request to continue osc re dismissal

Cal. Super. - 1st Dist.September 10, 2020

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 Larisa K. Raymundo, Esq. (SBN 233358) GILSLEIDER, MCMAHON, MOLINELLI & PHAN SALARIED EMPLOYEES OF PROGRESSIVE CASUALTY INSURANCE COMPANY 2300 Clayton Road, Suite 430 Concord, CA 94520-2142 (925) 446-3118 Direct Line (925) 798-5355 Fax Larisa_K_Raymundo@Progressive.com Attorneys for defendants, HONEY CADENA AND SEAN FARRELL SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO - UNLIMITED JURISDICTION MIGUEL PEREZ, ) Case No.: CGC-18-571977 ) PLAINTIFF, ) REQUEST TO CONTINUE OSC ) V. ) ) DISMISSAL HONEY CADENA; SEAN FARRELL; AND DOES 1 THROUGH 10, INCLUSIVE, ) Complaint Filed: 12/10/2018 ) DEFENDANTS. ) ) An Order to Show Cause re: Dismissal is set for January 28, 2020 @ 10:30 a.m. in Dept. 610. Counsel for Plaintiff is still working on obtaining a final Medi-Cal lien. Counsel for both Plaintiff and Defendants request that the court reschedule (continue) the hearing date for 90 days to allow additional time to finalize the matter. Dated: January 23, 2020 GILSLEIDER, MCMAHON, MOLINELLI & P N Dated: January 23, 2020 LARISA K. RAYMUNDO mey for Defendants, ONEY CADENA AND SEAN FARRELL BAY AREA BICYCLE LAW MICHELLE L. WEISS Attorney for Plaintiff, MIGUEL PEREZ REQUEST TO CONTINUE OSC RE: DISMISSAL ELECTRONICALLY F I L E D Superior Court of California, County of San Francisco 01/23/2020 Clerk of the Court BY: JOSE RIOS-MERIDA Deputy Clerk 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 STATE OF CALIFORNIA ) ss: COUNTY OF CONTRA COSTA ) I am employed in the County of Contra Costa, State of California, I am over the age of 18 and not a party to the within action; my business address is 2300 Clayton Road, Suite 430, Concord, CA 94520-2142. On January 23, 2020, I served the foregoing document described as REQUEST TO CONTINUE OSC RE: DISMISSAL on the parties in this action by placing a true copy thereof enclosed in a sealed envelope addressed as follows: SEE ATTACHED SERVICE LIST El BY MAIL: I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. Under that practice it would be deposited with U.S. postal service on that same day with postage thereon fully prepaid at Concord, California, in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. 1:1 BY PERSONAL SERVICE: I caused such envelope to be delivered by hand to the offices of the addressee. ❑ BY OVERNIGHT MAIL: I arranged for such envelope to be delivered to the addressees as listed on the service list. O BY FACSIMILE: In addition to regular mail, I sent this document via facsimile to they numbers as listed on the service list and pursuant to CCP §1013(e). O BY ELECTRONIC SERVICE: I sent this document via electronic transmission to the joffices of the addressees as listed on the service list and pursuant to CCP §1010.6. O (State) I declare under penalty of perjury under the laws of the State of California th t the above is true and correct. El (Federal) I declare that I am employed in the office of a member of the bar of this court at whose direction the service was made. Executed on January 23, 2020, at Concord, California. Mia Foster-White 2 REQUEST TO CONTINUE OSC RE: DISMISSAL 1 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 1 Michelle L. Weiss, Esq. Bay Area Bicycle Law P.O. Box 71227 Oakland, CA 94612 (415) 466-87171/(888) 563-7661 (F) Attorney for Plaintiff MIGUEL PEREZ SERVICE LIST I 3 REQUEST TO CONTINUE OSC RE: DISMISSAL I