On January 01, 1900 a
Request,Application
was filed
involving a dispute between
Reyes, Anita,
and
Madera Community College Center,
State Center Community College District,
for 23 Unlimited - Other PI/PD/WD
in the District Court of Fresno County.
Preview
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, state bar number, and address): | | FOR COURT USE ONLY . |
Anthony N. DeMaria #177894
DeMaria Law Firm APC
| 1690West Shaw Ave.,Suite #220 E-FILED
6/9/2022 11:43 AM
TELEPHONE NO: (559) 206-2410 FAX NO: Superior Court of California
ATTORNEY FOR (Name):Defendant State CenterCommunity College District ae = County of Fresno
By: L. Whipple, Deputy
| SUPERIOR COURT OF CALIFORNIA * COUNTY OF FRESNO |
Civil Division |
1130 O Street |
Fresno, California 93721-2220
| PLAINTIFF/PETITIONER: Anita Reyes | | .
DEFENDANT/RESPONDENT: State Center Community College District,
etal. |
| ee -_ CASE NUMBER: oO
REQUEST FOR PRETRIAL DISCOVERY CONFERENCE 19CECG03826
LJ Plaintiff(s) Defendant(s) [_] Cross-complainant(s) [] Cross-defendant(s) [] Other(s) Request a
Pretrial Discovery Conference.
A Pretrial Discovery Conference isbeing requested for the following reasons:
LIA dispute has arisen. regarding a request for preduction of documents, set propounded on
[_] Adispute has arisen regarding form or special interrogatories, set propounded on .
["] A dispute has arisen regarding a deposition subpoena directed at for deposition
scheduled for .
L_] A dispute has arisen regarding a deposition notice, production of documents at a deposition or deposition
questions related to the deposition of scheduled for or held on .
A dispute has arisen regarding monetary, issue, evidence or terminating sanctions related to a failure to
comply with .
; L_] Privilege isthe basis for the refusal to produce documents and a privilege log isattached which complies
with Local Rule 2.1.17(B).
The parties have engaged in the following meaningful meet and confer efforts prior to filing this request:
(Describe in detail all meet and confer efforts including any narrowing of the issues or resolutions reached via
these efforts.)
The parties met and conferred in email and by phone. The IME Report was finally completed and has now
been served. The issue is resolved and no motion isrequired.
PCV-70 RO5-19 REQUEST FOR PRETRIAL DISCOVERY CONFERENCE Page 1of 2
Mandatory Local Rule 2.1.17
A brief summary of the dispute, including the facts and legal arguments at issue isas follows:
(Excepting a privilege log ifchecked above, no pleadings, exhibits, declarations, or attachments shall be
attached.)
The issue isresolved. Defendant was able to obtain the IME report of Dr. Edmonds on June 6, 2022, advised the
plaintiff that itwas received on June 7, 2022, and served the report on plaintiff on June 8, 2022. There isno
discovery issue pending.
Itis understood that the filing of this request for a Pretrial Discovery Conference tolls the time for filing a motion
to compel discovery on the disputed issues for the number of days between the filing of the request and
issuance by the Court of a subsequent order pertaining to the discovery dispute.
Opposing Party was served with a copy of REQUEST FOR PRETRIAL DISCOVERY CONFERENCE on: 6/9/2022
Date
Pursuant to Local Rule 2.].17(A}(1), any opposition to this request for a Pretrial Discovery Conference must also
be filed on an approved form and must be filed within five (5) court days of receipt of the request for a Pretrial
Discovery Conference and must be served on the opposing party.
| declare under penalty of perjury under the laws of the State of California that the foregoing is true and
correct, (>
6/9/2022 Anthony N. DeMaria {S/ " __.
