On March 18, 2019 a
Stipulation,Agreement
was filed
involving a dispute between
M.D.L.F.,
and
Arrowood, Cindy,
Does 1 Through 10, Inclusive,
Fisher, Diana,
Morongo Unified School District, A Government Entity,
for Personal Injury Non-Motor Vehicle Unlimited
in the District Court of San Bernardino County.
Preview
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SUPERIOR Ci OURT OF CALIFORNIA
MARTIN & MARTIN, LLP COUNTY O} F SAN BERNARDINO
Janet A. Ariza, Esq. (SBN 144629)
SAN BERNARDINO DISTRICT
jariza@martin-martin.com JUN 22 2021
Laura M. Fields, Esq. (SBN 132427)
lfields@martin-martin.com BY.
3530 Wilshire Blvd., Suite 670 FILING FEE EXEMPT
Los Angeles, CA 90010 TO GOVERNMENT CODE § 6103
Tel: (213) 388-4747
Fax: (213) 388-6655
Attorneys for Defendant MORONGO UNIFIED SCHOOL DISTRICT, CINDY
ARROWOOD AND DIANA FISHER
LAW OFFICES OF THEIDA SALAZAR
10 Theida Salazar, Esq. (SBN: 295547)
2140 North Hollywood Way, #7192
I
Burbank, CA 91510
12 Phone: (818) 433-7290
Facsimile: (818) 436-4009
13
14 SUPERIOR COURT OF THE STATE OF CALIFORNIA
15 FOR THE COUNTY OF SAN BERNARDINO
16
M.D.LF., a minor, by and through his Guardian CASE NO.: CIVDS 1908236
17 (Hon. Lynn Poncin, Dept. $28]
ad Litem, MELINDA FIELDS.,
18
Plaintiff,
19 JOINT STIPULATION AND
v.
ORDER TO CONTINUE
20 MORONGO UNIFIED SCHOOL DISTRICT, TRIAL AND ALL TRIAL RELATED
21 a governmental entity; CINDY ARROWOOD, DEADLINES
22 an individual, DIANA FISHER, an individual;
23 and DOES | through 25, inclusive, Complaint Filed: March 18, 2019
24 Defendants. Trial: November 15, 2021
25
26 IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiff M.D.LF.
27 and Defendants CINDY ARROWOOD and DIANA FISHER, by and through their respective
be continued
28 attorneys of record, that the trial of this case, currently set for November 15, 2021,
Page 1 of 4
AND ALL TRIAL RELATED DEADLINES
JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE TRIAL
1 to October 3, 2022, or a date convenient to the Court. The Parties respectfully request that the
2 || Court grant this continuance.
3 This Stipulation is based upon the following facts and circumstances, which the Parties
4 believe constitute good cause:
5
The COVID-19 pandemic has disrupted the Parties' handling of the case. The court
closures and other issues related to the pandemic, however, have caused significant
problems with counsels’ schedules, making the preparation for a trial in November
2021 essentially impossible. The effects of the COVID-19 pandemic on the
10 Court’s calendar, the availability of parties, witnesses, and counsel for the parties
11 in November 2021 is uncertain.
12 The Parties have engaged in diligent discovery, but have been unable to complete
13 discovery, including taking depositions.
14 The Parties have met and conferred about discovery, informal settlement, and
15 possible mediation, once Plaintiff's medical records have been received.
16 Defendants Arrowood and Fisher’s discovery has been delayed in that the Covid-
19 pandemic has severely impacted Defendants ability to procure Plaintiffs
17
18 medical records from the seventeen healthcare providers, identified to date. Most
19 providers are currently running two to three months behind on responding to
20 subpoenas due to the pandemic.
21 Defendants Arrowood and Fisher have not been able to take Plaintiff's deposition
22 and will not be able to do so until all medical records have been received.
23 Counsel for Plaintiff MDLF and Defendants Arrowood and Fisher have met and
24 conferred and agree that the case can best be handled efficiently and effectively if
25 the Court were to continue the trial to October 3, 2022. That date will work best
26 with the impacted schedules of trial counsel for the parties.
27 Trial previously has been continued in this matter due to the issues that impacted
28 the Court because of the Covid-19 pandemic.
