Stipulation,Agreement: Jaspreet Singh vs Reedy Mechanical, Inc. a California corporation

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RECEIVED
2022-05-05 17:18:35

Harry B. Gill (State Bar No. 296730) /
Email: harry.gill@hbglaw.com Filed May 06 2022
Preetpal Toor (State Bar No. 325663) RE DIEY AIEDE
Email: preetpal.toor@hbglaw.com BRANDODYF. RILEY, CLERK
Jerome A. Clay, Jr. (State Bar No. 327175)
HBG Law, PC By
4317 North Star Way, Suite B DEPUTY
Modesto, CA 95356 \e
Telephone: (209) 285-2100
Facsimile: (209) 285-2114
Attomey(s) for Defendant:
Reedy Mechanical, inc.
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN JOAQUIN
JASPREET SINGH, Case No. STK-CV-UCC-2021-11339
Plaintiff, JOINT STIPULATION TO CONTINUE
DEMURRER HEARING DATE TO OR AFTER
v. MAY 29, 2022
REEDY MECHANICAL, INC.,

Defendants.

JOINT STIPULATION TO CONTINUE REQUEST FOR JUDICIAL NOTICE/DEMURRER
HEARING TO OR AFTER MAY 29, 2022
Defendant, REEDY MECHANICAL, INC. (“Defendant”) and Plaintiff, JASPREET SINGH

(‘Plaintiff’) respectfully submit through their respective counsel this Stipulation.

RECITALS
WHEREAS, on December 16, 2021, Plaintiff filed an Unverified Complaint (“Complaint”)
against Defendant;
WHEREAS, on March 14, 2022, Plaintiff served Defendant with the Complaint;
WHEREAS, on or about April 21, 2022, Defendant concurrently filed a Demurrer to Plaintiff's

Complaint alongside a Request for Judicial Notice ("RUN") in Support of Defendant's Demurrer.

Case No. STK-CV-UCC-2021-11339 1

JOINT STIPULATION TO CONTINUE DEMURRER HEARING DATE TO OR AFTER MAY 29, 2022oo onn Do F&F Ob NY =

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WHEREAS, this San Joaquin Superior Court scheduled a Hearing for this Demurrer/RJN on
May 17, 2022, at 9:00 AM (“Hearing Date”) in Department 10D;

WHEREAS the parties dispute the sufficiency of adequacy of notice related to the pertinent
pleadings and validity of the currently scheduled Hearing Date;

WHEREAS, the Plaintiff and Defendant (collectively, the “Parties") have agreed to continue
the Hearing for the Demurrer/RJN to or after May 29, 2022, to allow Plaintiff to file an opposition.

STIPULATION

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED by the Parties that the

pertinent Hearing Date in this matter regarding the Demurrer/RJN be moved to or after May 29,

2022.

AGREED TO AND ACCEPTED BY:

Dated: May 3, 2022 Dated: May 3, 2022
LAW OFFICE OF HASTINGS & RON HBG LAW, PC
=f
Natali A. Ron, Esq. Preetpal Toor, Esq.
Counsel to Plaintiff, Jaspreet Singh counsel to Defendant, Reedy Mechanicai,
nC.
Case No, STK-CV-UCC-2021-11339 2

JOINT STIPULATION TO CONTINUE DEMURRER HEARING DATE TO OR AFTER MAY 29, 2022oon OD on FF WO NB =

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[PROPOSED] ORDER
IT IS HEREBY ORDERED that the pertinent Hearing Date in this matter regarding the

Demurrer/RJN be moved to Sen ISAO -

IT IS FURTHER ORDERED that:

IT IS SO ORDERED.

a ee
Dated: S( le |r BARBARA A. KRONLUND

Judge of the Superior Court

Case No. STK-CV-UCC-2021-11339 3
JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE DEMURRER HEARING DATE