declaration of douglas e johns confirming notice given to all parties

Cal. Super. - 1st Dist.March 6, 2020

1 2 3 4 5 Randolph S. Hicks, Esq. - SBN 83627 Douglas E. Johns, Esq. - SBN 314798 CODDINGTON, HICKS & DANFORTH A Professional Corporation, Lawyers 555 Twin Dolphin Drive, Suite 300 Red\vood City, CA 94065-2133 Tel.: 650.592.5400 Fax: 650.592.5027 ATTORNEYS FOR Defendants 6 Douglas Charles Speck and Northwest Demolition, Inc. 7 8 9 10 11 12 13 14 15 16 17 18 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF S.i\N FRANCISCO DAVINA GISSELLE NARVAEZ, Plaintiff, vs. DOUGLAS CHARLES SPECI<, NORTHWEST DEMOLITION, INC., and DOES 1 to 20, Defendants. Case No. CGC-18-565326 DECLARATION OF DOUGLAS E.JOHNS CONFIRMING NOTICE GIVEN TO ALL PARTIES OF EX PARTE APPLICATION FOR TRIAL CONTINUANCE Date: Time: Dept.: Complaint Filed: Trial: June 27, 2019 11:00 a.m. 206 March 27,2018 August 26, 2019 19 Pursuant to California Rule of Court 3.1201 and California Rule of Court 3.1204, I, 20 Douglas E. Johns, submit the following declaration, and declare that: 21 1. I am an attorney duly licensed to practice before the Courts of the State of 22 California, and I am an associate of the law fltm of Coddington, Hicks & Danforth, attorneys 23 of record for defendants, Mr. Douglas Charles Speck and Northwest Demolition, Inc., in the 24 above-entitled action. I make this declaration on behalf of those defendants. I have personal 25 knowledge of the facts regarding the notice stated herein, and if called to testify with respect 26 thereto, I could, and would, do so competently and under oath. 27 / / / 28 / / / 1 Declaration of Douglas E. Johns Confirming Notice Given to All Parties of Ex Parte Application for Trial Continuance; Case No: CGC-18-565326 596219 ELECTRONICALLY F I L E D Superior Court of California, County of San Francisco 06/25/2019 Clerk of the Court BY: VANESSA WU Deputy Clerk 1 2. On June 25, 2019, I notified counsel for plaintiff, Ms. Divinia Narvaez, Jeremy 2 M. Jessup, Esq., by email that I would present to this Court on June 27, 2019, at 11:00 a.m. in 3 the morning in Department 206, an ex parte application for a trial continuance and an order 4 continuing the trial date with all pre-trial deadlines running from the new trial date in 5 accordance with the California Code of Civil Procedure and Local Rules of Court. 6 3. Based on prior discussions with Mr. Jessup as well as the executed "Stipulation of 7 Parties to Trial Continuance in Support of Ex Parte Application for Trial Continuance," I 8 understand, and based thereon allege, that defendants, Mr. Douglas Charles Speck and 9 Northwest Demolition, Inc.'s, ex parte application for a trial continuance is unopposed. 10 4. Mr. Jessup was served with the ex parte application on June 25, 2019 by email. 11 I declare under penalty of perjury under the la'\vs of the State of California that the 12 foregoing is true and correct. Executed on this 25th day of June, 2019, in Redwood City, 13 California. 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 Declaration of Douglas E. Johns Conftrming Notice Given to All Parties of Ex Parte Application for Trial Continuance; Case No: CGC-18-565326 596219 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE California Code of Civil Procedure sections 1011, 1013, 1013a, 2015.5 California Rule of Court rule 2.251 Federal Rule of Civil Procedure Rule 5(b) I, the undersigned, declare that I am employed in the County of San Mateo, State of California. I am over the age of eighteen (18) years and not a party to the within action. My business address is 555 Twin Dolphin Drive, Suite 300, Redwood City, California 94065. My electronic mail address is hporter@chdlawyers.com. I am readily familiar with my employer's business practice for collection and processing of correspondence and documents for mailing with the United States Postal Service, mailing via overnight delivery, transmission by facsimile machine, and delivery by hand. On June 25, 2019, I served a copy of each of the documents listed below by placing said copies for processing as indicated herein. DECLARATION OF DOUGLAS E. JOHNS CONFIRMING NOTICE GIVEN TO ALL PARTIES OF EX PARTE APPLICATION FOR TRIAL CONTINUANCE United States Mail: The correspondence or documents were placed in sealed, labeled envelopes with postage thereon fully prepaid on the above date placed for collection and mailing at my place of business to be deposited with the U.S. Postal Service at Redwood City, California on this same date in the ordinary course of business. Overnight Delivery: The correspondence or documents were placed in sealed, labeled packaging for overnight deuvery, with Federal Express, with all charges to be paid by my employer on the above date for collection at my place of business to be deposited in a facility regularly maintained by the overnight delivery carrier, or delivered to a courier or driver authorized by the overnight delivery carrier to receive such packages, on this date in the ordinary course of business. Hand Delivery: The correspondence or documents were placed in sealed, labeled envelopes and served by personal delivery to the party or attorney indicated herein, or if upon attorney, by leaving the labeled envelopes with a receptionist or other person having charge of the attorney's office. Facsimile Transmission: The correspondence or documents were placed for transmission from (650) 592-5027 at Redwood City, California, and were transmitted to a facsimile machine maintained by the party or attorney to be served at the facsimile machine telephone number provided by said party or attorney, on this same date in the ordinary course of business. The transmission was reported as complete and without error, and a record of the transmission was properly issued by the transmitting facsimile machine. 1 XX 2 3 4 5 6 7 8 9 Electronic Transmission: The correspondence or documents were transmitted electronically to the electronic address set forth below. State. The recipient has filed and served notice that he or she accepts electronic service; the recipient has electronically filed a document with the court; and/ or the Court has mandated that the parties serve documents through its Court approved vendor. The printed form of this document bearing the original signature is on file and available for inspection at the request of the court or any party to the action or proceeding in which it is filed, in the manner provided in California Rule of Court Rufe 2.257 (a). Federal. The recipient of this electronic service has consented to this method of service in writing, a copy of which is on file and available for inspection in my employer's office. I have received no indication the electronic transmission did not reach the recipient. 10 PERSONS OR PARTIES SERVED: 11 Attorneys for Plaintiff 12 Christopher B. Dolan, Esq. Dolan Law Firm, PC 13 1438 Market Street San Francisco, CA 94102 14 Telephone: (415) 421-2800 15 Facsimile: (415) 421-2830 chris.dolan@dolanlawfirm.com 16 17 18 19 20 21 22 23 I certify (or declare) under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that thia a ; June 25, 2019. Heie110rter Court: Superior Court oj California, San Francisco County 24 Action No: CGC-18-565326 25 26 27 28 Case Name: Narvaez v. Speck, et aL