On November 23, 2022 a
Party Discovery
was filed
involving a dispute between
Delgadillo Jr., Francisco,
and
Baez, Maria,
Baez, Nancy,
Does 1 To 25,
Scott Jr, Shannon,
for Auto PI/PD/WD Unlimited
in the District Court of San Bernardino County.
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ANDREW ZEYTUNTSYAN, SBN 246616 F 5 L E D
ANTHONY M. CRISCI, SBN 327418 sgggffigg gougN gggfikggmm
LAW OFFICES 0F ANDREW ZEYTUNTSYAN, P.c. w agzwfimmmeme:-
1306 W. Magnolia Blvd ‘ r '
5E! 1
Burbank, CA 91506
r3 202.3
Tel: (323) 882-6500
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Fax: (800) 506-7176 k"
Email: Anthony@a2zlegal.com
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Attorneys for Plaintiff,
FRANCISCO DELGADILLO Ir.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
10
CASE NO.: CIVSB 2225815
11
FRANCISCO DELGADILLO IR,
PLAINTIFF FRANCISCO
12 Plaintiff, DELGADILLO JRJS STATUTORY
OFFER To COMPROMISE To
13
v. DEFENDANT NANCY BAEz To
14
c.c.P § 99s;
NANCY BAEZ; MARIA BAEZ;
15
SHANNON SCOTT JR; and DOES 1 to NOTICE OF ACCEPTANCE
16 25, Inclusive,
17 Defendants.
18
19
20
TO DEFENDANT AND THEIR ATTORNEYS OF RECORD:
21
PLEASE TAKE NOTICE that pursuant to California Code 0f Civil Procedure § 998,
22
Plaintiff FRANCISCO DELGADILLO JR. (”Plaintiff"), offers to settle his claim represented
23 THOUSAND
to Defendants NANCY BAEZ (“Defendant"), for the amount of FIFTEEN
24
DOLLARS ($15,000), with each side t0 bear their own costs. Said sum shall include
25
attorneys’ fees. Should Defendant accept Plaintiff’s offer, Plaintiff agrees to dismiss and
26
release any and all claims he may have against all defendants and dismiss his complaint with
27
prejudice.
28
1
PLAINTIFF FRANCISCO DELGADILLO R.’S STATUTORY
OFFER TO COMPROMISE, NOTICE O ACCEPTANCE
‘ . .
.
Please note that if you decline this offer of compromise and Plaintiff is successful in
recovering this amount or more, you shall be liable for a reasonable sum to cover all costs
associated with expert witnesses hired by Plaintiff in preparation for trial 0f the claim, in
addition to Plaintiff’s costs and accrued interest from date of expiration or decline 0f this
offer.
This offer must be accepted in writing prior to commencement 0f trial or within thirty
(30) days after it is made, whichever occurs first, otherwise it is withdrawn. This offer may
be accepted and signed by Defendant 0r the attorneys for Defendant. If accepted, it shall be
filed with the Superior Court with proof of the concurrently served Notice of Acceptance.
10
You are required to promptly communicate all amounts, terms and conditions of
11
this written offer to your client. See California Business & Professions Code § 6103.5(a).
12
13 DATED: August 15, 2023 LAW OFFICES OF
ANDREW ZEYTUNTSYAN, PC
14
15
16 ANTHONY M. CRISCI
Attorneys for Plaintiff
17
FRANCISCO DELGADILLO
18
19
20
21
22
23
24
25
26
27
28
2
PLAINTIFF FRANCISCO DELGADILLO R.’S STATUTORY
OFFER TO COMPROMISE, NOTICE O ACCEPTANCE
Document Filed Date
September 18, 2023
Case Filing Date
November 23, 2022
Category
Auto PI/PD/WD Unlimited
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ANDREW ZEYTUNTSYAN, SBN 246616 F 5 L E D ANTHONY M. CRISCI, SBN 327418 sgggffigg gougN gggfikggmm LAW OFFICES 0F ANDREW ZEYTUNTSYAN, P.c. w agzwfimmmeme:- 1306 W. Magnolia Blvd ‘ r ' 5E! 1 Burbank, CA 91506 r3 202.3 Tel: (323) 882-6500 ‘ Fax: (800) 506-7176 k" Email: Anthony@a2zlegal.com _ 9V: “4M «Svff/ ”/29? " erg": \fiimnuava, Ueputi} ” “M“ Attorneys for Plaintiff, FRANCISCO DELGADILLO Ir. SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO 10 CASE NO.: CIVSB 2225815 11 FRANCISCO DELGADILLO IR, PLAINTIFF FRANCISCO 12 Plaintiff, DELGADILLO JRJS STATUTORY OFFER To COMPROMISE To 13 v. DEFENDANT NANCY BAEz To 14 c.c.P § 99s; NANCY BAEZ; MARIA BAEZ; 15 SHANNON SCOTT JR; and DOES 1 to NOTICE OF ACCEPTANCE 16 25, Inclusive, 17 Defendants. 18 19 20 TO DEFENDANT AND THEIR ATTORNEYS OF RECORD: 21 PLEASE TAKE NOTICE that pursuant to California Code 0f Civil Procedure § 998, 22 Plaintiff FRANCISCO DELGADILLO JR. (”Plaintiff"), offers to settle his claim represented 23 THOUSAND to Defendants NANCY BAEZ (“Defendant"), for the amount of FIFTEEN 24 DOLLARS ($15,000), with each side t0 bear their own costs. Said sum shall include 25 attorneys’ fees. Should Defendant accept Plaintiff’s offer, Plaintiff agrees to dismiss and 26 release any and all claims he may have against all defendants and dismiss his complaint with 27 prejudice. 28 1 PLAINTIFF FRANCISCO DELGADILLO R.’S STATUTORY OFFER TO COMPROMISE, NOTICE O ACCEPTANCE ‘ . . . Please note that if you decline this offer of compromise and Plaintiff is successful in recovering this amount or more, you shall be liable for a reasonable sum to cover all costs associated with expert witnesses hired by Plaintiff in preparation for trial 0f the claim, in addition to Plaintiff’s costs and accrued interest from date of expiration or decline 0f this offer. This offer must be accepted in writing prior to commencement 0f trial or within thirty (30) days after it is made, whichever occurs first, otherwise it is withdrawn. This offer may be accepted and signed by Defendant 0r the attorneys for Defendant. If accepted, it shall be filed with the Superior Court with proof of the concurrently served Notice of Acceptance. 10 You are required to promptly communicate all amounts, terms and conditions of 11 this written offer to your client. See California Business & Professions Code § 6103.5(a). 12 13 DATED: August 15, 2023 LAW OFFICES OF ANDREW ZEYTUNTSYAN, PC 14 15 16 ANTHONY M. CRISCI Attorneys for Plaintiff 17 FRANCISCO DELGADILLO 18 19 20 21 22 23 24 25 26 27 28 2 PLAINTIFF FRANCISCO DELGADILLO R.’S STATUTORY OFFER TO COMPROMISE, NOTICE O ACCEPTANCE