On November 03, 2021 a
Stipulation,Agreement
was filed
involving a dispute between
Doe, John Vnr,
and
Brown, Eric Lynn,
Does 1-100,
Victor Valley Union High School District,
for Other PI/PD/WD Unlimited
in the District Court of San Bernardino County.
Preview
Ra 0nd F. Dolen SBN 130534 sweacholuLR'Tgprmmn
D LEN TUCKER TIERNEY & ABRAHAM SAN BERNARDNO DSTRICT
1710 Plum Lane, Suite A
Redlands, CA 92374 MAR 0 8‘ 2022
Ph: 951-683-6014
Fax: 95 1 -683-03 14
rdolen@redlands-law.com
\OOOVONUI-bIJJNt—n
Our File No: 12-303
Attorne s for Defendant,
VICTO VALLEY UNION HIGH SCHOOL DISTRICT
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
JOHN VNR DOE, an individual; CASE NO: CIVSB 2131418
Assigned Judge: Khymberli S. Apaloo
Plaintiff, Depanment: S-25
Complaint Filed: November 3, 2021
vs.
[Fee Exempt per Gov. Code §6103]
VICTOR VALLEY UNION HIGH
SCHOOL DISTRICT, a business entity of STIPULATION BETWEEN
form unknown; ERIC LYNN BROWN, an PLAINTIFF AND DEFENDANT
individual, and DOES 1 through 100 VICTOR VALLEY UNION HIGH
SCHOOL DISTRICT REGARDING
Defendants. PLAINTIFF’S PRAYER
TREBLE DAMAGES; D] [
NNNNNNNNNu—dp—‘t—tt—tt—r—tp—HHH
ORDER
OONGUI-hUJNh—‘OOOOQQUIhWNP—‘O
TO: THE HONORABLE COURT, ALL PARTIES AND THEIR COUNSEL
OF RECORD:
PLEASE TAKE NOTICE THAT Plaintiff John VNR Doe (“Plaintiff”) and
Defendant Victor Valley Union High School District (“District”), (Plaintiff and
Defendant are sometimes referred t0 as “Parties”), hereby stipulate, by and between their
counsel of record, to the following, and seek an Order of the Court thereon:
WHEREAS, 0n 0r about January 3 1, 2022, Defendant was served with Plaintiff’s
Complaint for Damages;
WHEREAS, prior to the filing of a potential Motion to Strike by District, the
Parties’ counsel met and conferred and agreed to this stipulation regarding certain
STIPULATION BETWEEN PLAINTIFF AND DEFENDANT VICTOR VALLEY UNION HIGH SCHOOL DISTRICT
REGARDING PLAINTIFF’S PRAYER FOR TREBLE DAMAGES; [PROPOSED] ORDER
allegations that will be withdrawn, without prejudice, that will moot Defendant’s motion
t0 strike.
WHEREAS, the concepts ofjudicial economy, conservation of resources, and
efficiency would be promoted by allowing the Parties to stipulate as set forth herein and
\OOONQUI-AUJN—n
the Court entering an Order on the stipulation in lieu of unnecessary law and motion
practice;
And, THEREFORE, the parties hereby stipulate through counsel of record t0 the
following, and seek a Court Order thereon;
1. Plaintiff agrees to withdraw, without prejudice, his prayer for treble damages.
2. By entering into this stipulation, Plaintiff is not giving up his right to seek to
amend his Complaint pursuant to California law. In the event that Plaintiff wishes to re-
assert the claims and/or remedies withdrawn herein, Plaintiff must bring a noticed motion
pursuant to California Code of Civil Procedure §473; California Rules ofCourt, Rule
3.1324; and, any other applicable local 0r departmental rules;
3. Plaintiffs entry into this stipulation shall not be deemed a waiver 0f
Plaintiff’ s right or ability to pursue the claims and/or remedies withdrawn herein in any
NNNNNNNNNr—IH—IHr—Ir—At—Ir—tb—It—d
other matters, including, but not limited t0, any matters that have been consolidated
WQONUI-PUJNt—‘OOOOQQUI-hWNp-xo
and/or
Dated: W
deemed
March
related to this action.
