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  • TIMED OUT, LLC VS C.V. HOLDINGS, INC. Other Non-Personal Injury/Property Damage tort (General Jurisdiction) document preview
  • TIMED OUT, LLC VS C.V. HOLDINGS, INC. Other Non-Personal Injury/Property Damage tort (General Jurisdiction) document preview
						
                                

Preview

1 HALL GRIFFIN LLP JOHN T. GRIFFIN, State Bar No. 149713 2 jgriffin@hallgriffin.com BENJAMIN C. BERTCH, State Bar No. 306858 3 bbertch@hallgriffin.com 1851 East First Street, 10th Floor 4 Santa Ana, California 92705-4052 Telephone: (714) 918-7000 5 Facsimile: (714) 918-6996 6 Attorneys for Defendant C.V. HOLDINGS, INC., dba AZUL ULTRA LOUNGE 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF LOS ANGELES, CENTRAL DISTRICT 10 11 TIMED OUT, LLC, CASE NO. 19GDCV00373 12 Plaintiff, STIPULATION TO CONTINUE TRIAL AND [PROPOSED] ORDER THEREON 13 vs. JUDGE: Hon. Ralph C. Hofer Electronically Received 02/03/2021 04:15 PM 14 C.V. HOLDINGS, INC., a California DEPT.: D corporation doing business as AZUL ULTRA ACTION FILED: March 22, 2019 15 LOUNGE; and DOES 1 to 20, inclusive, TRIAL DATE: April 12, 2021 16 Defendants. 17 18 WHEREAS, trial in the above-captioned matter is presently scheduled on April 12, 2021; 19 WHEREAS, the parties have been undertaking their best efforts to conduct discovery in 20 this matter, but those efforts have been frustrated and delayed as a result of the ongoing COVID- 21 19 pandemic; 22 WHEREAS, as part of those efforts to conduct discovery, the parties met and conferred 23 and agreed upon a detailed Stipulation and Protective Order for Plaintiff’s disclosure of certain 24 confidential materials, which materials have now been produced; 25 WHEREAS, numerous depositions of percipient witnesses and expert witnesses remain to 26 be completed, which could not have previously been taken until after the production of 27 confidential materials and due to delays associated with the Stay at Home orders issued as a result 28 of the COVID-19 pandemic; STIPULATION TO CONTINUE TRIAL AND [PROPOSED] ORDER THEREON 03958.0001 4814-9561-1610.1