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2ON224-OOFF
S
SEN on = eo, ob
20.00
BY FAX
William E. Weiss, State Bar No. 73108
LAW OFFICES OF WILLIAM E. WEISS
140 Geary Street, 7th Floor
San Francisco, California 94108
Telephone: (415) 362-6765
Facsimile: (415) 362-2405
Attorneys for Plaintiffs:
C™IGINAL
SANDRA HERNANDEZ-PEREZ, individually and as successor in interest to JESUS
BERRIOS II and JENILEE BERRIOS, individually and as successor in interest to JESUS
BERRIOS IT
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF CONTRA COSTA
SANDRA HERNANDEZ-PEREZ,
individually and as successor in interest to
Jesus Berrios II, JENILEE BERRIOS,
individually and as successor in interest to
Jesus Berrios II,
Plaintiffs,
v.
CALTRANS (CALIFORNIA
DEPARTMENT OF TRANSPORTATION),
JESUS BERRIOS and DOES 1-75,
Defendants.
JESUS BERRIOS,
Plaintiff,
Vv.
STATE OF CALIFORNIA,
eS wS Se SS SH SY
Defendant.
Case No.: C20-01144
(Complaint Filed: 06/30/2020
1* Amended Complaint Filed: 09/21/2020)
JOINT STIPULATION AND ORDER TO
CONSOLIDATE RELATED ACTION
WITH PENDING ACTION OF
HERNANDEZ-PEREZ, ET AL. v.
CALTRANS, ETAL.
Assigned For All Purposes To:
The Hon. Steven K. Austin — Dept. 33
Case No.: C20-02009
(Complaint Filed: October 2, 2020)
Assigned For All Purposes To:
The Hon. Charles S. Treat — Dept. 12
JQ0oase cons C2.0-200% into
-C00-C\N44 |
JOINT STIPULATION AND ORDER TO CONSOLIDATE RELATED ACTION WITH PENDING ACTION OF
HERNANDEZ-PEREZ, ET AL, v. CALTRANS, ET AL.Sc FO Oo NH BR we
—
The undersigned parties, Plaintiffs SANDRA HERNANDEZ-PEREZ, individually and as
successor in interest to Jesus Berrios II and JENILEE BERRIOS, individually and as successor in
interest to Jesus Berrios I and Plaintiff JESUS BERRIOS, representing the wifé,
mother, and
father of decedent Jesus Berrios II, are all Plaintiffs and/or potential Plaintiffs to|the September 22,
2019 motor vehicle accident, and Defendants CALTRANS (CALIFORNIA DEPARTENT OF
TRANSPORTATION) and STATE OF CALIFORNIA, by and through their respective counsel,
HEREBY AGREE AND STIPULATE to the consolidation of the following actions now
pending: |
1. Sandra Hernandez-Perez, et al. v. Caltrans, et al.
Case No.: C20-01144 (Instant Action)
2. Jesus Berrios v. State of California
Case No.: C20-02009
These actions are related and arise out of the same motor vehicle accident, The parties are
the wife, mother, and father of the decedent, Jesus Berrios II. Because they share
common
questions of law and/or facts, consolidation is appropriate pursuant to California Code of Civil
Procedure Section 1048. To avoid unnecessary fees and costs or delay in trying each case
separately, the parties herein agree and stipulate to consolidation of the Berrios action with the
Hernandez-Perez action, which was the first action filed.
SO STIPULATED.