Page 2 of 4
RELATED DEADLINES
(OINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE TRIAL AND ALL TRIAL
Document Filed Date
June 22, 2021
Case Filing Date
March 18, 2019
Category
Personal Injury Non-Motor Vehicle Unlimited
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= SUPERIOR Ci OURT OF CALIFORNIA MARTIN & MARTIN, LLP COUNTY O} F SAN BERNARDINO Janet A. Ariza, Esq. (SBN 144629) SAN BERNARDINO DISTRICT jariza@martin-martin.com JUN 22 2021 Laura M. Fields, Esq. (SBN 132427) lfields@martin-martin.com BY. 3530 Wilshire Blvd., Suite 670 FILING FEE EXEMPT Los Angeles, CA 90010 TO GOVERNMENT CODE § 6103 Tel: (213) 388-4747 Fax: (213) 388-6655 Attorneys for Defendant MORONGO UNIFIED SCHOOL DISTRICT, CINDY ARROWOOD AND DIANA FISHER LAW OFFICES OF THEIDA SALAZAR 10 Theida Salazar, Esq. (SBN: 295547) 2140 North Hollywood Way, #7192 I Burbank, CA 91510 12 Phone: (818) 433-7290 Facsimile: (818) 436-4009 13 14 SUPERIOR COURT OF THE STATE OF CALIFORNIA 15 FOR THE COUNTY OF SAN BERNARDINO 16 M.D.LF., a minor, by and through his Guardian CASE NO.: CIVDS 1908236 17 (Hon. Lynn Poncin, Dept. $28] ad Litem, MELINDA FIELDS., 18 Plaintiff, 19 JOINT STIPULATION AND v. ORDER TO CONTINUE 20 MORONGO UNIFIED SCHOOL DISTRICT, TRIAL AND ALL TRIAL RELATED 21 a governmental entity; CINDY ARROWOOD, DEADLINES 22 an individual, DIANA FISHER, an individual; 23 and DOES | through 25, inclusive, Complaint Filed: March 18, 2019 24 Defendants. Trial: November 15, 2021 25 26 IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiff M.D.LF. 27 and Defendants CINDY ARROWOOD and DIANA FISHER, by and through their respective be continued 28 attorneys of record, that the trial of this case, currently set for November 15, 2021, Page 1 of 4 AND ALL TRIAL RELATED DEADLINES JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE TRIAL 1 to October 3, 2022, or a date convenient to the Court. The Parties respectfully request that the 2 || Court grant this continuance. 3 This Stipulation is based upon the following facts and circumstances, which the Parties 4 believe constitute good cause: 5 The COVID-19 pandemic has disrupted the Parties' handling of the case. The court closures and other issues related to the pandemic, however, have caused significant problems with counsels’ schedules, making the preparation for a trial in November 2021 essentially impossible. The effects of the COVID-19 pandemic on the 10 Court’s calendar, the availability of parties, witnesses, and counsel for the parties 11 in November 2021 is uncertain. 12 The Parties have engaged in diligent discovery, but have been unable to complete 13 discovery, including taking depositions. 14 The Parties have met and conferred about discovery, informal settlement, and 15 possible mediation, once Plaintiff's medical records have been received. 16 Defendants Arrowood and Fisher’s discovery has been delayed in that the Covid- 19 pandemic has severely impacted Defendants ability to procure Plaintiffs 17 18 medical records from the seventeen healthcare providers, identified to date. Most 19 providers are currently running two to three months behind on responding to 20 subpoenas due to the pandemic. 21 Defendants Arrowood and Fisher have not been able to take Plaintiff's deposition 22 and will not be able to do so until all medical records have been received. 23 Counsel for Plaintiff MDLF and Defendants Arrowood and Fisher have met and 24 conferred and agree that the case can best be handled efficiently and effectively if 25 the Court were to continue the trial to October 3, 2022. That date will work best 26 with the impacted schedules of trial counsel for the parties. 27 Trial previously has been continued in this matter due to the issues that impacted 28 the Court because of the Covid-19 pandemic. Page 2 of 4 RELATED DEADLINES (OINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE TRIAL AND ALL TRIAL