSIVE PLEADING DEADLINE 0n all interested parties in this action as shown below as follows: SEE ATTACHED SERVICE LIST [] {BY U.S. MAIL! By placing a true copy thereof, enclosed in a sealed envelope with postage thereon fully paid for collection and mailing, under that practice it would be deposited with the U.S. Postal Service 0n that same day, With postage thereon fully prepaid at Aliso Viejo, California, in the ordinary course of business. I am familiar with the Law Firm’s practice 0f collection and processing correspondence for mailing. I am aware that 0n motion of the party served, service is presumed invalid if postal cancellation date 0r postage meter date is more than one day after date of deposit for mailing an affidavit. [X] (BY ELECTRONIC TRANSMISSION - EMAIL) I electronically served the above- referenced document(s) Via electronic email, to the persons listed 0n the attached service list. [] (BY PERSONAL DELIVERY) By placing a true copy thereof, enclosed in a sealed envelope, to be delivered by our attorney service addresses shown in the attached service list. [] (BY FACSIMILE TRANSMISSION) By transmitting a true copy thereofby facsimile transmission from facsimile number (949) 83 1-0343 t0 the interested parties t0 said action at the facsimile numbers shown in the attached Service List. Executed 0n April 26, 2021 at Aliso Viejo, California. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. \s\ Patrick Thatcher Patrick Thatcher 1 PROOF OF SERVICE QOOVOTU‘l-bOONA NNAAAAAAAAAA AOLOOONOUO‘l-thAO 22 23 24 25 26 27 28 SERVICE LIST Dhaivat H Shah, Esq. GRELLAS SHAW LLP 20400 Stevens Creek Blvd. #280 Cupertino, CA 95014 ds rellas.c0m T: (408) 255-63 10 F: (408) 255-6350 Attorney for Plaintiffs MAGNOLIADRHOMES LLC and YOULIN WANG 2 PROOF OF SERVICE