DATED: November {7 ,2020 LAW OFFICES OF WILLIAM E,
BY:
JAM E’ WEISS
Attorneys for Plaintiffs
.| WEISS
SANDRA HERNANDEZ-PEREZ,
individually and as successor in interest to
Jesus Berrios II and JENILEE BERRIOS,
individually and as successor in interest to
Jesus Berrios II
2
JOINT STIPULATION AND ORDER TO CONSOLIDATE RELATED ACTION WITH PENDING ACTION OF
HERNANDEZ-PEREZ, ET AL. v. CALTRANS, ETAL.YAU Bw N
DATED: November 16, 2020 THE BRANDI LAW FIRM
DATED: November 17_, 2020
py eon wa LL ade
THOMAS J. GRANDI |
Attorneys for Plaintiff JESUS BERRIOS
CALIFORNIA DEPARTMENT|OF
TRANSPORTATION-LEGAL DIVISION
wv, Rody DOL
3
ROSEMARY LOVE
Attorneys for Defendants CALTRANS
(CALIFORNIA DEPARTMENT OF
TRANSPORTATION) and STATE OF
CALIFORNIA |
JOINT STIPULATION AND ORDER TO CONSOLIDATE RELATED ACTION WITH PENDING ACTION OF
HERNANDEZ. PEREZ, ET AL v. CALTRANS. ETAL,So em NDAD HW RB Ww DP =
ORDER
The Court having read and considered all relevant information, document and evidence
on file in this matter and the mutual agreement by Plaintiffs SANDRA HERNANDEZ-PEREZ,
individually and as successor in interest to Jesus Berrios II and JENILEE BERRIOS,
individually and as successor in interest to Jesus Berrios I and JESUS BERRIOS and
Defendants CALTRANS (CALIFORNIA DEPARTMENT OF TRANSPORTATION) and
STATE OF CALIFORNIA, and no opposition thereto and good cause appearing therefor:
IT IS HEREBY ORDERED that, upon entry of this Order, the civil action filed with this
Court on October 2, 2020, entitled Jesus Berrios v. State of California, Case No: C20-02009,
shall be consolidated inte and made a part of the related civil action filed on June 30,
2020, Sandra Hernandez-Perez, et al. v. Caltrans, et al., Case No.: 20-0144.
IT IS FURTHER ORDERED that all documents filed, submitted, and/ot lodged with
this Court shall be filed under the earliest filed action, Hernandez-Perez case cshtin, Case No.:
C20-01144, All documents filed, submitted, and/or lodged shall be identified as a
“Consolidated Action,” and shall list all consolidated actions thereto.
SO ORDERED. !
THE HON. STEVEN K. AUSTIN 1
Judge of the Superior Court \
County of Contra Costa
4
JOINT STIPULATION AND ORDER TO CONSOLIDATE RELATED ACTION WITH PENDING ACTION OF
IEZ-P) ‘AL. v. CALTI 1
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2ON224-OOFF S SEN on = eo, ob 20.00 BY FAX William E. Weiss, State Bar No. 73108 LAW OFFICES OF WILLIAM E. WEISS 140 Geary Street, 7th Floor San Francisco, California 94108 Telephone: (415) 362-6765 Facsimile: (415) 362-2405 Attorneys for Plaintiffs: C™IGINAL SANDRA HERNANDEZ-PEREZ, individually and as successor in interest to JESUS BERRIOS II and JENILEE BERRIOS, individually and as successor in interest to JESUS BERRIOS IT SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF CONTRA COSTA SANDRA HERNANDEZ-PEREZ, individually and as successor in interest to Jesus Berrios II, JENILEE BERRIOS, individually and as successor in interest to Jesus Berrios II, Plaintiffs, v. CALTRANS (CALIFORNIA DEPARTMENT OF TRANSPORTATION), JESUS BERRIOS and DOES 1-75, Defendants. JESUS BERRIOS, Plaintiff, Vv. STATE OF CALIFORNIA, eS wS Se SS SH SY Defendant. Case No.: C20-01144 (Complaint Filed: 06/30/2020 1* Amended Complaint Filed: 09/21/2020) JOINT STIPULATION AND ORDER TO CONSOLIDATE RELATED ACTION WITH PENDING ACTION OF HERNANDEZ-PEREZ, ET AL. v. CALTRANS, ETAL. Assigned For All Purposes To: The Hon. Steven K. Austin — Dept. 33 Case No.: C20-02009 (Complaint Filed: October 2, 2020) Assigned For All Purposes To: The Hon. Charles S. Treat — Dept. 12 JQ0oase cons C2.0-200% into -C00-C\N44 | JOINT STIPULATION AND ORDER TO CONSOLIDATE RELATED