Motion_to_continue_trialMotionCal. Super. - 4th Dist.June 18, 201810 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CARROLL, KELLY, TROTTER, FRANZEN & McBRIDE MARK V. FRANZEN (STATE BAR NO. 079470) JENNIFER L. STURGES (STATE BAR NO. 155703) CARLEY M. RYCKMAN (STATE BAR NO. 314621) 111 West Ocean Boulevard, 14th Floor Post Office Box 22636 Long Beach, California 90801-5636 Telephone No. (562) 432-5855 / Facsimile No. (562) 432-8785 Attorneys for Defendants, SAYED J. MIRRAFATI, M.D. (erroneously served and sued as Sid J. Mirrafati, M.D.), SAYED J. MIRRAFATI, MD, PC dba MIRA AESTHETIC MEDICAL CENTER & SPA (erroneously served and sued as Mira Aesthetic Medical Center, Inc. and Mira Aesthetic Medical Center and Spa), and ELITE SURGERY CENTER SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ORANGE — CENTRAL JUSTICE CENTER PALOMA ROCIO CAMUNEZ CASE NO.: 30-2018-00999859 Plaintiff, NOTICE OF MOTION AND MOTION TO CONTINUE TRIAL AND ALL RELATED Vs. DATES; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION SID J. MIRRAFATI, M.D; BROWNELL OF CARLEY M. RYCKMAN PAYNE, M.D.; ELITE SURGERY CENTER; MIRA AESTHETIC MEDICAL CENTER, DATE: APRIL 16, 2020 INC.; MIRA AESTHETIC MEDICAL TIME: 1:30 P.M. CENTER AND SPA; PROPERTY OWNERS DEPT.: C-13 OF PROPERTY LOCATED AT 3140 RED, RESV.: 73187760 HILL, SUITE 150, COSTA MESA, CALIFORNIA 92626 Defendants. ASSIGNED FOR ALL PURPOSES TO JUDGE HON. MELISSA MCCORMICK DEPARTMENT: C-13 Complaint Filed: March 17, 2016 Trial Date: February 24, 2020 TO THE COURT, ALL PARTIES, AND TO THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that on April 16, 2020, at 1:30 p.m., or as soon thereafter as the matter may be heard in Department C-13 of the above titled court, located at 700 Civic Center Drive West, Santa Ana, CA 92701, Defendants, SAYED J. MIRRAFATI, M.D., SAYED J. MIRRAFATI, MD, PC dba MIRA AESTHETIC MEDICAL CENTER & SPA, and ELITE SURGERY CENTER, will and hereby do move the Court for an Order that the current trial of E:\52\5796-01\PLD\Motion To Continue Trial. Docx 1 MOTION TO CONTINUE TRIAL AND ALL RELATED DATES 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 February 24, 2020, be continued to May 4, 2020, or to an alternative date convenient to the Court, as well as the availability of trial counsel, the parties, the witnesses, and the experts. If this motion is granted, this would be the third continuance of trial in this matter and there is good cause to continue trial. Defense Counsel has been engaged in trial in the matter of Liv. Lee, M.D. (San Bernardino County Case No. CIVIDS 1621591), which began in mid- October and is continuing in San Bernardino County. Plaintiff’s Counsel has attempted to notice the deposition of Defendant, Dr. Mirrafati. Unfortunately, because of the Li trial, the soonest dates Defense Counsel can offer for this deposition are January 7, 9, or 13, 2020. Additionally, Defense Counsel seeks to take the deposition of Plaintiff’s expert, Dr. Moneer. Dr. Moneer is available for deposition on January 13, 2020. This motion is made pursuant to California Rules of Court, Rule 3.1332 and Code of Civil Procedure section 128, and is based upon this Notice, the attached Memorandum of Points and Authorities, the declaration of Carley M. Ryckman, and all pleadings, motions, and papers filed in this action. This Motion is made on the grounds that Defendants have demonstrated good cause to continue trial, given that Defendants are requesting a brief continuance of only 70 days; the need for a continuance is based on the additional time required to schedule the depositions of both Dr. Mirrafati and Plaintiffs Expert, Dr. Moneer; and no party will be prejudiced by the continuance, in fact, the parties have stipulated to the continuance. DATED: December 16,2019 CARROLL, KELLY, TROTTER, FRANZEN & McBRIDE By: /s/ Carley M. Ryckman MARK V. FRANZEN JENNIFER L. STURGES CARLEY M. RYCKMAN Attorneys for Defendants, SAYED