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ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP 13266. 10 ir 12 13, 14 15 16 7 18 19 20 a1 23 24 25 26 27 28 STEVEN D. WERTH, State Bar No. 121153 swerth@aghwlaw.com CHRISTINA M. FORST, State Bar No. 306632 cforst@aghwlaw.com ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP ELECTRONICALLY | 180 Montgomery Street, Suite 1200 FILED San Francisco, CA 94104 ‘Superior Court of Catifornia, Telephone: (41S) 697-2000 County of San Francisco Facsimile: (415) 813-2045 02/07/2017 Clerk of the Court Attorneys for Defendant SBYSVANESSA WA) EPISCOPAL COMMUNITY SERVICES OF SAN Peru FRANCISCO (erroneously sued as EPISCOPAL COMMUNITY SERVICES) SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO CHARLES PITTS, Case No. CGC-16-555910 Plaintiff, DECLARATION OF CHRISTINA M. FORST IN SUPPORT OF DEFENDANT EPISCOPAL v. COMMUNITY SERVICES OF SAN FRANCISCO'S MOTION TO STRIKE CITY AND COUNTY OF SAN PORTIONS OF PLAINTIFF'S COMPLAINT. FRANCISCO, HUMAN SERVICES. AGENCY, EPISCOPAL COMMUNITY | Date: March 8, 2017 SERVICES and OFFICE OF H.0.P.B, Time 9:30 a.m. Dept: 302 Defendants. Reservation No.: 01300308-04 Action Filed: — December 14, 2016 Trial Date: None Set I, CHRISTINA M. FORST, declare as follows: 1 Tam an attorney licensed to practice in the State of California. I am an associate at the law firm of Allen, Glaessner, Hazelwood & Werth, LLP, and am counsel of record for Defendant EPISCOPAL COMMUNITY SERVICES OF SAN FRANCISCO (“ECS”) in this, matter. I have personal knowledge of the statements made in this declaration and could competently testify to them if called as a witness. 1 DECLARATION OF CHRISTINA M, FORST IN SUPPORT OF DEFENDANT EPISCOPAL COMMUNITY — SERVICES OF SAN FRANCISCO'S MOTION TO STRIKE PORTIONS OF PLAINTIFF'S COMPLAINT 460 Montgomery Str San Francisco, Z = s 8 8 3 2 = o 3 3 z 138266. 10 ul 12 13 14 1s 16 17 18 19 20 a1 22 23 24 25 26 27 28 2, Attached hereto as EXHIBIT A is a true and correct copy of a letter that was mailed and emailed to Plaintiff CHARLES PITTS (“Plaintiff"), advising Plaintiff regarding the issue of a request for punitive damages and medical expenses under breach of contract causes of action. 3, Attached hereto as EXHIBIT B are true and correct copies of emails that were exchanged between myself and Plaintiff regarding the request to strike punitive damages and medical expenses from the complaint, 4. On or about January 14, 2017, Plaintiff agreed to a 15-day extension for ECS to file a responsive pleading. Attached as EXHIBIT C is a true and correct copy of the email from Plaintiff granting the extension, The date for ECS to file a responsive pleading to the complaint was extended to February 1, 2017. 5. Onorabout January 24, 2017, Plaintiff requested that ECS file a demurrer. Attached hereto as EXHIBIT D is a true and correct copy of an email sent by Plaintiff requesting that ECS file a demurzer, 6, These efforts constitute an attempt to meet and confer under San Francisco Superior Court Local Rule 12.15(A). I declare under penalty of perjury, under the laws of the State of California, that the foregoing is true and correct. Executed on February 7, 20: \cifco, California, 2 "~~ DECLARATION OF CHRISTINA M. FORST IN SUPPORT OF DEFENDANT EPISCOPAL COMMUNITY SERVICES OF SAN FRANCISCO'S MOTION TO STRIKE PORTIONS OF PLAINTIFF'S COMPLAINT EXHIBIT A

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