ACTION WITH PENDING ACTION OF HERNANDEZ-PEREZ, ET AL, v. CALTRANS, ET AL.Sc FO Oo NH BR we — The undersigned parties, Plaintiffs SANDRA HERNANDEZ-PEREZ, individually and as successor in interest to Jesus Berrios II and JENILEE BERRIOS, individually and as successor in interest to Jesus Berrios I and Plaintiff JESUS BERRIOS, representing the wifé, mother, and father of decedent Jesus Berrios II, are all Plaintiffs and/or potential Plaintiffs to|the September 22, 2019 motor vehicle accident, and Defendants CALTRANS (CALIFORNIA DEPARTENT OF TRANSPORTATION) and STATE OF CALIFORNIA, by and through their respective counsel, HEREBY AGREE AND STIPULATE to the consolidation of the following actions now pending: | 1. Sandra Hernandez-Perez, et al. v. Caltrans, et al. Case No.: C20-01144 (Instant Action) 2. Jesus Berrios v. State of California Case No.: C20-02009 These actions are related and arise out of the same motor vehicle accident, The parties are the wife, mother, and father of the decedent, Jesus Berrios II. Because they share common questions of law and/or facts, consolidation is appropriate pursuant to California Code of Civil Procedure Section 1048. To avoid unnecessary fees and costs or delay in trying each case separately, the parties herein agree and stipulate to consolidation of the Berrios action with the Hernandez-Perez action, which was the first action filed. SO STIPULATED. DATED: November {7 ,2020 LAW OFFICES OF WILLIAM E, BY: JAM E’ WEISS Attorneys for Plaintiffs .| WEISS SANDRA HERNANDEZ-PEREZ, individually and as successor in interest to Jesus Berrios II and JENILEE BERRIOS, individually and as successor in interest to Jesus Berrios II 2 JOINT STIPULATION AND ORDER TO CONSOLIDATE RELATED ACTION WITH PENDING ACTION OF HERNANDEZ-PEREZ, ET AL. v. CALTRANS, ETAL.YAU Bw N DATED: November 16, 2020 THE BRANDI LAW FIRM DATED: November 17_, 2020 py eon wa LL ade THOMAS J. GRANDI | Attorneys for Plaintiff JESUS BERRIOS CALIFORNIA DEPARTMENT|OF TRANSPORTATION-LEGAL DIVISION wv, Rody DOL 3 ROSEMARY LOVE Attorneys for Defendants CALTRANS (CALIFORNIA DEPARTMENT OF TRANSPORTATION) and STATE OF CALIFORNIA | JOINT STIPULATION AND ORDER TO CONSOLIDATE RELATED ACTION WITH PENDING ACTION OF HERNANDEZ. PEREZ, ET AL v. CALTRANS. ETAL,So em NDAD HW RB Ww DP = ORDER The Court having read and considered all relevant information, document and evidence on file in this matter and the mutual agreement by Plaintiffs SANDRA HERNANDEZ-PEREZ, individually and as successor in interest to Jesus Berrios II and JENILEE BERRIOS, individually and as successor in interest to Jesus Berrios I and JESUS BERRIOS and Defendants CALTRANS (CALIFORNIA DEPARTMENT OF TRANSPORTATION) and STATE OF CALIFORNIA, and no opposition thereto and good cause appearing therefor: IT IS HEREBY ORDERED that, upon entry of this Order, the civil action filed with this Court on October 2, 2020, entitled Jesus Berrios v. State of California, Case No: C20-02009, shall be consolidated inte and made a part of the related civil action filed on June 30, 2020, Sandra Hernandez-Perez, et al. v. Caltrans, et al., Case No.: 20-0144. IT IS FURTHER ORDERED that all documents filed, submitted, and/ot lodged with this Court shall be filed under the earliest filed action, Hernandez-Perez case cshtin, Case No.: C20-01144, All documents filed, submitted, and/or lodged shall be identified as a “Consolidated Action,” and shall list all consolidated actions thereto. SO ORDERED. ! THE HON. STEVEN K. AUSTIN 1 Judge of the Superior Court \ County of Contra Costa 4 JOINT STIPULATION AND ORDER TO CONSOLIDATE RELATED ACTION WITH PENDING ACTION OF IEZ-P) ‘AL. v. CALTI 1