On August 10, 2021 a
Stipulation,Agreement
was filed
involving a dispute between
Rivera, Fabian,
and
Does 1-100,
Metro Rf Services, Inc.,
for Complex Civil Unlimited
in the District Court of San Bernardino County.
Preview
xv
Brandon R. McKelvey (SBN 217002)
E-mail: brandon@medinamckelvey.com
Timothy B. Nelson (SBN 235279)
E-mail: tim@medinamckelvey.com
MEDINA McKELVEY LLP ax
LEED
SUPERIOR?)CL UJRT C
925 Highland Pointe Drive, Suite 300 FLLAUFORNIA
-E)
COUE QTY ”)F S [‘V DERNARDINO
Roseville, California 95678 SAN BEH :“-'.
“(.31 RICT
.
.
A Telephone: (9 1 6) 960-221 1
.
Facsimile: (9 1 6) 742—5488 AUG]: 2022
NOV:
Attorneys for Defendant METRO RF BY__
v
w~~:.... nnnn
~R £2 “Ly“;
SERVICES, INC. EAL«.L ‘ {35—}?
\AIVL» 7_ JErjug-Y
|
‘.
Edwin Aiwazian (SBN 232943)
Email: edwin@calljustice.com
Charles T. Sweeny (SBN 325 167)
Email: charles@calljustice.com
10
Hagit Goltzer (SBN 324276)
Email: hagit@calljustice.com
11 LAWYERSfor JUSTICE, PC
410 West Arden Avenue, Suite 203
12 Glendale, Califomia 9 1 203
Telephone: (818) 265-1020
13
Facsimile: (818) 265—1021
14
Attorneys for Plaintiff FABIAN RIVERA
15
16 SUPERIOR COURT OF THE STATE OF CALIFORNIA
17 FOR THE COUNTY OF SAN BERNARDINO
18 Case No. CIVSB2123539
19 FABIAN RIVERA, individually, and on behalf Honorable John M Tomberlin
0f other aggrieved employees pursuant to the Department S33
20 California Private Attorneys General Act;
21
22
V.
Plaintiff,
[W]
JOINT STIPULATION AND
ORDER TO
CONTINUE TRIAL SETTING
CONFERENCE
METRO RF SERVICES, INC., a California
23 corporation; and DOES 1 through 100 inclusive, Hearing Date: August 23, 2022
Hearing Time: 8:30 a.m.
24 Defendants. Location: Department S33
25 Action Filed: August 10, 2021
Trial Date: Not Yet Assigned
26
27
28
-1-
M
MED‘NA MCKELVEY JOINT STIPULATION AND [FWD] ORDER TO CONTINUE TRIAL SETTING CONFERENCE
Plaintiff FABIAN RIVERA (“Plaintiff’) and defendant METRO RF SERVICES, INC.
(“Defendant”) (collectively, the “Parties”), by and through their counsel, hereby stipulate as
follows:
WHEREAS, 0n August 10, 2021, Plaintiff initiated this action by filing his Complaint for
Enforcement Under the Private Attorneys General Act, California Labor Code § 2698, ct seq., with
the above-entitled Court;
WHEREAS, the Court set a trial setting conference scheduled for August 23, 2022 at 8:30
a.m. in Department S33;
WHEREAS, the Parties attended private mediation with the Honorable Patrick Walsh (Ret.)
10 on June 16, 2022. Though the Parties were not able to come to a resolution in this matter during
11 mediation, the parties are continuing to discuss resolution with the assistance of the mediator;
12 WHEREAS, the Parties have met and conferred on how best to streamline the case to save
13 Court and Parties resources and are still exploring the possibility of early resolution t0 achieve that
14 end. Early resolution would thereby obviate the need to engage in further pleading practice, the
15 setting of trial dates, or the exchanging of discovery.