Date Type or PrintName Signature of Partyor Attorney forParty
PCV-70 ROS5-19 REQUEST FOR PRETRIAL DISCOVERY CONFERENCE Page 2 of 2
Mandatory Local Rule 2.1.17
1 PROOF OF SERVICE
2 || STATE OF CALIFORNIA, COUNTY OF FRESNO
3| At the time of service, Iwas over 18 years of age and not a party to this action. I an
employed in the County of Fresno, State of California. My business address is 1690 W. Shaw
4 || Avenue, Ste. 220, Fresno, CA 93711.
5 On June 9, 2022, I served true copies of the following document(s) described ai
6 REQUEST FOR PRETRIAL DISCOVERY CONFERENCE on the interested parties in thig
action as follows:
"| PLAINTIFF COUNSEL:
8 Eugenia L. Steele
Reza Torkzadeh
9 Tracy R. Horn
THE TORKZADEH LAW FIRM
10 18650 MacArthur Blvd., Ste. 300
Irvine, CA 92612
ll PHONE: (310) 935-1111
FAX: (310) 935-0100
12 EMAIL; Eugenia(@torklaw.com
EMAIL: christine@torklaw.com
13 EMAIL: tracy@torklaw.com
14 | _X BY MAIL: | enclosed said document(s) in a sealed envelope or package addressed ta
the persons at the address listed on the Service List and placed the envelope for collection and
15 || mailing, following our ordinary business practices. I am readily familiar with this business’s
practice for collecting and processing correspondence for mailing. On the same day the
16 || correspondence is placed from collection and mailing itis deposited in the ordinary course of
"7 business with the United States Postal Service, in a sealed envelope with postage fully pre-paid.
18 X__By E-Mail or Electronic Transmission: Based on a court order or an agreement of the
| parties to accept service by email or electronic transmission, Icaused the documents to be sent ta
19 the persons atthe e-mail addresses listed above. I did not receive, within a reasonable time after
the transmission, any electronic message or other indication that the transmission was unsuccessful
20 I declare under penalty of perjury under the laws of the United States of America that thd
21|| foregoing is true and correct and that Iam employed in the office of a member of the bar of this
| Court at whose direction the service was made.
22
Executed on June 9, 2022, at Fresno, California, 7
24 | JO OEE
25 @hris Galarza
26 |}
27
28
Document Filed Date
June 09, 2022
Case Filing Date
January 01, 1900
Category
23 Unlimited - Other PI/PD/WD
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ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, state bar number, and address): | | FOR COURT USE ONLY . | Anthony N. DeMaria #177894 DeMaria Law Firm APC | 1690West Shaw Ave.,Suite #220 E-FILED 6/9/2022 11:43 AM TELEPHONE NO: (559) 206-2410 FAX NO: Superior Court of California ATTORNEY FOR (Name):Defendant State CenterCommunity College District ae = County of Fresno By: L. Whipple, Deputy | SUPERIOR COURT OF CALIFORNIA * COUNTY OF FRESNO | Civil Division | 1130 O Street | Fresno, California 93721-2220 | PLAINTIFF/PETITIONER: Anita Reyes | | . DEFENDANT/RESPONDENT: State Center Community College District, etal. | | ee -_ CASE NUMBER: oO REQUEST FOR PRETRIAL DISCOVERY CONFERENCE 19CECG03826 LJ Plaintiff(s) Defendant(s) [_] Cross-complainant(s) [] Cross-defendant(s) [] Other(s) Request a Pretrial Discovery Conference. A Pretrial Discovery Conference isbeing requested for the following reasons: LIA dispute has arisen. regarding a request for preduction of documents, set propounded on [_] Adispute has arisen regarding form or special interrogatories, set propounded on . ["] A dispute has arisen regarding a deposition subpoena directed at for deposition scheduled for . L_] A dispute has arisen regarding a deposition notice, production of documents at a deposition or deposition questions related to the deposition of scheduled for or held on . A dispute has arisen regarding monetary, issue, evidence or terminating sanctions related to a failure to comply with . ; L_] Privilege isthe basis for the refusal to produce documents and a privilege log