ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP
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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.
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DECLARATION OF CHRISTINA M, FORST IN SUPPORT OF DEFENDANT EPISCOPAL COMMUNITY —
SERVICES OF SAN FRANCISCO'S MOTION TO STRIKE PORTIONS OF PLAINTIFF'S COMPLAINT460 Montgomery Str
San Francisco,
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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,
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"~~ DECLARATION OF CHRISTINA M. FORST IN SUPPORT OF DEFENDANT EPISCOPAL COMMUNITY
SERVICES OF SAN FRANCISCO'S MOTION TO STRIKE PORTIONS OF PLAINTIFF'S COMPLAINTEXHIBIT A