On March 02, 2015 a
Motion-Secondary
was filed
involving a dispute between
Rigoli, Brianne,
and
C.R. England, Inc. A Utah Corporation,
England Global Logistics Usa, Inc. A Utah Corporation,
Torres, Lorena,
Rigoli, Brianne,
for Wrongful Termination
in the District Court of San Bernardino County.
Preview
f
r
1 Jeffrey A Rager Esq SBN 185216
James Y Yoon Esq SBN 289906
2 THE RAGER LAW FIRM v F
970 West 190 Street Suite 340
3 Torrance California 90502
Telephone 310 527 6994 2017
4 Facsimile 310 527 6800
Email je xa erlawoffices com
i
5 ames a ragerlawoffices com
6 Melanie Savarese SBN 216950
Savarese Law Firm
7 37 W Sierra Madre Blvd
Sierra Madre CA 91024
8 Phone 626 355 3264
Facsimile 626 355 3491
9 Email melanie savareselawfirm com
10 Attorneys for Plaintiff BRIANNE RIGOLI
11 SUPERIOR COURT OF THE STATE OF CALIFORNIA
12 FOR THE COUNTY OF SAN BERNARDINO
13
14 BRIANNE RIGOLI CASE No CIVDS 1502545
15 Assigned To Hon Janet M Frangie Dept
Plaintiff S29
16
vs
17 PLAINTIFF S OPPOSITION TO
DEFENDANTS EX PARTE
18 C R ENGLAND INC a Utah Corporation APPLICATION TO CONTINUE TRIAL
ENGLAND GLOBAL LOGISTICS USA INC DECLARATION OF MELANIE
19 a Utah Corporation LORENA TORRES an SAVARESE
individual and DOES 1 through 10 inclusive
20 Date December 22 2017
Time 8 30 a m
21 Defendants Dept S29
22
23 Filed March 2 2015
TRC January 4 2018
24 Trial January 8 2018
25
26
27
28
PLAINTIFF S OPPOSITION TO DEFENDANTS EX PARTE APPLICATION TO CONTINUE
TRIAL
1
2 I FACTS RELEVANT TO DEFENDANTS EX PARTE APPLICATION
3 This case will be three years old shortly
4
One year ago the trial date was continued an entire year while no discovery absent a request
5 for supplemental discovery was done and the parties waited for the trial date to draw near It is time
6 for this case to be tried
7
Defendants set forth in their application that they are awaiting information from Plaintiff that
8 their experts need That statement is not entirely accurate Plaintiff produced document to defendants
9 on July 8 2015 October 6 2015 June 14 2016 December 7 2016 January 4 2017 and most recently
10 on December 20 2017 Savarese Decl 2 The documents produced on December 20 h are those that
11 Defendant has in its own possession but that Plaintiffproduced in an abundance ofcaution to avoid any
12 argument of prejudice Id at 3 They are documents from a prior lawsuit to which Defendant was a
13 party Ibid Defendant sent an e mail contending that Plaintiff is required to produce her most recent
14 medical records from early 2017 but these are not medical records that Ms Rigoli currently has in her
15 possession Savarese Decl 4 They are however records that Defendants have subpoenaed in the past
16 and certainly could have re subpoenaed Ibid Plaintiff knows of no other outstanding discovery that
17 any expert may need
18 Two expert depositions occurred on December 21 2017 and all expert depositions will be
28th
19 complete as of December Savarese Decl 5
20 The parties have met and conferred about motions in limine have conferred as to the joint trial
21 documents and plaintiff is prepared to have those submitted to the court Savarese Decl 6
22 Plaintiff is sympathetic to the unfortunate situation defense counsel is in These papers have been
23 filed simply to make sure that the court has a complete picture of where the case stands to date While
24
25
26
27
28
PLAINTIFF S OPPOSITION TO DEFENDANTS EX PARTE APPLICATION TO CONTINUE
TRIAL
Document Filed Date
December 22, 2017
Case Filing Date
March 02, 2015
Category
Wrongful Termination
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f r 1 Jeffrey A Rager Esq SBN 185216 James Y Yoon Esq SBN 289906 2 THE RAGER LAW FIRM v F 970 West 190 Street Suite 340 3 Torrance California 90502 Telephone 310 527 6994 2017 4 Facsimile 310 527 6800 Email je xa erlawoffices com i 5 ames a ragerlawoffices com 6 Melanie Savarese SBN 216950 Savarese Law Firm 7 37 W Sierra Madre Blvd Sierra Madre CA 91024 8 Phone 626 355 3264 Facsimile 626 355 3491 9 Email melanie savareselawfirm com 10 Attorneys for Plaintiff BRIANNE RIGOLI 11 SUPERIOR COURT OF THE STATE OF CALIFORNIA 12 FOR THE COUNTY OF SAN BERNARDINO 13 14 BRIANNE RIGOLI CASE No CIVDS 1502545 15 Assigned To Hon Janet M Frangie Dept Plaintiff S29 16 vs 17 PLAINTIFF S OPPOSITION TO DEFENDANTS EX PARTE 18 C R ENGLAND INC a Utah Corporation APPLICATION TO CONTINUE TRIAL ENGLAND GLOBAL LOGISTICS USA INC DECLARATION OF MELANIE 19 a Utah Corporation LORENA TORRES an SAVARESE individual and DOES 1 through 10 inclusive 20 Date December 22 2017 Time 8 30 a m 21 Defendants Dept S29 22 23 Filed March 2 2015 TRC January 4 2018 24 Trial January 8 2018 25 26 27 28 PLAINTIFF S OPPOSITION TO DEFENDANTS EX PARTE APPLICATION TO CONTINUE TRIAL 1 2 I FACTS RELEVANT TO DEFENDANTS EX PARTE APPLICATION 3 This case will be three years old shortly 4 One year ago the trial date was continued an entire year while no discovery absent a request 5 for supplemental discovery was done and the parties waited for the trial date to draw near It is time 6 for this case to be tried 7 Defendants set forth in their application that they are awaiting information from Plaintiff that 8 their experts need That statement is not entirely accurate Plaintiff produced document to defendants 9 on July 8 2015 October 6 2015 June 14 2016 December 7 2016 January 4 2017 and most recently 10 on December 20 2017 Savarese Decl 2 The documents produced on December 20 h are those that 11 Defendant has in its own possession but that Plaintiffproduced in an abundance ofcaution to avoid any 12 argument of prejudice Id at 3 They are documents from a prior lawsuit to which Defendant was a 13 party Ibid Defendant sent an e mail contending that Plaintiff is required to produce her most recent 14 medical records from early 2017 but these are not medical records that Ms Rigoli currently has in her 15 possession Savarese Decl 4 They are however records that Defendants have subpoenaed in the past 16 and certainly could have re subpoenaed Ibid Plaintiff knows of no other outstanding discovery that 17 any expert may need 18 Two expert depositions occurred on December 21 2017 and all expert depositions will be 28th 19 complete as of December Savarese Decl 5 20 The parties have met and conferred about motions in limine have conferred as to the joint trial 21 documents and plaintiff is prepared to have those submitted to the court Savarese Decl 6 22 Plaintiff is sympathetic to the unfortunate situation defense counsel is in These papers have been 23 filed simply to make sure that the court has a complete picture of where the case stands to date While 24 25 26 27 28 PLAINTIFF S OPPOSITION TO DEFENDANTS EX PARTE APPLICATION TO CONTINUE TRIAL