isattached which complies with Local Rule 2.1.17(B). The parties have engaged in the following meaningful meet and confer efforts prior to filing this request: (Describe in detail all meet and confer efforts including any narrowing of the issues or resolutions reached via these efforts.) The parties met and conferred in email and by phone. The IME Report was finally completed and has now been served. The issue is resolved and no motion isrequired. PCV-70 RO5-19 REQUEST FOR PRETRIAL DISCOVERY CONFERENCE Page 1of 2 Mandatory Local Rule 2.1.17 A brief summary of the dispute, including the facts and legal arguments at issue isas follows: (Excepting a privilege log ifchecked above, no pleadings, exhibits, declarations, or attachments shall be attached.) The issue isresolved. Defendant was able to obtain the IME report of Dr. Edmonds on June 6, 2022, advised the plaintiff that itwas received on June 7, 2022, and served the report on plaintiff on June 8, 2022. There isno discovery issue pending. Itis understood that the filing of this request for a Pretrial Discovery Conference tolls the time for filing a motion to compel discovery on the disputed issues for the number of days between the filing of the request and issuance by the Court of a subsequent order pertaining to the discovery dispute. Opposing Party was served with a copy of REQUEST FOR PRETRIAL DISCOVERY CONFERENCE on: 6/9/2022 Date Pursuant to Local Rule 2.].17(A}(1), any opposition to this request for a Pretrial Discovery Conference must also be filed on an approved form and must be filed within five (5) court days of receipt of the request for a Pretrial Discovery Conference and must be served on the opposing party. | declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, (> 6/9/2022 Anthony N. DeMaria {S/ " __. Date Type or PrintName Signature of Partyor Attorney forParty PCV-70 ROS5-19 REQUEST FOR PRETRIAL DISCOVERY CONFERENCE Page 2 of 2 Mandatory Local Rule 2.1.17 1 PROOF OF SERVICE 2 || STATE OF CALIFORNIA, COUNTY OF FRESNO 3| At the time of service, Iwas over 18 years of age and not a party to this action. I an employed in the County of Fresno, State of California. My business address is 1690 W. Shaw 4 || Avenue, Ste. 220, Fresno, CA 93711. 5 On June 9, 2022, I served true copies of the following document(s) described ai 6 REQUEST FOR PRETRIAL DISCOVERY CONFERENCE on the interested parties in thig action as follows: "| PLAINTIFF COUNSEL: 8 Eugenia L. Steele Reza Torkzadeh 9 Tracy R. Horn THE TORKZADEH LAW FIRM 10 18650 MacArthur Blvd., Ste. 300 Irvine, CA 92612 ll PHONE: (310) 935-1111 FAX: (310) 935-0100 12 EMAIL; Eugenia(@torklaw.com EMAIL: christine@torklaw.com 13 EMAIL: tracy@torklaw.com 14 | _X BY MAIL: | enclosed said document(s) in a sealed envelope or package addressed ta the persons at the address listed on the Service List and placed the envelope for collection and 15 || mailing, following our ordinary business practices. I am readily familiar with this business’s practice for collecting and processing correspondence for mailing. On the same day the 16 || correspondence is placed from collection and mailing itis deposited in the ordinary course of "7 business with the United States Postal Service, in a sealed envelope with postage fully pre-paid. 18 X__By E-Mail or Electronic Transmission: Based on a court order or an agreement of the | parties to accept service by email or electronic transmission, Icaused the documents to be sent ta 19 the persons atthe e-mail addresses listed above. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the transmission was unsuccessful 20 I declare under penalty of perjury under the laws of the United States of America that thd 21|| foregoing is true and correct and that Iam employed in the office of a member of the bar of this | Court at whose direction the service was made. 22 Executed on June 9, 2022, at Fresno, California, 7 24 | JO OEE 25 @hris Galarza 26 |} 27 28