J. MIRRAFATI, M.D., SAYED J. MIRRAFATI, MD, PC dba MIRA AESTHETIC MEDICAL CENTER & SPA and ELITE SURGERY CENTER E:\52\5796-01\PLD\Motion To Continue Trial. Docx 2 MOTION TO CONTINUE TRIAL AND ALL RELATED DATES 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MEMORANDUM OF POINTS AND AUTHORITIES I. INTRODUCTION There is good cause to continue trial in this matter, which is currently set February 24, 2020. Good cause in this instance includes Defense Counsel’s current trial in the matters of Li v. Lee, M.D. (San Bernardino County Case No. CIVIDS 1621591). Trial began on October 16, 2019 and is ongoing. As of the date of the filing of this motion, Defense Counsel is awaiting a jury verdict. [Declaration of Carley M. Ryckman (hereinafter ”"Ryckman Dec.”) 9 3.] Plaintiff’s Counsel has attempted to notice the deposition of Dr. Mirrafati. Unfortunately, because of the Li trial, the soonest dates Defense Counsel can offer are January 7, 9, or 13, 2020. Defense Counsel also plans to take the deposition of Plaintiff's expert, Dr. Moneer. Dr. Moneer is available for his deposition on January 13, 2020 and the deposition has been noticed for that date. (Ryckman Dec. 44.) Trial in this matter is currently set for February 24, 2020 and will be impacted by Defense Counsel’s scheduled trial, and the need for the depositions of both Defendant, Dr. Mirrafati and Plaintiff’s Expert, Dr. Moneer. (Ryckman Dec. § 5.) The parties have agreed to continue trial just as long as is necessary to permit Defense Counsel to complete the subject trial and to allow the opportunity to conduct these two depositions. (Ryckman Dec. q 6; Exhibit “C”.) Defense Counsel attempted to have the trial date continued for 70 days by way of ex parte application on December 3, 2019. On December 2, 2019, before the Court entertained any oral arguments on the matter, the Court transmitted a minute order indicating that the ex parte application for a brief 70-day continuance had been denied. As such, Defense Counsel had no choice but to file this motion. (Ryckman Dec. 7; Exhibit “B”.) II. THE COURT HAS AUTHORITY TO CONTINUE TRIAL IN THIS MATTER Code of Civil Procedure section 128 enables the Court to “provide for the orderly conduct of proceedings before it”. Well-settled case law recognizes that a court is vested with “broad discretion” in exercising its inherent power to grant continuances. “The granting or refusal of a continuance is a matter of discretion with the trial court.” (Cohen v. Herbert (1960) E:\52\5796-01\PLD\Motion To Continue Trial. Docx 3 MOTION TO CONTINUE TRIAL AND ALL RELATED DATES 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 186 Cal.App.2d 488, 493; see also, People ex rel Department of Public Works v. Busick (1968) 259 Cal.App.2d 744.) In Curtis v. Underwood (1894) 101 Cal. 661, the Supreme Court stated, “[t]hat the court had power to continue the hearing . . . we do not doubt. The jurisdiction to hear and determine a cause or proceeding involves the power to postpone for good cause the time of hearing, unless prohibited by positive law.” (Id. at 669; see also Park Motors v. Cozens (1975) 49 Cal.App.3d 12, 18). Moreover, trial courts can continue pending actions independent of statutory provisions. (Powers v. Bakersfield City School Dist. (1984) 157 Cal.App.3d 560.) California Appellate law favors liberality in granting continuances where, as here, a delay does not adversely prejudice the interests of the other litigants. (Whalen v. Superior Court (1961) 184 Cal. App.2d 598). Granting the requested continuance would not prejudice any party, in fact, both parties have stipulated as to the brief continuance. However, denial of this brief continuance would certainly cause all parties significant hardship. III. GOOD CAUSE EXISTS TO CONTINUE TRIAL California Rules of Court, Rule 3.1332 provides that the Court may grant a continuance upon a showing of good cause which includes, among other grounds, the unavailability of trial counsel for an excusable circumstance (/d. at subd.