Superior Court of California County of San Francisco
Opposition to summary judgment
I. Receipt of a package does not resolve completeness
The June 3 receipt establishes that Northline delivered the complete project package by the contractual deadline.
Two days later, Rivera identified Exhibits C and D as missing and requested the complete set. The record therefore distinguishes when the upload arrived from what it contained.
II. The missing exhibits were required deliverables
The agreement required the completed project files, including Exhibits A through D, by June 3, with any extension subject to Rivera's written approval.
The manifest lists Exhibits C and D in a June 6 supplemental upload, while Northline's declaration states that every required item was delivered on June 3.
The factual argument should address that conflict rather than equate a transfer acknowledgment with complete performance. The complete record and governing legal standard remain for counsel's review.
