On August 14, 2020 a
Motion,Ex Parte
was filed
involving a dispute between
Corona, Maria Ochoa,
and
Cardenas Market An Unknown Business Entity,
Cardenas Markets, Llc,
Does 2-50 Inclusive,
for Other PI/PD/WD Unlimited
in the District Court of San Bernardino County.
Preview
F I L E_ I3
' SUPERDH COURT Gs {.MFORMA
Rhett P. Warrlnel‘, Esq. - Bar N0. 145211 COUNT” r):- 32% :{Iieln‘fzigzg‘-lryw
Michael Chuah, Esq. - Bar No. 318633 MN REBNF‘aUl-l -‘--- vL \*--
WARRINER, GREEN & RILEY, LLP 1U? ’i
I1
2623
355 S. Grand Avenue, Suite 2450
Los Angeles, CA 90071
(213) 943-1405 tel
(213) 943-1408 fax
rwarriner@thewgrlawfirm.com
Attorneys for Defendant CARDENAS MARKETS LLC
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO—SAN BERNARDINO DISTRICT
MARIA OCHOA CORONA, an Individual, ) CASE NO.: CIVDSZOI7590
)
Plaintiffs, )
) EX PARTE APPLICATION REQUESTING
VS' ) ORDER T0 CONTINUE TRIAL DATE;
) DECLARATION 0F NOTICE
CARDENAS MARKET, an Unknown Bus1ness
_
)
Entlty; DOES TO 50’ Induswe’
1
) [Filed concurrently with the Memorandum in
) Support QfEx Parte Application Requesting Order
Defendants'
t0 Continue Trial Date, and Proposed Order]
3
) DATE: July 18, 2023 y L4
) TIME: 8:30 am. 0 u
I
) DEPT: s22
\0 ”7
JUDGE: Hon. Bryan Foster lg?
20 g
21
22
Defendant, through their counsel of record, hereby applies ex parté for an order continuing the
23
trial date in this action from August 21, 2023 t0 November 20, 2023 or t0 a time convenient for the
24
Court, or in the alternative, a date to be set at a further trial setting conference. A11 trial readiness
25
conference dates will be set to the new trial dates.
26
1. This application is made on the ground to allow more time for Parties to complete mediation and
27
discuss settlement as provided under Court Rule 3. 1322(c)(7). Defendant also requires additional time
28
to schedule expert witnesses as provided under Court Rule 3.1332(c)(1).
1
EX PARTE APPLICATION REQUESTING ORDER TO CONTINUE TRIAL DATE;
DECLARATION 0F NOTICE AND PROPOSED ORDER.
2. In support of this application, I can state, based upon personal knowledge:
(a) Plaintiff filed the complaint in the above entitled action on August 14, 2020. A11 discovery has
been completed and the case is set for trial on August 14, 2023.
(b) Plaintiff‘s counsel has met and conferred with our office. Both parties have agreed to and signed
a stipulation for 9O days as Parties in the case are working towards private mediation. A continuance
will allow time for this issue to firm up. A copy of the signed stipulation has been included in the
supporting Memorandum filed with this application.
(c) Plaintiff s counsel is communicating with MediCal for document production relevant for
evidentiary purposes and is waiting t0 complete this task.
10 3. Plaintiff’s Counsel conferred With our office on July 12, 2023 that this application would be
11
presented to this Court in Department $22 on an ex parte basis. Plaintiff‘s counsel informed
12 Defendant’s Counsel they would not oppose the application.
13
14 declare under penalty of perjury under the laws of the State of California that the foregoing
I is true and
15
correct.
16
17
18 Date: July 13, 2023 WARRINER,
GREyLEY LLP
20
21
22
Mhael Chuah, qu. - Declarant
Attorneys for Defendants,
23 CARDENAS MARKETS LLC
24
25
26
27
28
2
EX PARTE APPLICATION REQUESTING ORDER TO CONTINUE TRIAL DATE;
DECLARATION 0F NOTICE AND PROPOSED ORDER.
Document Filed Date
July 14, 2023
Case Filing Date
August 14, 2020
Category
Other PI/PD/WD Unlimited
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
F I L E_ I3 ' SUPERDH COURT Gs {.MFORMA Rhett P. Warrlnel‘, Esq. - Bar N0. 145211 COUNT” r):- 32% :{Iieln‘fzigzg‘-lryw Michael Chuah, Esq. - Bar No. 318633 MN REBNF‘aUl-l -‘--- vL \*-- WARRINER, GREEN & RILEY, LLP 1U? ’i I1 2623 355 S. Grand Avenue, Suite 2450 Los Angeles, CA 90071 (213) 943-1405 tel (213) 943-1408 fax rwarriner@thewgrlawfirm.com Attorneys for Defendant CARDENAS MARKETS LLC SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO—SAN BERNARDINO DISTRICT MARIA OCHOA CORONA, an Individual, ) CASE NO.: CIVDSZOI7590 ) Plaintiffs, ) ) EX PARTE APPLICATION REQUESTING VS' ) ORDER T0 CONTINUE TRIAL DATE; ) DECLARATION 0F NOTICE CARDENAS MARKET, an Unknown Bus1ness _ ) Entlty; DOES TO 50’ Induswe’ 1 ) [Filed concurrently with the Memorandum in ) Support QfEx Parte Application Requesting Order Defendants' t0 Continue Trial Date, and Proposed Order] 3 ) DATE: July 18, 2023 y L4 ) TIME: 8:30 am. 0 u I ) DEPT: s22 \0 ”7 JUDGE: Hon. Bryan Foster lg? 20 g 21 22 Defendant, through their counsel of record, hereby applies ex parté for an order continuing the 23 trial date in this action from August 21, 2023 t0 November 20, 2023 or t0 a time convenient for the 24 Court, or in the alternative, a date to be set at a further trial setting conference. A11 trial readiness 25 conference dates will be set to the new trial dates. 26 1. This application is made on the ground to allow more time for Parties to complete mediation and 27 discuss settlement as provided under Court Rule 3. 1322(c)(7). Defendant also requires additional time 28 to schedule expert witnesses as provided under Court Rule 3.1332(c)(1). 1 EX PARTE APPLICATION REQUESTING ORDER TO CONTINUE TRIAL DATE; DECLARATION 0F NOTICE AND PROPOSED ORDER. 2. In support of this application, I can state, based upon personal knowledge: (a) Plaintiff filed the complaint in the above entitled action on August 14, 2020. A11 discovery has been completed and the case is set for trial on August 14, 2023. (b) Plaintiff‘s counsel has met and conferred with our office. Both parties have agreed to and signed a stipulation for 9O days as Parties in the case are working towards private mediation. A continuance will allow time for this issue to firm up. A copy of the signed stipulation has been included in the supporting Memorandum filed with this application. (c) Plaintiff s counsel is communicating with MediCal for document production relevant for evidentiary purposes and is waiting t0 complete this task. 10 3. Plaintiff’s Counsel conferred With our office on July 12, 2023 that this application would be 11 presented to this Court in Department $22 on an ex parte basis. Plaintiff‘s counsel informed 12 Defendant’s Counsel they would not oppose the application. 13 14 declare under penalty of perjury under the laws of the State of California that the foregoing I is true and 15 correct. 16 17 18 Date: July 13, 2023 WARRINER, GREyLEY LLP 20 21 22 Mhael Chuah, qu. - Declarant Attorneys for Defendants, 23 CARDENAS MARKETS LLC 24 25 26 27 28 2 EX PARTE APPLICATION REQUESTING ORDER TO CONTINUE TRIAL DATE; DECLARATION 0F NOTICE AND PROPOSED ORDER.