(c)(3).) In ruling on a motion or application, the Court must consider all the facts and circumstances relevant to the determination, including whether trial counsel is engaged in another trial and whether all parties have stipulated to a continuance. (See Id. at subd. (d).) [Emphasis added.] Here, the good cause justifying continuing trial to May 4, 2020, is Defense Counsel’s continued engagement in the Li trial as well as the importance of the depositions of Dr. Mirrafati and Dr. Moneer. A. DEFENSE COUNSEL’S AVAILABILITY 1. Liv. Lee, M.D. (San Bernardino County Case No. CIVIDS 1621591) Defense Counsel’s trial in the matter of Li v. Lee, M.D., began on October 16, 2019 in San Bernardino County. The trial has progressed slowly and is still continuing. E:\52\5796-01\PLD\Motion To Continue Trial. Docx 4 MOTION TO CONTINUE TRIAL AND ALL RELATED DATES 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2. Plaintiff’s Deposition of Dr. Mirrafati On August 30, 2019, Plaintiff’s Counsel unilaterally noticed the deposition of Defendant, Dr. Mirrafati for September 16, 2019. Defense Counsel objected and the deposition did not go forward due to Counsel’s unavailability as a result of the scheduled videotaped trial testimony of an expert in the Li v. Lee, M.D. matter, which lasted the entire day. Plaintiff’s Counsel has inquired regarding dates for this deposition and Defense Counsel has only been able to offer January 7, 9, or 13, 2020 due to their engagement in the Li trial. 3. Deposition of Expert Dr. Moneer Defense Counsel seeks to take the deposition of Plaintiff’s Expert, Dr. Moneer. Dr. Moneer is available to sit for his deposition on January 13, 2020. IV. PREVIOUS CONTINUANCES This matter became at issue seven months ago, on May 21, 2019. This is the third continuance in this matter. V. CONCLUSION Based upon the foregoing, this Court should issue an Order continuing trial and all discovery and motion dates in this matter from February 24, 2019 to May 4, 2020, or a date as soon thereafter as is convenient for this Court’s calendar. DATED: December 16,2019 CARROLL, KELLY, TROTTER, FRANZEN & McBRIDE /s/ Carley M. Ryckman MARK V. FRANZEN JENNIFER L. STURGES CARLEY M. RYCKMAN Attorneys for Defendants, SAYED J. MIRRAFATI, M.D., SAYED J. MIRRAFATI, MD, PC dba MIRA AESTHETIC MEDICAL CENTER & SPA and ELITE SURGERY CENTER By: E:\52\5796-01\PLD\Motion To Continue Trial. Docx 5 MOTION TO CONTINUE TRIAL AND ALL RELATED DATES 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DECLARATION OF CARLEY M. RYCKMAN I, Carley M. Ryckman, declare as follows: 1. I am an attorney duly licensed to practice law in the State of California. I am an associate with the law firm Carroll, Kelly, Trotter, Franzen and McBride, attorneys of record for Defendants, SAYED J. MIRRAFATI, M.D., SAYED J. MIRRAFATI, MD, PC dba MIRA AESTHETIC MEDICAL CENTER & SPA, and ELITE SURGERY CENTER. If called as a witness, I could and would testify competently to the following. 2. I make this declaration in support of Defendants’ Motion to Continue Trial. 3. There is good cause to continue trial in this matter, which is currently set February 24, 2020. Good cause in this instance includes Defense Counsel’s current trial in the matters of Li v. Lee, M.D. (San Bernardino County Case No. CIVIDS 1621591). Trial began on October 16, 2019 and is ongoing. As of the date of the filing of this motion, Defense Counsel is awaiting a jury verdict. 4. Plaintiff’s Counsel has attempted to notice the deposition of Dr. Mirrafati. Unfortunately, because of the Li trial, the soonest dates my office can offer are January 7, 9, or 13, 2020. We also plans to take the deposition of Plaintiff’s expert, Dr. Moneer. Dr. Moneer is available for his deposition on January 13, 2020 and the deposition has been noticed for that date. 5. Trial in this matter is currently set for February 24, 2020 and will be impacted by Defense Counsel’s scheduled trial, and the need for the depositions of both Defendant, Dr. Mirrafati and Plaintiff’s Expert, Dr. Moneer. 