On September 28, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Aquino, Erlinda O,
and
California Board Of Registered Nursing,
Trujillo, Jessica,
for Writ of Mandate Unlimited
in the District Court of San Bernardino County.
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ERLINDA O. AQUINO
1792 Big Oak Avenue Fl
D)
Chino Hills, CA 91 709 PEIEFEODT
COUNTY OEFRSAN BE NARDINO
Tel- N0. (909) 4653853 SAN BERNARDINO DISTRICT
FEB 1 5 2023
PETITIONER In Pro Per
YCU‘xUH 4020C: n.
'
EPUTY
SUPERIOR COURT FOR THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO—WRIT REVIEW
ERLINDA O. AQUINO, Case Number: CIVSB2125400
Petitioner,
10 PET l I lONER’S REQUES T F 0R
VS EXTENSION OF TIME T0 AMEND ITS;
ll MOTIONS FOR RECONSIDERATION
BOARD OF REGISTERED NURSING, AND VACATE THE PAST DUE
ET.AL., PROPOSED JUDGMENT PURSUANT TO
CRC 3. 1590 AND RESPONSE TO
13
CURRENT COURT’S PERTINENT OSC;
Respondent. MEMORANDUM OF POINTS AND
vvv’v‘vvvv‘mvvvvvvvvvvv
AUTHORITES AND DECLARATION IN
14
SUPPORT THEREOF.
Date: February 22, 2023
l6 Time: 8:30 am
Dept: $17
l7 Judge: Hon. Joseph T. Ortiz
l8
vv‘
l9
COMES NOW PETITIONER ERLINDA O‘ AQUINO AQUINO] who hereby [ Request 60
Days Exclusively Separate Extension /C0ntinuance To Be Able t0 :
1‘ Amend Petitioner’s Motion for Reconsideration rescheduling it to April 28, 2023 .j
2. Amend Petitioner’s Motion to Vacate Proposed Judgment rescheduling it to May 2023
5,
Said Proposed Judgment was recently inexplicably Accelerated to an
[
Executed (ie.
Signed) and Filed (ie. Entry) Status Without Requisite Notice Necessitating Petitioner to
thereby Amend said Motions ; and
REQUEST FOR EXTENSION 015 TLME FOR MOTLONS FOR RECONSlDERATiON, MOTLON To
VACATE, AND RESPONSE TO SUBJECT OSC ORDER.
3. Officially Respond to an apparent/ purported OSC [Order to Show] originally set for
h.)
2/22/2023 be rescheduled to April 2], 2023 Unless the court
considers the Filing 0f these
Dual Motions as Petitioner’s IMPLIED Response to the OSC Issue [Why the Proposed
Judgment should not have been executed (ie. Signed) and then Filed ( ie. Entry) without
affording Petitioner any Opportunity to Plead in Opposition
to finalize what Petitioner
deemed t0 be a wrongfully past due Suspicious Transition of a prior
Tentative Ruling to
a Proposed Judgment]. Alternatively, however, Petitioner’s
filing 0f the Dual Motions is
tantamount to an Implied Response to the OSC which essentially MOOTS the need for an
OSC. Additionally, the court’s wrongful execution and finalization
ofthe Subject
lO
Judgment without giving Petitioner the Opponunity to rebut the controversial procedural
ll and substantantive Issues contained in this Judgment philosophically contradicts the
principle behind the OSC process where the court should have first waited for a
responsive rebuttal from Petitioner before its finalization of the judgment rendering the
OSC moot and unnecessarily inutile.
MEMORANDUM OF POINTS AND AUTHORITIES
INTRODUCTION
While awaiting a suspicious transition of a pn'or court’s Tentative Ruling into a
Proposed
Judgment which was suddenly mysteriously executed [signed
by anotherjudge] and hurriedly
finalized despite exceeding the 50 days time limitations prescribed
under CRC 3. IASFgfégdging
claimed atrocities behind an egregiously biased atypical unilateral
Judgment mimicking the
Respondent’s Opposition brief, Petitioner hereby invokes her due process right to amend her
most recent Motions for Recon sideration and Vacate the Resultant Judgm
ent by filing this
Requests for Continuance to allow her the Opportunity t0 Amend her dual Motions and Produce
a Response t0 this new court’s OSC pertaining to this controversial final judgment. Furthermore,
Respondent DAG filed the Proposed Judgment on 1 1/29/2022 in violation of CRC 3. 1590 (h)
Page
REQUEST FOR EXTENSION OF TIME FOR MOTlONS FOR RECONSIDERATLON,
MOTION TO
VACATE, AND RESPONSE TO SUBJECT OSC ORDER.