4,
,
2022
2022
W
MANLY, STEWART & FINALDI
. Mam
CRISTINA JINOLAN
Attorneys for Plaintiff
JOHN VNR DOE
Dated: March 4, 2022 DOLEN TUCKER TIERNEY & ABRAHAM
MK 03%
RAYMOND F. DOLEN
Attome s for Defendant,
VICTO VALLEY UNION HIGH SCHOOL
DISTRICT
-2-
STIPULATION BE W EEN PLAINTIFF
l AND DEFENDANT VICTOR VALLEY UNION HIGH SCHOOL DISTRICT
REGARDING PLATNTIFF‘S PRAYER FOR TREBLE DAMAGES; [PROPOSED] ORDER
Document Filed Date
March 08, 2022
Case Filing Date
November 03, 2021
Category
Other PI/PD/WD Unlimited
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Preview
Ra 0nd F. Dolen SBN 130534 sweacholuLR'Tgprmmn D LEN TUCKER TIERNEY & ABRAHAM SAN BERNARDNO DSTRICT 1710 Plum Lane, Suite A Redlands, CA 92374 MAR 0 8‘ 2022 Ph: 951-683-6014 Fax: 95 1 -683-03 14 rdolen@redlands-law.com \OOOVONUI-bIJJNt—n Our File No: 12-303 Attorne s for Defendant, VICTO VALLEY UNION HIGH SCHOOL DISTRICT SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO JOHN VNR DOE, an individual; CASE NO: CIVSB 2131418 Assigned Judge: Khymberli S. Apaloo Plaintiff, Depanment: S-25 Complaint Filed: November 3, 2021 vs. [Fee Exempt per Gov. Code §6103] VICTOR VALLEY UNION HIGH SCHOOL DISTRICT, a business entity of STIPULATION BETWEEN form unknown; ERIC LYNN BROWN, an PLAINTIFF AND DEFENDANT individual, and DOES 1 through 100 VICTOR VALLEY UNION HIGH SCHOOL DISTRICT REGARDING Defendants. PLAINTIFF’S PRAYER TREBLE DAMAGES; D] [ NNNNNNNNNu—dp—‘t—tt—tt—r—tp—HHH ORDER OONGUI-hUJNh—‘OOOOQQUIhWNP—‘O TO: THE HONORABLE COURT, ALL PARTIES AND THEIR COUNSEL OF RECORD: PLEASE TAKE NOTICE THAT Plaintiff John VNR Doe (“Plaintiff”) and Defendant Victor Valley Union High School District (“District”), (Plaintiff and Defendant are sometimes referred t0 as “Parties”), hereby stipulate, by and between their counsel of record, to the following, and seek an Order of the Court thereon: WHEREAS, 0n 0r about January 3 1, 2022, Defendant was served with Plaintiff’s Complaint for Damages; WHEREAS, prior to the filing of a potential Motion to Strike by District, the Parties’ counsel met and conferred and agreed to this stipulation regarding certain STIPULATION BETWEEN PLAINTIFF AND DEFENDANT VICTOR VALLEY UNION HIGH SCHOOL DISTRICT REGARDING PLAINTIFF’S PRAYER FOR TREBLE DAMAGES; [PROPOSED] ORDER allegations that will be withdrawn, without prejudice, that will moot Defendant’s motion t0 strike. WHEREAS, the concepts ofjudicial economy, conservation of resources, and efficiency would be promoted by allowing the Parties to stipulate as set forth herein and \OOONQUI-AUJN—n the Court entering an Order on the stipulation in lieu of unnecessary law and motion practice; And, THEREFORE, the parties hereby stipulate through counsel of record t0 the following, and seek a Court Order thereon; 1. Plaintiff agrees to withdraw, without prejudice, his prayer for treble damages. 2. By entering into this stipulation, Plaintiff is not giving up his right to seek to amend his Complaint pursuant to California law. In the event that Plaintiff wishes to re- assert the claims and/or remedies withdrawn herein, Plaintiff must bring a noticed motion pursuant to California Code of Civil Procedure §473; California Rules ofCourt, Rule 3.1324; and, any other applicable local 0r departmental rules; 3. Plaintiffs entry into this stipulation shall not be deemed a waiver 0f Plaintiff’ s right or ability to pursue the claims and/or remedies withdrawn herein in any NNNNNNNNNr—IH—IHr—Ir—At—Ir—tb—It—d other matters, including, but not limited t0, any matters that have been consolidated WQONUI-PUJNt—‘OOOOQQUI-hWNp-xo and/or Dated: W deemed March related to this action. 4, , 2022 2022 W MANLY, STEWART & FINALDI . Mam CRISTINA JINOLAN Attorneys for Plaintiff JOHN VNR DOE Dated: March 4, 2022 DOLEN TUCKER TIERNEY & ABRAHAM MK 03% RAYMOND F. DOLEN Attome s for Defendant, VICTO VALLEY UNION HIGH SCHOOL DISTRICT -2- STIPULATION BE W EEN PLAINTIFF l AND DEFENDANT VICTOR VALLEY UNION HIGH SCHOOL DISTRICT REGARDING PLATNTIFF‘S PRAYER FOR TREBLE DAMAGES; [PROPOSED] ORDER