6. The parties have agreed to continue trial just as long as is necessary to permit Defense Counsel to complete the subject trial and to allow the opportunity to conduct these two depositions. Ts We attempted to have the trial date continued for 70 days by way of ex parte application on December 3, 2019. On December 2, 2019, before the Court entertained any oral arguments on the matter, the Court transmitted a minute order indicating that the ex parte application for a brief 70-day continuance had been denied. As such, we had no choice but to E:\52\5796-01\PLD\Motion To Continue Trial. Docx 6 MOTION TO CONTINUE TRIAL AND ALL RELATED DATES 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 file this motion. 8. Attached as Exhibit “A” hereto is a true and correct copy of the Proposed Order and Stipulation to Continue Trial and Related Motion/Discovery Dates signed by the parties requesting trial be continued to May 4, 2020. 9. Attached hereto as Exhibit “B” is a true and correct copy of the Court’s Minute Order, dated December 2, 2019, denying the ex parte application to continue trial. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed this 2nd day of October, 2019, in Long Beach, California. /s/ Carley M. Ryckman CARLEY M. RYCKMAN E:\52\5796-01\PLD\Motion To Continue Trial. Docx 7 MOTION TO CONTINUE TRIAL AND ALL RELATED DATES EXHIBIT “A” EXHIBIT “A” SN o e N a N Wn 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CARROLL, KELLY, TROTTER, FRANZEN & McBRIDE MARK V. FRANZEN (STATE BAR NO. 079470) JENNIFER L. STURGES (STATE BAR NO. 155703) CARLEY M. RYCKMAN (STATE BAR NO. 314621) 111 West Ocean Boulevard, 14th Floor Post Office Box 22636 Long Beach, California 90801-5636 Telephone No. (562) 432-5855 / Facsimile No. (562) 432-8785 Attorneys for Defendants, SAYED J. MIRRAFATI, M.D. (erroneously served and sued as Sid J. Mirrafati, M.D.), SAYED J. MIRRAFATI, MD, PC dba MIRA AESTHETIC MEDICAL CENTER & SPA (erroneously served and sued as Mira Aesthetic Medical Center, Inc. and Mira Aesthetic Medical Center and Spa), and ELITE SURGERY CENTER SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ORANGE — CENTRAL JUSTICE CENTER PALOMA ROCIO CAMUNEZ CASE NO.: 30-2018-00999859 Plaintiff, STIPULATION TO CONTINUE TRIAL AND DISCOVERY DEADLINES; ORDER Vs. [PROPOSED] SID J. MIRRAFATI, M.D; BROWNELL] ASSIGNED FOR ALL PURPOSES TO PAYNE, M.D.; ELITE SURGERY CENTER; JUDGE HON. MELISSA MCCORMICK MIRA AESTHETIC MEDICAL CENTER, DEPARTMENT: C-13 INC.; MIRA AESTHETIC MEDICAL) CENTER AND SPA; PROPERTY OWNERS| Complaint Filed: March 17, 2016 OF PROPERTY LOCATED AT 3140 RED! Trial Date: February 24, 2020 HILL, SUITE 150, COSTA MESA) CALIFORNIA 92626 Defendants. IT IS HEREBY STIPULATED, by and between the parties hereto, through their respective attorneys of record, that good cause exists to continue the trial date in this matter, currently set for February 24, 2020, for the following reasons: IL. DEFENSE COUNSEL’S AVAILABILITY A. LIV. LEE, M.D. (San Bernardino County Case No. CIVIDS 1621591) Defense Counsel has begun trial in the matter of Li v. Lee, M.D., in San Bernardino County. The trial is expected to extend to late December 2019. " " 1 WLAWSERVER2\Public\LITIGATION\Camunez V. Mirrafati\DEF - (2ND) STIP TO CONTINUE TRIAL AND DISCOVERY DEADLINES; PROPOSED ORDER Pdf. Docx 1 STIPULATION TO CONTINUE TRIAL AND DISCOVERY DEADLINES; ORDER [PROPOSED] N A N n y BR W N 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 IL. PLAINTIFF'S DEPOSITION OF Dr. MIRRAFATI Plaintiff’s Counsel is attempting to notice the deposition of Dr. Mirrafati. Unfortunately, because Defense Counsel is engaged in the Li trial, the soonest dates available for deposition are January 7, 9, or 13, 2020. II. DEFENDANT’S DEPOSITION OF EXPERT DR. MONEER Defense