Sheena Sales vs. Charles C. Production Group, Inc.

Opposition

Cal. Super. - 4th Dist.May 15, 2017

© 0 a S UT BR W N em N O R N O N N N N N N e e ed SESSIONS & KIMBALL LLP ELECTRONICALLY FILED Attorneys at Law Superior Court of California, Don D. Sessions, State Bar No. 072598 County of Orange dds@job-law.com 02/05/2019 at 01:26:00 PM Brittany J. Becklin, State Bar No. 278448 Clerk of the Superior Court bjb@job-law.com By e Clerk, Deputy Clerk 23456 Madero, Suite 170 Mission Viejo, California 92691 Tel: (949) 380-0900 Fax: (949) 380-8283 Attorneys for Plaintiffs SHEENA SALES AND GABRIELA SAUNDERS SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF ORANGE — CENTRAL DISTRICT SHEENA SALES, an individual, and CASE NO. 30-2017-00920216-CU-OE-CJC GABRIELA SAUNDERS, an individual, Assigned for All Purposes to: Hon. John C. Gastelum PLAINTIFFS, Dept C-11 Vv. OPPOSITION TO EX PARTE CHARLES C. PRODUCTION GROUP, APPLICATION TO CONTINUE TRIAL; INC., a California corporation, CHARLES DECLARATION OF BRITTANY J. TOWLE, an individual, and DOES 1 BECKLIN through 20, inclusive, Hearing Date: February 6, 2019 DEFENDANTS. Time: 1:30 p.m. Place: Department C-11 TO THE HONORABLE COURT: Plaintiffs hereby oppose Defendants’ ex parte application for a short continuance of trial in this action. Plaintiffs would be prejudiced if this trial is continued beyond 60 days. Plaintiffs have already waited almost two years for their day in court and are prepared for the resolution of this matter. Additionally, Plaintiffs’ counsel is responsible for several other matters currently in litigation and arbitration with deadlines in May. A 90-day continuance would be extremely difficult, if not impossible, to accommodate. " alm OPPOSITION TO EX PARTE APPLICATION TO CONTINUE TRIAL oo 0 JI S N n T RA W O N em 9 [3 S] 9 Nd no 9 No nN [S o] pi oy La e) Jd pu ) Furthermore, as Defendants’ counsel has been relieved in this matter, it is essential that Defendants and their new counsel, if any, be required to attend a mandatory settlement conference in advance of a new trial date. Wherefore, Plaintiffs respectfully request that trial not be continued more than 60 days, that parties appear for a mandatory settlement conference in advance of the new trial date, and that this Honorable Court grant any other or further relief that this Honorable Court deems just and proper. DATED: February 5, 2019 SESSIONS & KIMBALL LLP 0) py (CTE) DON D. SESSIONS BRITTANY J. BECKLIN Attorneys for PLAINTIFFS, SHEENA SALES and GABRIELA SAUNDERS 2. OPPOSITION TO EX PARTE APPLICATION TO CONTINUE TRIAL Oo 0 J AN WN A W N N N N N O N N N N NY E e em DECLARATION OF BRITTANY J. BECKLIN IN OPPOSITION TO EX PARTE APPLICATION TO CONTINUE TRIAL I, Brittany J. Becklin, declare as follows: 1 I am an attorney licensed to practice law in the State of California and currently serve as counsel to Plaintiffs Sheena Sales and Gabriela Saunders (“Plaintiffs”) in this matter. 2 This Declaration is submitted in opposition to Defendants’ Ex Parte Application to Continue Trial. The following facts arc within my personal knowledge and, if called as a witness herein, I can and will competently testify thereto. 3 Trial in this matter is currently scheduled for February 25, 2019. Plaintiffs oppose the continuance of trial past 60 days. 4. I am responsible for several other matters currently in litigation and arbitration with deadlines in May. A 90-day continuance would be extremely difficult, if not impossible, to accommodate. 5. Plaintiffs understand the need for Defendants to retain new counsel. Defendants would not be prejudiced if trial is not continued past 60 days, as they would still have adequate time to retain new counsel and prepare for trial. 6. Furthermore, as Defendants’ counsel has been relieved in this matter, it is essential that new counsel, if any, be required to attend a mandatory settlement conference in advance of a new trial date. Notice of Opposition: 7. On Friday, February 1 at 12:16 PM, I responded to an email from Defendants’ counsel and stated that I would oppose trial continuance on Plaintiffs’ behalf. 8. On Friday, February 1 at 12:18 PM, I again responded to an email from Defendants’ counsel and again stated that I would oppose trial continuance on Plaintiffs’ behalf. I hereby declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct to the best of my knowledge and belief. Executed on February 5, 2019 at Mission Viejo, California. re TTT rT 2 Brittany J. Becklin -3- DECLARATION OF BRITTANY J. BECKLIN IN OPPOSITION TO EX PARTE APPLICATION TO CONTINUE TRIAL oo 0 a A WN AR W O N N N N N N N N N ee em je PROOF OF SERVICE SHEENA SALES AND GABRIELA SAUNDERS v. CHARLES C. PRODUCTION GROUP, INC., ET AL. Orange County Superior Court, Case No. 30-2017-000929216-CU-OE-CJC I, Benjamin Smith, declare: I am a resident of the State of California and over the age of eighteen years, and not a party to the within action; my business address is 23456 Madero, Suite 170, Mission Viejo, CA 92691. On February 5, 2019, I served the within document(s): OPPOSITION TO EX PARTE APPLICATION TO CONTINUE TRIAL; DECLARATION OF BRITTANY J. BECKLIN FAX: By transmitting via facsimile the document(s) listed above to the fax number(s) set forth below on this date before 5:00 p.m. E-MAIL: By transmitting the document(s) listed above, electronically, via the e- mail addresses set forth below. OFFICE MAIL: By placing in sealed envelope(s), which I placed for collection and mailing today following ordinary business practices. Iam readily familiar with this firm’s practice for collection and processing of correspondence for mailing; such correspondence would be deposited with the U.S. Postal Service on the same day in the ordinary course of business. PERSONAL DEPOSIT IN MAIL, CERTIFIED MAIL, FIRST-CLASS MAIL, POSTAGE PREPAID WITH RETURN RECEIPT REQUESTED: By placing in sealed envelope(s), which I personally deposited with the U.S. Postal Service. REGULAR U.S. MAIL: Each such envelope was deposited with the U.S. Postal Service at Mission Viejo, California, with first class postage thereon fully prepaid. Gary S. Mobley, Attorney for Defendants GARY S. MOBLEY, A PROFESSIONAL CORPORATION 17011 Beach Blvd., Suite 900 Huntington Beach, CA 92647 gmobley(@gsmpe.com Fax: (714) 375-6672 I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on February 5, 2019, at Mission Viejo, California. Benjamin Smith PROOF OF SERVICE