Document Filed Date
February 15, 2023
Case Filing Date
September 28, 2021
Category
Writ of Mandate Unlimited
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ERLINDA O. AQUINO 1792 Big Oak Avenue Fl D) Chino Hills, CA 91 709 PEIEFEODT COUNTY OEFRSAN BE NARDINO Tel- N0. (909) 4653853 SAN BERNARDINO DISTRICT FEB 1 5 2023 PETITIONER In Pro Per YCU‘xUH 4020C: n. ' EPUTY SUPERIOR COURT FOR THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO—WRIT REVIEW ERLINDA O. AQUINO, Case Number: CIVSB2125400 Petitioner, 10 PET l I lONER’S REQUES T F 0R VS EXTENSION OF TIME T0 AMEND ITS; ll MOTIONS FOR RECONSIDERATION BOARD OF REGISTERED NURSING, AND VACATE THE PAST DUE ET.AL., PROPOSED JUDGMENT PURSUANT TO CRC 3. 1590 AND RESPONSE TO 13 CURRENT COURT’S PERTINENT OSC; Respondent. MEMORANDUM OF POINTS AND vvv’v‘vvvv‘mvvvvvvvvvvv AUTHORITES AND DECLARATION IN 14 SUPPORT THEREOF. Date: February 22, 2023 l6 Time: 8:30 am Dept: $17 l7 Judge: Hon. Joseph T. Ortiz l8 vv‘ l9 COMES NOW PETITIONER ERLINDA O‘ AQUINO AQUINO] who hereby [ Request 60 Days Exclusively Separate Extension /C0ntinuance To Be Able t0 : 1‘ Amend Petitioner’s Motion for Reconsideration rescheduling it to April 28, 2023 .j 2. Amend Petitioner’s Motion to Vacate Proposed Judgment rescheduling it to May 2023 5, Said Proposed Judgment was recently inexplicably Accelerated to an [ Executed (ie. Signed) and Filed (ie. Entry) Status Without Requisite Notice Necessitating Petitioner to thereby Amend said Motions ; and REQUEST FOR EXTENSION 015 TLME FOR MOTLONS FOR RECONSlDERATiON, MOTLON To VACATE, AND RESPONSE TO SUBJECT OSC ORDER. 3. Officially Respond to an apparent/ purported OSC [Order to Show] originally set for h.) 2/22/2023 be rescheduled to April 2], 2023 Unless the court considers the Filing 0f these Dual Motions as Petitioner’s IMPLIED Response to the OSC Issue [Why the Proposed Judgment should not have been executed (ie. Signed) and then Filed ( ie. Entry) without affording Petitioner any Opportunity to Plead in Opposition to finalize what Petitioner deemed t0 be a wrongfully past due Suspicious Transition of a prior Tentative Ruling to a Proposed Judgment]. Alternatively, however, Petitioner’s filing 0f the Dual Motions is tantamount to an Implied Response to the OSC which essentially MOOTS the need for an OSC. Additionally, the court’s wrongful execution and finalization ofthe Subject lO Judgment without giving Petitioner the Opponunity to rebut the controversial procedural ll and substantantive Issues contained in this Judgment philosophically contradicts the principle behind the OSC process where the court should have first waited for a responsive rebuttal from Petitioner before its finalization of the judgment rendering the OSC moot and unnecessarily inutile. MEMORANDUM OF POINTS AND AUTHORITIES INTRODUCTION While awaiting a suspicious transition of a pn'or court’s Tentative Ruling into a Proposed Judgment which was suddenly mysteriously executed [signed by anotherjudge] and hurriedly finalized despite exceeding the 50 days time limitations prescribed under CRC 3. IASFgfégdging claimed atrocities behind an egregiously biased atypical unilateral Judgment mimicking the Respondent’s Opposition brief, Petitioner hereby invokes her due process right to amend her most recent Motions for Recon sideration and Vacate the Resultant Judgm ent by filing this Requests for Continuance to allow her the Opportunity t0 Amend her dual Motions and Produce a Response t0 this new court’s OSC pertaining to this controversial final judgment. Furthermore, Respondent DAG filed the Proposed Judgment on 1 1/29/2022 in violation of CRC 3. 1590 (h) Page REQUEST FOR EXTENSION OF TIME FOR MOTlONS FOR RECONSIDERATLON, MOTION TO VACATE, AND RESPONSE TO SUBJECT OSC ORDER.