On March 06, 2019 a
Stipulation,Agreement
was filed
involving a dispute between
Murray, Abraham,
and
Simplified Labor Staffing Solutions, Inc.,
Simplified Staffing Labor Solutions,Llc,
Simplified Staffing Labor Solutions-Ontario,
for Wrongful Termination
in the District Court of San Bernardino County.
Preview
Sandra H. Castro, Esq. SBN#207475
1
Fataleg}?l'CCEaSSt8’
Esq' SBN#312495
.A r’ ‘
F SANDRA H. CASTRO, INC. SUPERIORchulfiTaQALIFORNA "
2 1111321 Blvd, Ste. 265 C??:?EYESSASRW»?§3TSAT%%¥O
$220 131%?
n arlo
3 Telephone No: (909)989-2700 JAN 1 2 2022
4
Facsmgile N0: (909)989-2733
castro a lawservicesonline.com
kathleen@lawservicesonline.com
BY W’Mz?‘ ,
\
ANNE PERRY EPUTY
.
5
Kristen Brown, Esq. SBN#208030
6 LAW OFFICES OF KRISTEN BROWN
900 W. 17th Street, Ste. C
7 Santa Ana, 92706 CA
Telephone No: (714) 564—7695
8 Facsimile N0: (714) 766-8440
krisbrownesq@yahoo.com
9
Attorneys for Plaintiff, ABRAHAM MURRAY
1O
11
SUPERIOR COURT OF THE STATE OF CALIFORNIA
.
12
COUNTY OF SAN BERNARDINO
13
14
ABRAHAM MURRAY, CASE NO.. CIV 081907075
. z
15
Plaintiff’
STIPULATION T0 CONTINUE
TRIAL AND TRIAL RELATED
16
vs
DATES
17
[Prop0_sed/ Order Filed Concurrently
SIMPLIFIED STAFFING LABOR ””9“”
13 SOLUTIONS ONTARIO; —
SIMPLIFIED STAFFING LABOR
1g SOLUTIONS, LLC; and DOES m 1
Tm” .
Da‘e' .
Fm 17’ 2°22
20’
Trial Readiness Cont: Feb. 22, 2022
20
Defendants.
Dept: s_32
21
22
a”) r,
“a ,2 ye»; ii jiz‘ 21,3
23
TO ALL PARTIES HEREIN AND THEIR RESPECTIVE COUNSEL OF RECORD:
24
25 Subject to the approval ofthe Court, PlaintiffABRAHAM MURRY (“Plaintiff") and
26 Defendants SIMPLIFIED STAFFING LABOR SOLUTIONS LLC AND SIMPLIFIED LABOR
27 STAFFING SOLUTIONS INC. (“Defendants”) (collectively, the “Parties”), by and through their
28
LAW OFFICES OF
szfimma’éfiérslgfid. STIPULA'I‘mN T0 CONTINUE TRIAL
S(e.265
Ontario CA 91 764
A
respective counsel 0f record, stipulate and agree to a continuance of the current trial date and all
related deadlines in this matter.
RECITALS
WHEREAS, the Complaint in this action was filed 0n March 6, 2019;
WHEREAS, Plaintifffiled a First Amended Complaint 0n or about September 9, 201 9;
OOmVQU‘IAWN
WHEREAS. Defendant SIMPLIFIED STAFFING LABOR SOLUTIONS LLC filed an
Answer t0 Plaintiff’s First Amended Complaint 0n 0r about September 25, 2019;
WHEREAS, Plaintiff filed an amendment to the First Amended Complaint 0n 0r about
January 15, 2020;
WHEREAS, Defendant SIMPLIFIED LABOR STAFFING SOLUTIONS INC. filed an
Answer t0 Plaintiff‘s First Amended Complaint on or about February 18, 2020;
WHEREAS, a Notice ofSubstitution of Attorneys was filed by prior defense counsel 0n 0r
about August 4, 2020 substituting out prior defense counsel and substituting in the current defense
counsel Ricardo Martin Esq. 0f Angel City Law;
WHEREAS, the Court previously continued the trial in this matter t0 the current dates of
Trial 0n February 22, 2022 with a Trial Readiness Conference on February 17, 2022;
WHEREAS, given the disruption and delays of the global pandemic and health and safety
NNNNNNNNAAAQJAJAA-k
order 0f the federal, state and local governments, the Parties have had some delay in obtaining
VmwthAOmmflmmLmN—A
discovery however that parties have propounded and responded to written discovery.
WHEREAS, Plaintiffhas taken the deposition 0fthe Person Most Knowledgeable.
Plaintiff‘s deposition is pending t0 be calendared as well;
WHEREAS, Kathleen Castro, the associate 0fthe Law Offices of Sandra H. Castro, Inc. and
Kristen Brown are the main attorneys handling this matter;
WHEREAS, Kathleen Castro recently needed to be placed out earlier than expected by her
physician 0n pregnancy leave. Kristen Brown has assumed all of her case load responsibilities for
certain civil cases while she is 0n leave. Ms‘ Castro is expected to return to work approximately
April 2022.
