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
ELECTRONICALLY
1 DANIEL R. STERRETT (SBN 260290)
LAW OFFICES OF DANIEL STERRETT F I L E D
2 Superior Court of California,
315 Montgomery Street, Suite 900 County of San Francisco
3 San Francisco, CA 94104 07/31/2020
Tel: (415) 829-4485 Clerk of the Court
4 BY: EDNALEEN ALEGRE
Attorneys for Herzie Mendoza Deputy Clerk
5
6 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN FRANCISCO
7 UNLIMITED JURISDICTION
8
9 HERZIE MENDOZA, an individual, Case No.: CGC-19-575541
10 Plaintiff,
11 vs. STIPULATION TO CONTINUE TRIAL
DATE AND PRE-TRIAL DEADLINES
12
CITY AND COUNTY OF SAN FRANCISCO
13 AND DOES 1 THROUGH 10 INCLUSIVE,
14 Defendants Date Action Filed: April 26, 2019
Trial Date: October 5, 2020
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STIP. TO CONT. TRIAL
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1 IT IS HEREBY STIPULATED AND AGREED by the attorneys of record for all parties to
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Superior Court Case No. CGC-19-575541, plaintiff Herzie Mendoza and defendant City and
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County of San Francisco, that the trial date of this action may be continued to March 8, 2021 or
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the next available date thereafter, and that all dates and deadlines, including discovery dates will
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6 track the new trial date.
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WHEREAS, the repercussions of shelter-in-place orders due to the COVID-19 Pandemic, the
9 parties have been unable to conduct and complete discovery that is necessary to then prepare for
10 expert evaluations. See Government Code Section 68115.
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WHEREAS, this is the parties first request for a trial continuance.
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WHEREAS the parties agree that the existing trial date should be continued, and all dates that
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are calculated based on the existing trial date, including but not limited to discovery cut off, the
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15 time to demand expert witness disclosures, dispostive motion deadlines, and deadlines for expert
16 discovery under the Code of Civil Procedure, the California Rules of Court, and this Court’s
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local rules, should be reset to run from the new trial date rather than the initial trial date.
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STIP. TO CONT. TRIAL
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1 IT IS HEREBY STIPULATED:
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1. The parties stipulate that the trial date be continued from October 5, 2020 to March 8, 2021, or
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as soon thereafter as the court and all parties are available; and
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2. The parties stipulate that the existing trial date should be continued, and all dates that are
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6 calculated based on the existing trial date, including but not limited to discovery cut off, the time
7 to demand expert witness disclosures, and deadlines for expert discovery under the Code of Civil
8
Procedure, the California Rules of Court, and this Court’s local rules, and any and all motions,
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including dispositive motions, should be reset to run from the new trial date rather than the initial
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trial date.
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13 DATED: July _28__, 2020
LAW OFFICES OF DANIEL STERRETT
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16 By: Daniel Sterrett
___________________________
DANIEL R. STERRETT
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Attorney for Plaintiff HERZIE MENDOZA
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DATED: 28
July ___, 2020
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DENNIS J. HERRERA
21 City Attorney
DAVID DELBON
22 Deputy City Attorney
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By: ___________________________
25 DAVID DELBON
Attorney for Defendant
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CITY AND COUNTY OF SAN FRANCISCO
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STIP. TO CONT. TRIAL
-3
Document Filed Date
July 31, 2020
Case Filing Date
April 26, 2019
Category
PERSONAL INJURY/PROPERTY DAMAGE - NON-VEHICLE RELATED
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ELECTRONICALLY 1 DANIEL R. STERRETT (SBN 260290) LAW OFFICES OF DANIEL STERRETT F I L E D 2 Superior Court of California, 315 Montgomery Street, Suite 900 County of San Francisco 3 San Francisco, CA 94104 07/31/2020 Tel: (415) 829-4485 Clerk of the Court 4 BY: EDNALEEN ALEGRE Attorneys for Herzie Mendoza Deputy Clerk 5 6 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO 7 UNLIMITED JURISDICTION 8 9 HERZIE MENDOZA, an individual, Case No.: CGC-19-575541 10 Plaintiff, 11 vs. STIPULATION TO CONTINUE TRIAL DATE AND PRE-TRIAL DEADLINES 12 CITY AND COUNTY OF SAN FRANCISCO 13 AND DOES 1 THROUGH 10 INCLUSIVE, 14 Defendants Date Action Filed: April 26, 2019 Trial Date: October 5, 2020 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STIP. TO CONT. TRIAL -1 1 IT IS HEREBY STIPULATED AND AGREED by the attorneys of record for all parties to 2 Superior Court Case No. CGC-19-575541, plaintiff Herzie Mendoza and defendant City and 3 County of San Francisco, that the trial date of this action may be continued to March 8, 2021 or 4 the next available date thereafter, and that all dates and deadlines, including discovery dates will 5 6 track the new trial date. 7 8 WHEREAS, the repercussions of shelter-in-place orders due to the COVID-19 Pandemic, the 9 parties have been unable to conduct and complete discovery that is necessary to then prepare for 10 expert evaluations. See Government Code Section 68115. 11 WHEREAS, this is the parties first request for a trial continuance. 12 WHEREAS the parties agree that the existing trial date should be continued, and all dates that 13 are calculated based on the existing trial date, including but not limited to discovery cut off, the 14 15 time to demand expert witness disclosures, dispostive motion deadlines, and deadlines for expert 16 discovery under the Code of Civil Procedure, the California Rules of Court, and this Court’s 17 local rules, should be reset to run from the new trial date rather than the initial trial date. 18 /// 19 /// 20 21 /// 22 /// 23 /// 24 /// 25 /// 26 27 /// 28 /// STIP. TO CONT. TRIAL -2 1 IT IS HEREBY STIPULATED: 2 1. The parties stipulate that the trial date be continued from October 5, 2020 to March 8, 2021, or 3 as soon thereafter as the court and all parties are available; and 4 2. The parties stipulate that the existing trial date should be continued, and all dates that are 5 6 calculated based on the existing trial date, including but not limited to discovery cut off, the time 7 to demand expert witness disclosures, and deadlines for expert discovery under the Code of Civil 8 Procedure, the California Rules of Court, and this Court’s local rules, and any and all motions, 9 including dispositive motions, should be reset to run from the new trial date rather than the initial 10 trial date. 11 12 13 DATED: July _28__, 2020 LAW OFFICES OF DANIEL STERRETT 14 15 16 By: Daniel Sterrett ___________________________ DANIEL R. STERRETT 17 Attorney for Plaintiff HERZIE MENDOZA 18 19 DATED: 28 July ___, 2020 20 DENNIS J. HERRERA 21 City Attorney DAVID DELBON 22 Deputy City Attorney 23 24 By: ___________________________ 25 DAVID DELBON Attorney for Defendant 26 CITY AND COUNTY OF SAN FRANCISCO 27 28 STIP. TO CONT. TRIAL -3