On February 03, 2021 a
Stipulation,Agreement
was filed
involving a dispute between
Gardea, Rory,
and
Does 1-25,
Morales, Brissa,
Walmart Inc.,
Walmart, Inc,
for Other PI/PD/WD Unlimited
in the District Court of San Bernardino County.
Preview
Andrew N. Kohn, Esq., SBN 166385
Rafael Garcia~Salgad0, Esq., SBN 283230 SUPERDREOL'gTEOFCALWORNIA
PETTIT KOHN INGRASSIA LUTZ & DOLIN PC COUNTY 0F SAN BERNARDINO
11622 El Camino Real, Suite 300 SAN BERNARD'NO ”'STR'CT
San Diego, CA 92130
Telephone: (858) 755—8500 MAY 1 7 2023
Facsimile: (858) 755-8504
E-mail: akohn@gettitkohn.com
rgarciampettitkohnfiom BY.
r
K C?
VALERIE URUENA, DEPUTY
p
Attorneys for Defendant
WALMART INC.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
10
ll RORY GARDEA, an individual, CASE NO.: CIVSB21 l4] 91
Plaintiff, STIPULATION TO CONTINUE TRIAL
v. WRDER
AND TRIAL-RELATED DATES AND
5"2 s c 407.3 3
THEREON
7423 -
@
WALMART, INC, Delaware corporation;
a
BRISSA MORALES, an individual; and Dept: $22
DOES 1-25, inclusive, Judge: Hon. David E. Driscoll
Filed: June 2, 2021
Defendants. Trial: September l l, 2023
Plaintiff RORY GARDEA (“Plaintiff”) and Defendant WALMART INC. (“Walmart,”
and together with Plaintiff, the “Panics"), by and through their respective counsel, hereby agree
and stipulate, as follows:
1. Trial in this matter is currently set for September 1 1, 2023. The Parties have
requested ajury trial.
2. This is the first continuance of the trial and related dates requested by the
Parties.
3. On May 10, 2023, Plaintiff's counsel filed a Notice ofMotion and Motion to Be
Relieved as Counsel on the basis that counsel was no longer able to contact Plaintiff.
4. Despite their diligent efforts, the Parties have been unable t0 obtain essential
28 testimony, documents, or other material evidence t0 prepare for trial and that are necessary for
2354-3340
I
STIPULATION TO CONTINUE TRIAL AND RELATED DATES AND [PROPOSED] ORDER
l resolution.
2 5. Neither ofthe Parties will be harmed or prejudiced by the requested continuance,
3 and the interests ijustice will be served by a continuance 0fthe trial and related dates.
4 6. The Parties agree to a continuance 0fthejury trial to March 1 1, 2024, or
5 the Court’s next available date thereafter. The Parties agree to continue the trial-related dates in
6 accordance with the new trial date.
7 Based 0n the foregoing, good cause exists to continue the trial in this matter to March l l,
8 2024, 0r to a subsequent date that is convenient to the Court’s calendar, and to continue the expert
9 exchange dates and discovery and motion cut-off dates per Code based 0n this new trial date.
IO DOWNTOWN L.A. LAW GROUP
l ]
J
l2 Q/
l3
Dated: May IO, 2023, By:
14
Vanessa Fantasia, Esq.
Attorney for Plaintiff
15
RORY GARDEA
16
PETTIT KOHN INGRASSIA LUTz & DOLIN PC
l7
19
Dated: May Io 2023 By: .
”W
A'nd wN. Kohn, Esq.
-
Rafa Garcia-Salgado, Esq.
l
20 Attorneys for Defendant
WALMART INC.
2]
22
23
24
25
26
27
28
2354—3340
2
STIPULATION TO CONTINUE TRIAL AND RELATED DATES ANDf‘PRG-PGS‘B‘D] ORDER
Document Filed Date
May 17, 2023
Case Filing Date
February 03, 2021
Category
Other PI/PD/WD Unlimited
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Andrew N. Kohn, Esq., SBN 166385 Rafael Garcia~Salgad0, Esq., SBN 283230 SUPERDREOL'gTEOFCALWORNIA PETTIT KOHN INGRASSIA LUTZ & DOLIN PC COUNTY 0F SAN BERNARDINO 11622 El Camino Real, Suite 300 SAN BERNARD'NO ”'STR'CT San Diego, CA 92130 Telephone: (858) 755—8500 MAY 1 7 2023 Facsimile: (858) 755-8504 E-mail: akohn@gettitkohn.com rgarciampettitkohnfiom BY. r K C? VALERIE URUENA, DEPUTY p Attorneys for Defendant WALMART INC. SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO 10 ll RORY GARDEA, an individual, CASE NO.: CIVSB21 l4] 91 Plaintiff, STIPULATION TO CONTINUE TRIAL v. WRDER AND TRIAL-RELATED DATES AND 5"2 s c 407.3 3 THEREON 7423 - @ WALMART, INC, Delaware corporation; a BRISSA MORALES, an individual; and Dept: $22 DOES 1-25, inclusive, Judge: Hon. David E. Driscoll Filed: June 2, 2021 Defendants. Trial: September l l, 2023 Plaintiff RORY GARDEA (“Plaintiff”) and Defendant WALMART INC. (“Walmart,” and together with Plaintiff, the “Panics"), by and through their respective counsel, hereby agree and stipulate, as follows: 1. Trial in this matter is currently set for September 1 1, 2023. The Parties have requested ajury trial. 2. This is the first continuance of the trial and related dates requested by the Parties. 3. On May 10, 2023, Plaintiff's counsel filed a Notice ofMotion and Motion to Be Relieved as Counsel on the basis that counsel was no longer able to contact Plaintiff. 4. Despite their diligent efforts, the Parties have been unable t0 obtain essential 28 testimony, documents, or other material evidence t0 prepare for trial and that are necessary for 2354-3340 I STIPULATION TO CONTINUE TRIAL AND RELATED DATES AND [PROPOSED] ORDER l resolution. 2 5. Neither ofthe Parties will be harmed or prejudiced by the requested continuance, 3 and the interests ijustice will be served by a continuance 0fthe trial and related dates. 4 6. The Parties agree to a continuance 0fthejury trial to March 1 1, 2024, or 5 the Court’s next available date thereafter. The Parties agree to continue the trial-related dates in 6 accordance with the new trial date. 7 Based 0n the foregoing, good cause exists to continue the trial in this matter to March l l, 8 2024, 0r to a subsequent date that is convenient to the Court’s calendar, and to continue the expert 9 exchange dates and discovery and motion cut-off dates per Code based 0n this new trial date. IO DOWNTOWN L.A. LAW GROUP l ] J l2 Q/ l3 Dated: May IO, 2023, By: 14 Vanessa Fantasia, Esq. Attorney for Plaintiff 15 RORY GARDEA 16 PETTIT KOHN INGRASSIA LUTz & DOLIN PC l7 19 Dated: May Io 2023 By: . ”W A'nd wN. Kohn, Esq. - Rafa Garcia-Salgado, Esq. l 20 Attorneys for Defendant WALMART INC. 2] 22 23 24 25 26 27 28 2354—3340 2 STIPULATION TO CONTINUE TRIAL AND RELATED DATES ANDf‘PRG-PGS‘B‘D] ORDER