28
LAW OFFICES OF
SANDRA H. CASTRO
3200 Inland Empire Blvd.
5m. 265 STIPULATION TO CONTINUE TRIAL h)
Ontario CA 91 754
Document Filed Date
January 12, 2022
Case Filing Date
March 06, 2019
Category
Wrongful Termination
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Sandra H. Castro, Esq. SBN#207475 1 Fataleg}?l'CCEaSSt8’ Esq' SBN#312495 .A r’ ‘ F SANDRA H. CASTRO, INC. SUPERIORchulfiTaQALIFORNA " 2 1111321 Blvd, Ste. 265 C??:?EYESSASRW»?§3TSAT%%¥O $220 131%? n arlo 3 Telephone No: (909)989-2700 JAN 1 2 2022 4 Facsmgile N0: (909)989-2733 castro a lawservicesonline.com kathleen@lawservicesonline.com BY W’Mz?‘ , \ ANNE PERRY EPUTY . 5 Kristen Brown, Esq. SBN#208030 6 LAW OFFICES OF KRISTEN BROWN 900 W. 17th Street, Ste. C 7 Santa Ana, 92706 CA Telephone No: (714) 564—7695 8 Facsimile N0: (714) 766-8440 krisbrownesq@yahoo.com 9 Attorneys for Plaintiff, ABRAHAM MURRAY 1O 11 SUPERIOR COURT OF THE STATE OF CALIFORNIA . 12 COUNTY OF SAN BERNARDINO 13 14 ABRAHAM MURRAY, CASE NO.. CIV 081907075 . z 15 Plaintiff’ STIPULATION T0 CONTINUE TRIAL AND TRIAL RELATED 16 vs DATES 17 [Prop0_sed/ Order Filed Concurrently SIMPLIFIED STAFFING LABOR ””9“” 13 SOLUTIONS ONTARIO; — SIMPLIFIED STAFFING LABOR 1g SOLUTIONS, LLC; and DOES m 1 Tm” . Da‘e' . Fm 17’ 2°22 20’ Trial Readiness Cont: Feb. 22, 2022 20 Defendants. Dept: s_32 21 22 a”) r, “a ,2 ye»; ii jiz‘ 21,3 23 TO ALL PARTIES HEREIN AND THEIR RESPECTIVE COUNSEL OF RECORD: 24 25 Subject to the approval ofthe Court, PlaintiffABRAHAM MURRY (“Plaintiff") and 26 Defendants SIMPLIFIED STAFFING LABOR SOLUTIONS LLC AND SIMPLIFIED LABOR 27 STAFFING SOLUTIONS INC. (“Defendants”) (collectively, the “Parties”), by and through their 28 LAW OFFICES OF szfimma’éfiérslgfid. STIPULA'I‘mN T0 CONTINUE TRIAL S(e.265 Ontario CA 91 764 A respective counsel 0f record, stipulate and agree to a continuance of the current trial date and all related deadlines in this matter. RECITALS WHEREAS, the Complaint in this action was filed 0n March 6, 2019; WHEREAS, Plaintifffiled a First Amended Complaint 0n or about September 9, 201 9; OOmVQU‘IAWN WHEREAS. Defendant SIMPLIFIED STAFFING LABOR SOLUTIONS LLC filed an Answer t0 Plaintiff’s First Amended Complaint 0n 0r about September 25, 2019; WHEREAS, Plaintiff filed an amendment to the First Amended Complaint 0n 0r about January 15, 2020; WHEREAS, Defendant SIMPLIFIED LABOR STAFFING SOLUTIONS INC. filed an Answer t0 Plaintiff‘s First Amended Complaint on or about February 18, 2020; WHEREAS, a Notice ofSubstitution of Attorneys was filed by prior defense counsel 0n 0r about August 4, 2020 substituting out prior defense counsel and substituting in the current defense counsel Ricardo Martin Esq. 0f Angel City Law; WHEREAS, the Court previously continued the trial in this matter t0 the current dates of Trial 0n February 22, 2022 with a Trial Readiness Conference on February 17, 2022; WHEREAS, given the disruption and delays of the global pandemic and health and safety NNNNNNNNAAAQJAJAA-k order 0f the federal, state and local governments, the Parties have had some delay in obtaining VmwthAOmmflmmLmN—A discovery however that parties have propounded and responded to written discovery. WHEREAS, Plaintiffhas taken the deposition 0fthe Person Most Knowledgeable. Plaintiff‘s deposition is pending t0 be calendared as well; WHEREAS, Kathleen Castro, the associate 0fthe Law Offices of Sandra H. Castro, Inc. and Kristen Brown are the main attorneys handling this matter; WHEREAS, Kathleen Castro recently needed to be placed out earlier than expected by her physician 0n pregnancy leave. Kristen Brown has assumed all of her case load responsibilities for certain civil cases while she is 0n leave. Ms‘ Castro is expected to return to work approximately April 2022. 28 LAW OFFICES OF SANDRA H. CASTRO 3200 Inland Empire Blvd. 5m. 265 STIPULATION TO CONTINUE TRIAL h) Ontario CA 91 754