Counsel seeks to take the deposition of Plaintiff’s expert, Dr. Moneer. Dr. Moneer is available for deposition on January 13, 2020. IV. PREVIOUS CONTINUANCES This matter became at issue on May 21, 2019. This is the third continuance in this matter. IT IS FURTHER STIPULATED, by and between the parties, through their respective attorneys of record, and subject to the approval of the Court, that the current trial date of February 24, 2020, at 9:00 a.m. in Department C-13 of the above named court, be continued to May 4, 2020, at 9:00 a.m. in Department C-13 of the above named court, or such later date as is convenient to the Court’s calendar. DATED: November 13, 2019 CARROLL, KELLY, TROTTER, FRANZEN, McBRIDE & PEABODY ny. Gul In. pr — MARK V/FRANZEN JENNIFER 1. STURGES CARLEY M. RYCKMAN Attorneys for Defendants, SAYED J. MIRRAFATI, M.D., SAYED I. MIRRAFATI, MD, PC dba MIRA AESTHETIC MEDICAL CENTER & SPA and ELITE SURGERY CENTER DATED: A-79- 79 LAW OFFICES OP FRED HANASSAB FRED HANKS8AB NADIA LUNEVA Attorneys for Plaintiff, PALOMA ROCIO CAMUNEZ WLAWSERVER2\Public\LITIGATION\Camunez V. MirrafatiDEF - (2ND) STIP TO CONTINUI: TRIAL AND DISCOVERY DEADLINES; PROPOSED ORDER Pdf. Docx2 STIPULATION TO CONTINUE TRIAL AND DISCOVERY DEADLINES; ORDER [PROPOSED] S N ~~ S N W n 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 [PROPOSED] ORDER IT IS SO ORDERED THAT, there being good cause to continue trial based upon Defense Counsel’s unavailability due to trials in the matter of Li v. Lee, M.D. and the scheduling of depositions. Good cause further exists because this matter only became at issue on May 21, 2019. As such, trial in this matter is continued from February 24, 2020 to , at 9:00 a.m. in Department C-13 of the above named court, located at 700 Civic Center Drive West, Santa Ana, California. IT IS FURTHER ORDERED THAT, the time for all discovery and motions shall be extended, with said time to be governed by statute in accordance with the newly assigned trial date. DATED: HON. MELISSA MCCORMICK Judge of the Superior Court WLAWSERVER2\Public\LITIGATION\Camunez V. MirrafaliDEF - (2ND) STIP TO CONTINUE TRIAL AND DISCOVERY DEADLINES; PROPOSED ORDER Pdf. Docx 3 STIPULATION TO CONTINUE TRIAL AND DISCOVERY DEADLINES; ORDER [PROPOSED] EXHIBIT "B” EXHIBIT "B” SUPERIOR COURT OF CALIFORNIA, COUNTY OF ORANGE Central Justice Center 700 W. Civic Center Drive Santa Ana, CA 92702 SHORT TITLE: Camunez vs Mirrafati CLERK'S CERTIFICATE OF MAILING/ELECTRONIC CASE NUMBER: SERVICE 30-2018-00999859-CU-MM-CJC I certify that I am not a party to this cause. I certify that the following document(s), Minute Order dated 12/02/19, have been transmitted electronically by Orange County Superior Court at Santa Ana, CA. The transmission originated from Orange County Superior Court email address on December 2, 2019, at 1:14:18 PM PST. The electronically transmitted document(s) is in accordance with rule 2.251 of the California Rules of Court, addressed as shown above. The list of electronically served recipients are listed below: CARLEY M. RYCHMAN LAW OFFICES OF FRED HANASSAB CMRYCKMAN@CKTFMLAW.COM SANDRA@FHLAWOFFICES.COM Clerk of the Court, by: A Mao Eovsare_ Deputy CLERK'S CERTIFICATE OF MAILING/ELECTRONIC SERVICE V3 1013a (June 2004) Code of Civ. Procedure , § CCP1013(a) SUPERIOR COURT OF CALIFORNIA, COUNTY OF ORANGE CENTRAL JUSTICE CENTER MINUTE ORDER DATE: 12/02/2019 TIME: 01:06:00 PM DEPT: C13 JUDICIAL OFFICER PRESIDING: Melissa R. McCormick CLERK: Alma Bovard REPORTER/ERM: None BAILIFF/COURT ATTENDANT: CASE NO: 30-2018-00999859-CU-MM-CJ C CASE INIT.DATE: 06/18/2018 CASE TITLE: Camunez vs Mirrafati CASE CATEGORY: Civil - Unlimited CASE TYPE: Medical Malpractice EVENT ID/DOCUMENT ID: 73177415 EVENT TYPE: Chambers Work APPEARANCES There are no appearances by any party. On Court's motion, the Ex Parte Application set for December 3, 2019 is advanced to today. Defendants’ ex parte application to continue the February 24, 2020 trial date is denied. As the court stated in its October 2, 2019 order granting Defendants’ previous application to continue the trial date, “ [tlhe February 24, 2020 trial date is a firm trial date. All parties should prepare their cases diligently for trial with the expectation that, if the case does not otherwise resolve, the trial will commence on February 24, 2020.” 