Preview
RICHARD E. QUINTILONE, 11 (SBN 200995) swam; afifli WW,»
JEFFREY T. GREEN (SBN 330065) COUNTY 06-" a ”59.5wl5‘“
‘--
KYLE J. GALLEGO (PL—s 1 3245) - i
QUINTILONE & ASSOCIATES
22974 EL TORO ROAD, SUITE 100
LAKE FOREST, CA 92630 L4,- w”
TELEPHONE: (949) 458-9675
m {igfxflufiifwa/w-
_
fl ‘
URL":
,1?" p
?:."."‘Kf."§?2= C&WLS
FACSIMILE: (949) 458_9679
p
'y
\DOOQONUIAUJNu—A
EMAIL: REQ@QUINTLAW.COM; JTG@QUINTLAW.COM; KJG@QUINTLAW.COM
Attorneys for Defendants, LABOR SOLUTIONS — ONTARIO;
SIMPLIFIED STAFFING
SIMPLIFIED STAFFING LABOR SOLUTIONS, LLC; SIMPLIFIED STAFFING LABOR
SOLUTIONS, INC.
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
ABRAHAM MURRAY, CASE NO.: CIVDSl907075
Plaintiff, Assi ned for All Pur oses to:
Hon. Wilfred J. Schneider
V. Dept: S32
SINIPLIFIED STAFFING LABOR SOLUTIONS NOTICE 0F EX PARTE APPLICATION
— ONTARIO; SIMPLIFIED STAFFING LABOR
SOLUTIONS, LLC; and DOES 1 t0 20, AND EX PARTE APPLICATION FOR
ORDER CONTINUING TRIAL AND RE-
Defendants. OPENING DISCOVERY
[Filed concurrently with Declaration 0f Kyle
J. Gallego, Esq.; Declaration 0f Ash Wahi;
NNNNNNNNNHHu—‘HHHHHHH
[Proposed] Order]
OONQM¥UJNHO®OOVOUIhWNHO
Date: August 31, 2022
Time: 8:30 a.m.
Dept.: S32
Complaint Filed: March 6, 2019
FAC Filed: January 15, 2020
Trial date: September 19, 2022
-1-
DEF EX PARTE APPLICATION FOR ORDER CONTINUING TRIAL & RELATED DATES; RE-OPEN DISCOVERY
\x \z'
TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that pursuant to California Rules of Court, Rule 3.1332 and the
applicable Local Rules, Defendants, SIMPLIFIED STAFFING LABOR SOLUTIONS — ONTARIO;
SIMPLIFIED STAFFING LABOR SOLUTIONS, LLC; SIMPLIFIED STAFFING LABOR
\OOONONMhUJNt—l
SOLUTIONS, INC. (“Defendants”) hereby Will apply t0 the Court Ex Parte for an Order to (1)
Continue Trial to no sooner than December 5, 2022; and (2) allow discovery to be re-opened.
Defendant’s prior counsel has not served discovery and left the defendant Virtually “naked” for
trial. This motion will be made pursuant t0 California Rules of Court, Rule 3.1332, on the following
grounds: (1) the proximity ofthe trial date; (2) whether there was any previous continuance, extension
oftime, or delay 0ftrial due to any party; (3) the length ofthe continuance requested; (4) the availability
of alternative means to address the problem that gave rise to the motion or application for a
continuance; (5) the prejudice that parties or witnesses will suffer as a result of the continuance;(7) the
court's calendar and the impact of granting a continuance 0n other pending trials; (8) whether trial
counsel is engaged in another trial; (9) whether all parties have stipulated t0 a continuance; and (10)
whether the interests of justice are best served by a continuance, by the trial of the matter, or by
imposing conditions on the continuance.
NNNNNNNNNb—db—Ay—‘y—AHHp—Ar—nu—nr—a
This Ex Parte Application will be based upon this Notice, the attached Memorandum of Points
and Authorities, the attached Declaration of Kyle J. Gallego, Esq., the attached declaration of Ash
Wahi, the Court’s file herein, on the pleadings, papers, records, and files in this action, and 0n such
OOQGM-PWNHO\OWQO\UI&WNHO
oral or documentary evidence as may be presented at the hearing of the motion.
Dated: August 30, 2022 QUINTILONE & ASSOCIATES
HARD E. QUINTILONE II,
JEFFREY T. GREEN,
KYLE J. GALLEGO
Attorneys for Defendants, SIMPLIFIED
STAFFING LABOR SOLUTIONS — ONTARIO;
SIMPLIFIED STAFFING LABOR
SOLUTIONS, LLC; SIMPLIFIED STAFFING
LABOR SOLUTIONS, INC.
