defendants objection to notice of time and place of trial

Cal. Super. - 1st Dist.August 3, 2021

1 2 3 4 5 6 7 8 9 H. Gregory elch, Esq. - SB 118258 CODDINGTON, HICKS & DANFORTH A Professional Corporation, Lawyers 555 Twin Dolphin Drive, Suite 300 Redwood City, CA 94065-2133 Tel.: 650.592.5400 Fax: 650.592.5027 ATTORNEYS FOR Defendant Tom Soohoo, Tr. IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN FRANCISCO 10 MARCUS KEMP, Case No. CGC-20-585783 11 12 13 14 15 16 17 Plaintiff, vs. TOM SOOHOO,JR.; and DOES 1 to 10, Defendant. DEFEND.A T'S OBJECTION TO NOTICE OF TIME AND PLACE OF TRIAL Date: Time: Dept: February 10, 2021 10:30 a.m. 610 TO: PLAI TIFF AND TO HIS ATTORNEY OF RECORD 18 PLEASE TAKE NOTICE that defendant Tom Soohoo, Jr. hereby objects to the notice 19 of time and place of trial. All parties are to appear at 10:30 a.m. on February 10, 2021, in 20 Department 610 for the objection hearing. 21 22 23 24 25 26 27 28 Dated: February 4, 2021 Objection to Notice of Time and Place of Trial Case No: CGC-20-585783 CODDINGTON, HICKS & DANFORTH By: l~I ti. ~~ nddi, H. Gregotyech Attorneys for Defendant Tom Soohoo, Tr. 1 ELECTRONICALLY F I L E D Superior Court of California, County of San Francisco 02/05/2021 Clerk of the Court BY: JEFFREY LEE 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 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(6) 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 joseguera@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 February 5, 2021 , I served a copy of each of the documents listed below by placing them for processing as indicated herein. DEFENDANT's OBJECTION TO NOTICE OF TIME AND PLACE OF TRIAL United States Mail: The correspondence or documents were placed in sealed, labeled envelopes "vith 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 de1ivery, 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 \vith 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. 27 XX Electronic Transmission: The correspondence or documents were transmitted electronically to the electronic address set forth below. 28 1 2 3 4 5 6 7 8 9 10 11 12 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. PERSONS OR PARTIES SERVED: Attomey for Plaintiff Greg Woodhead, Esq. Movagar & Yamin, PC 4929 Wilshire Blvd. Suite 960 Los Angeles, CA 90010 13 Telephone: Facsimile: (877) 771-8175 (323) 475-7773 Greg@mylawcompany.com 14 E-mail: 15 16 17 18 19 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 this declaration was executed on February 5, 2021. ~ 20 Court: Superior Court of California, San Francisco Counry Action No: CGC-20-585783 21 Case Name: Kemp v. Soohoo,Jr. 22 23 24 25 26 27 28