10/02/19 Order (emphasis in original). Defendants state that the trial in which counsel presently is engaged will conclude this month and Defendants state that both of the depositions apparently remaining to be taken will be taken before the fact discovery cut-off date in this case. In sum, Defendants offer no persuasive reasons the February 24, 2020 trial date should be continued. The trial remains scheduled for February 24, 2020 at 9:00 a.m. in Department C13. The Mandatory S etlement Conference remains scheduled for February 7, 2020 at 8:30 a.m. in Department C13. Clerk to give notice. DATE: 12/02/2019 MINUTE ORDER Page 1 DEPT: C13 Calendar No. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF LOS ANGELES I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action. My business address is Post Office Box 22636, Long Beach, CA 90801-5636. On December 16, 2019, I served a true and correct copy of the following document on the list of interested parties attached: NOTICE OF MOTION AND MOTION TO CONTINUE TRIAL AND ALL RELATED DATES; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF CARLEY M. RYCKMAN By United States Mail (CCP §§1013a, et seq.): I enclosed said document(s) in a sealed envelope or package to each addressee. I placed the envelope for collection and mailing, following our ordinary business practices. I am readily familiar with the firm’s practice for collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service, with postage fully prepaid. (l By Overnight Delivery/Express Mail (CCP §§1013(c)(d), et seq.): I enclosed said document(s) in a sealed envelope or package provided by an overnight delivery carrier to each addressee. I placed the envelope or package, delivery fees paid for, for collection and overnight delivery at an office or at a regularly utilized drop box maintained by the express service carrier at 111 West Ocean Boulevard, Long Beach, California. 0 By Fax Transmission (CRC 2.306): Based on a written agreement of the parties to accept service by fax transmission, I faxed said document(s) to each addressee's fax number. The facsimile machine that I utilized, (562) 432-8785, complied with California Rules of Court, Rule 2.301(3), and no error was reported by the machine. Pursuant to Rule 2.306(h)(4), I caused the machine to print a record of the transmission, a copy of which is attached to the original of this proof of service. 0 By Messenger Service: I enclosed said document(s) in a sealed envelope or package to each addressee. I provided them to a professional messenger service (Signal Attorney Service) for service. An original proof of service by messenger will be filed pursuant to California Rules of Court, Rule 3.1300(c). O Electronic Mail. Via e-mail to the address shown above. I declare under the penalty of perjury under the laws of the State of California and of the United States that the foregoing is true and correct. Executed on December 16, 2019, at Long Beach, California. O Calder OFELIA I. CALDER E:\52\5796-01\PLD\Motion To Continue Trial. Docx 8 MOTION TO CONTINUE TRIAL AND ALL RELATED DATES 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Proof of Service Mailing List Re: Camunez vs. Sid J. Mirrafati, M.D, et al Case No. 30-2018-00999859 Fred Hanassab, Esq. LAW OFFICES OF FRED HANASSAB 6320 Canoga Avenue, Suite 790 Woodland Hills, CA 91367 Telephone No.: 818-888-6614 Facsimile No.: 818-888-6615 Attorneys for Plaintiff, PALOMA ROCIO CAMUNEZ E:\52\5796-01\PLD\Motion To Continue Trial. Docx 9 52-5796-01 MOTION TO CONTINUE TRIAL AND ALL RELATED DATES
