On April 26, 2019 a
Stipulation,Agreement
was filed
involving a dispute between
Mendoza, Herzie,
and
City And County Of San Francisco,
Does 1 To 10,
for PERSONAL INJURY/PROPERTY DAMAGE - NON-VEHICLE RELATED
in the District Court of San Francisco County.
Preview
1 DANIEL R. STERRETT (SBN 260290)
LAW OFFICES OF DANIEL STERRETT
2
315 Montgomery Street, Suite 900 ELECTRONICALLY
3 San Francisco, CA 94104 FILED
Tel: (415) 829-4485 Superior Court of California,
County of San Francisco
4 Attorneys for Herzie Mendoza
07/22/2021
5 Clerk of the Court
BY: SANDRA SCHIRO
6 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA Deputy Clerk
FOR THE COUNTY OF SAN FRANCISCO
7 UNLIMITED JURISDICTION
8
9 HERZIE MENDOZA, an individual, Case No.: CGC-19-575541
10 Plaintiff,
11 vs. NOTICE OF EX PARTE APPLICATION
AND APPLICATION FOR
12
CITY AND COUNTY OF SAN FRANCISCO CONTINUANCE OF TRIAL DATE AND
AND DOES 1 THROUGH 10 INCLUSIVE, PRE-TRIAL DEADLINES
13
PER STIPULATION OR FOR ORDER
14 Defendants SHORTENING TIME FOR MOTION
FOR CONTINUANCE OF TRIAL DATE
15 AND PRE-TRIAL DEADLINES
16
17 Hearing Date: July 23, 2021
Time: 11:00
18 Place: Dept. 206
19
20
Date Action Filed: April 26, 2019
21 Trial Date: September 7, 2021
22
23
24
25
26
27
28
NOTICE AND MOTION
-1
1 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD
2
Plaintiff Herzie Mendoza (“Plaintiff”), hereby applies and moves, ex parte, for an order
3
continuing trial pursuant to a stipulation by all parties. Alternately, Plaintiff seeks an order
4
shortening time for a hearing on July 29, 2021 for a motion to continue trial to be heard.
5
6 This application is unopposed. The parties have stipulated to continue the trial date from
7 September 7, 2021 to February 22, 2022. Plaintiff makes this application on the grounds that
8
there have been delays in discovery relating to COVID-19, and the parties need additional time
9
to complete discovery. Defendant is taking an independent medical examination of Plaintiff on
10
August 4, 2021 and the parties have scheduled depositions of several witnesses. Moreover, the
11
12 parties would like to purse ADR prior to trial. The parties are looking to set a settlement
13 conference with the court in late August or early September.
14
Two prior continuances have been sought and granted – both were stipulated. As set
15
forth in the Memorandum of Points and Authorities and the Declaration of Daniel Sterrett, both
16
17
filed with this notice, good cause exists to order a trial continuance to the requested and
18 stipulated date.
19
DATED: July 22, 2021
20
LAW OFFICES OF DANIEL STERRETT
21
22
Daniel Sterrett
By: ___________________________
23
DANIEL R. STERRETT
24 Attorney for Plaintiff HERZIE MENDOZA
25
26
27
28
NOTICE AND MOTION
-2
Document Filed Date
July 22, 2021
Case Filing Date
April 26, 2019
Category
PERSONAL INJURY/PROPERTY DAMAGE - NON-VEHICLE RELATED
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Preview
1 DANIEL R. STERRETT (SBN 260290) LAW OFFICES OF DANIEL STERRETT 2 315 Montgomery Street, Suite 900 ELECTRONICALLY 3 San Francisco, CA 94104 FILED Tel: (415) 829-4485 Superior Court of California, County of San Francisco 4 Attorneys for Herzie Mendoza 07/22/2021 5 Clerk of the Court BY: SANDRA SCHIRO 6 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA Deputy Clerk FOR THE COUNTY OF SAN FRANCISCO 7 UNLIMITED JURISDICTION 8 9 HERZIE MENDOZA, an individual, Case No.: CGC-19-575541 10 Plaintiff, 11 vs. NOTICE OF EX PARTE APPLICATION AND APPLICATION FOR 12 CITY AND COUNTY OF SAN FRANCISCO CONTINUANCE OF TRIAL DATE AND AND DOES 1 THROUGH 10 INCLUSIVE, PRE-TRIAL DEADLINES 13 PER STIPULATION OR FOR ORDER 14 Defendants SHORTENING TIME FOR MOTION FOR CONTINUANCE OF TRIAL DATE 15 AND PRE-TRIAL DEADLINES 16 17 Hearing Date: July 23, 2021 Time: 11:00 18 Place: Dept. 206 19 20 Date Action Filed: April 26, 2019 21 Trial Date: September 7, 2021 22 23 24 25 26 27 28 NOTICE AND MOTION -1 1 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD 2 Plaintiff Herzie Mendoza (“Plaintiff”), hereby applies and moves, ex parte, for an order 3 continuing trial pursuant to a stipulation by all parties. Alternately, Plaintiff seeks an order 4 shortening time for a hearing on July 29, 2021 for a motion to continue trial to be heard. 5 6 This application is unopposed. The parties have stipulated to continue the trial date from 7 September 7, 2021 to February 22, 2022. Plaintiff makes this application on the grounds that 8 there have been delays in discovery relating to COVID-19, and the parties need additional time 9 to complete discovery. Defendant is taking an independent medical examination of Plaintiff on 10 August 4, 2021 and the parties have scheduled depositions of several witnesses. Moreover, the 11 12 parties would like to purse ADR prior to trial. The parties are looking to set a settlement 13 conference with the court in late August or early September. 14 Two prior continuances have been sought and granted – both were stipulated. As set 15 forth in the Memorandum of Points and Authorities and the Declaration of Daniel Sterrett, both 16 17 filed with this notice, good cause exists to order a trial continuance to the requested and 18 stipulated date. 19 DATED: July 22, 2021 20 LAW OFFICES OF DANIEL STERRETT 21 22 Daniel Sterrett By: ___________________________ 23 DANIEL R. STERRETT 24 Attorney for Plaintiff HERZIE MENDOZA 25 26 27 28 NOTICE AND MOTION -2