16 WHEREAS, in order to afford the Parties time to further engage in settlement discussions,
17 and in order to preserve the Court’s time and resources, the Parties stipulate to a continuance of the
18 Trial Setting Conference.
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M
MEDINA MCKELVEY ‘~‘-"
JOINT STIPULATION AND [W] ORDER TO CONTINUE TRIAL SETTING CONFERENCE
Document Filed Date
August 11, 2022
Case Filing Date
August 10, 2021
Category
Complex Civil Unlimited
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xv Brandon R. McKelvey (SBN 217002) E-mail: brandon@medinamckelvey.com Timothy B. Nelson (SBN 235279) E-mail: tim@medinamckelvey.com MEDINA McKELVEY LLP ax LEED SUPERIOR?)CL UJRT C 925 Highland Pointe Drive, Suite 300 FLLAUFORNIA -E) COUE QTY ”)F S [‘V DERNARDINO Roseville, California 95678 SAN BEH :“-'. “(.31 RICT . . A Telephone: (9 1 6) 960-221 1 . Facsimile: (9 1 6) 742—5488 AUG]: 2022 NOV: Attorneys for Defendant METRO RF BY__ v w~~:.... nnnn ~R £2 “Ly“; SERVICES, INC. EAL«.L ‘ {35—}? \AIVL» 7_ JErjug-Y | ‘. Edwin Aiwazian (SBN 232943) Email: edwin@calljustice.com Charles T. Sweeny (SBN 325 167) Email: charles@calljustice.com 10 Hagit Goltzer (SBN 324276) Email: hagit@calljustice.com 11 LAWYERSfor JUSTICE, PC 410 West Arden Avenue, Suite 203 12 Glendale, Califomia 9 1 203 Telephone: (818) 265-1020 13 Facsimile: (818) 265—1021 14 Attorneys for Plaintiff FABIAN RIVERA 15 16 SUPERIOR COURT OF THE STATE OF CALIFORNIA 17 FOR THE COUNTY OF SAN BERNARDINO 18 Case No. CIVSB2123539 19 FABIAN RIVERA, individually, and on behalf Honorable John M Tomberlin 0f other aggrieved employees pursuant to the Department S33 20 California Private Attorneys General Act; 21 22 V. Plaintiff, [W] JOINT STIPULATION AND ORDER TO CONTINUE TRIAL SETTING CONFERENCE METRO RF SERVICES, INC., a California 23 corporation; and DOES 1 through 100 inclusive, Hearing Date: August 23, 2022 Hearing Time: 8:30 a.m. 24 Defendants. Location: Department S33 25 Action Filed: August 10, 2021 Trial Date: Not Yet Assigned 26 27 28 -1- M MED‘NA MCKELVEY JOINT STIPULATION AND [FWD] ORDER TO CONTINUE TRIAL SETTING CONFERENCE Plaintiff FABIAN RIVERA (“Plaintiff’) and defendant METRO RF SERVICES, INC. (“Defendant”) (collectively, the “Parties”), by and through their counsel, hereby stipulate as follows: WHEREAS, 0n August 10, 2021, Plaintiff initiated this action by filing his Complaint for Enforcement Under the Private Attorneys General Act, California Labor Code § 2698, ct seq., with the above-entitled Court; WHEREAS, the Court set a trial setting conference scheduled for August 23, 2022 at 8:30 a.m. in Department S33; WHEREAS, the Parties attended private mediation with the Honorable Patrick Walsh (Ret.) 10 on June 16, 2022. Though the Parties were not able to come to a resolution in this matter during 11 mediation, the parties are continuing to discuss resolution with the assistance of the mediator; 12 WHEREAS, the Parties have met and conferred on how best to streamline the case to save 13 Court and Parties resources and are still exploring the possibility of early resolution t0 achieve that 14 end. Early resolution would thereby obviate the need to engage in further pleading practice, the 15 setting of trial dates, or the exchanging of discovery. 16 WHEREAS, in order to afford the Parties time to further engage in settlement discussions, 17 and in order to preserve the Court’s time and resources, the Parties stipulate to a continuance of the 18 Trial Setting Conference. 19 /// 20 /// 21 /// 22 /// /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 -2- M MEDINA MCKELVEY ‘~‘-" JOINT STIPULATION AND [W] ORDER TO CONTINUE TRIAL SETTING CONFERENCE