4-
DEF EX PARTE APPLICATION FOR ORDER CONTINUING TRIAL & RELATED DATES; RE—OPEN DISCOVERY
Preview
RICHARD E. QUINTILONE, 11 (SBN 200995) swam; afifli WW,» JEFFREY T. GREEN (SBN 330065) COUNTY 06-" a ”59.5wl5‘“ ‘-- KYLE J. GALLEGO (PL—s 1 3245) - i QUINTILONE & ASSOCIATES 22974 EL TORO ROAD, SUITE 100 LAKE FOREST, CA 92630 L4,- w” TELEPHONE: (949) 458-9675 m {igfxflufiifwa/w- _ fl ‘ URL": ,1?" p ?:."."‘Kf."§?2= C&WLS FACSIMILE: (949) 458_9679 p 'y \DOOQONUIAUJNu—A EMAIL: REQ@QUINTLAW.COM; JTG@QUINTLAW.COM; KJG@QUINTLAW.COM Attorneys for Defendants, LABOR SOLUTIONS — ONTARIO; SIMPLIFIED STAFFING SIMPLIFIED STAFFING LABOR SOLUTIONS, LLC; SIMPLIFIED STAFFING LABOR SOLUTIONS, INC. SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO ABRAHAM MURRAY, CASE NO.: CIVDSl907075 Plaintiff, Assi ned for All Pur oses to: Hon. Wilfred J. Schneider V. Dept: S32 SINIPLIFIED STAFFING LABOR SOLUTIONS NOTICE 0F EX PARTE APPLICATION — ONTARIO; SIMPLIFIED STAFFING LABOR SOLUTIONS, LLC; and DOES 1 t0 20, AND EX PARTE APPLICATION FOR ORDER CONTINUING TRIAL AND RE- Defendants. OPENING DISCOVERY [Filed concurrently with Declaration 0f Kyle J. Gallego, Esq.; Declaration 0f Ash Wahi; NNNNNNNNNHHu—‘HHHHHHH [Proposed] Order] OONQM¥UJNHO®OOVOUIhWNHO Date: August 31, 2022 Time: 8:30 a.m. Dept.: S32 Complaint Filed: March 6, 2019 FAC Filed: January 15, 2020 Trial date: September 19, 2022 -1- DEF EX PARTE APPLICATION FOR ORDER CONTINUING TRIAL & RELATED DATES; RE-OPEN DISCOVERY \x \z' TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that pursuant to California Rules of Court, Rule 3.1332 and the applicable Local Rules, Defendants, SIMPLIFIED STAFFING LABOR SOLUTIONS — ONTARIO; SIMPLIFIED STAFFING LABOR SOLUTIONS, LLC; SIMPLIFIED STAFFING LABOR \OOONONMhUJNt—l SOLUTIONS, INC. (“Defendants”) hereby Will apply t0 the Court Ex Parte for an Order to (1) Continue Trial to no sooner than December 5, 2022; and (2) allow discovery to be re-opened. Defendant’s prior counsel has not served discovery and left the defendant Virtually “naked” for trial. This motion will be made pursuant t0 California Rules of Court, Rule 3.1332, on the following grounds: (1) the proximity ofthe trial date; (2) whether there was any previous continuance, extension oftime, or delay 0ftrial due to any party; (3) the length ofthe continuance requested; (4) the availability of alternative means to address the problem that gave rise to the motion or application for a continuance; (5) the prejudice that parties or witnesses will suffer as a result of the continuance;(7) the court's calendar and the impact of granting a continuance 0n other pending trials; (8) whether trial counsel is engaged in another trial; (9) whether all parties have stipulated t0 a continuance; and (10) whether the interests of justice are best served by a continuance, by the trial of the matter, or by imposing conditions on the continuance. NNNNNNNNNb—db—Ay—‘y—AHHp—Ar—nu—nr—a This Ex Parte Application will be based upon this Notice, the attached Memorandum of Points and Authorities, the attached Declaration of Kyle J. Gallego, Esq., the attached declaration of Ash Wahi, the Court’s file herein, on the pleadings, papers, records, and files in this action, and 0n such OOQGM-PWNHO\OWQO\UI&WNHO oral or documentary evidence as may be presented at the hearing of the motion. Dated: August 30, 2022 QUINTILONE & ASSOCIATES HARD E. QUINTILONE II, JEFFREY T. GREEN, KYLE J. GALLEGO Attorneys for Defendants, SIMPLIFIED STAFFING LABOR SOLUTIONS — ONTARIO; SIMPLIFIED STAFFING LABOR SOLUTIONS, LLC; SIMPLIFIED STAFFING LABOR SOLUTIONS, INC. 4- DEF EX PARTE APPLICATION FOR ORDER CONTINUING TRIAL & RELATED DATES; RE—OPEN DISCOVERY