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F L
SUPERIOR COURT E
l
COUNTY 0F SAN OFQAUFORNIA
SAN BERNARDINngg‘éQrgfiE'P
George M. Wallace -- Cal. Bar No. 101472
WALLACE, BROWN & SCHWARTZ
215 North Marengo Avenue JUN 0 2 2021
Third Floor
‘
Pasadena, California 91 101-1504
(626) 844—6777; Fax (626) 795-0353
By K /
GRACE RIOS, D.V.M.,
Attorneys for Defendants
and ANIMAL EMERGENCY CLINIC
\oooqoxmeNH
SUPERIOR COURT OF THE STATE 0F CALIFORNIA
COUNTY 0F SAN BERNARDINO
HO
ILLYA HARDY, an individual; Case No.: CIV DS 2002744
JOHANNA BARLUND HARDY, an
[\J
individual; TOPLINE K9 SERVICES, Unlimited Jurisdiction - Claim
Exceeds $25,000
U)
Plaintiffs, [Assignedfor allgurposes t0 the
Honorable Lynn oncin, Dept. S28]
vs.
Com Iaint Filed: January 27, 2020
mm-b
GRACE RIOS, D.V.M., an Individual; Tria Date: August 16, 2021
ANIMAL ENIERGENCY CLINIC;
and DOES 1- 50, inclusive, STIPULATION AND [PRGPOSEB]
'
NNNNNNr—dr—dv—dt—Hp—np—tr—Hy—n
ORDER TO CONTINUE TRIAL AND
Defendants. PRETRIAL DATES
OOOOQ
H The parties to this action, through their respective attorneys of record,
stipulate as follows:
UI-hUJN
Stipulation and [Proposed] Order Continuing Trial — 1
2020.
1. Plaintiffs filed this veterinary malpractice action on January 27,
2. On September 11, 2020, the Court conducted a Trial Setting
trial to begin on August 16,
Conference and scheduled the case for a 3-5 day jury
with a Final
2021, at 8:30 a.m. in Department $28 of the above—entitled Court,
\oooqo‘mhwwy—I
Status Conference to be held August 12, 2021, at 8:30 a.m. in Department $28 of
the Court.
cooperation on
3. Despite diligent efforts on the part of all parties, and
both sides in those efforts, necessary discovery and depositions have not yet been
completed, and will not be completed in advance of the
upcoming pretrial
parties themselves have
discovery cut-ofis. In particular, the depositions ofthe
of percipient
been tentatively scheduled, but not yet conducted. The depositions
witnesses may affect the parties’ expert disclosures and discovery as well. In the
circumstances, all parties, by and through their respective counsel, are seeking a
continuance of the trial and pretrial dates, and of discovery and motion cut-offs, for
approximately four months beyond the existing dates.
4. As all parties are in agreement concerning the continuance, there
NNNNNNHHHHo—AHp—Ap—aHp—n
would be no prejudice to any party in further continuing trial in this matter. The
patties therefore respectfully request this court to continue the start
of trial from
UI-PWNh‘OKOOOflO\UIhWNFO
August 16, 2021, to a date convenient and acceptable to the Court’s calendar in
December, 2021, and propose either December 6 or December 13, 2021 for
early
that purpose, with Final Status Conference being continued for a similar period of
time, e.g. to a date during the week of November 29, 2021. A11 parties further
discovery, motion, and other pretrial cut-off dates and deadlines
be
request that all
extended, and that they be calculated per Code from the new trial date.
Stipulation and [Proposed] Order Continuing Trial
— 2
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F L SUPERIOR COURT E l COUNTY 0F SAN OFQAUFORNIA SAN BERNARDINngg‘éQrgfiE'P George M. Wallace -- Cal. Bar No. 101472 WALLACE, BROWN & SCHWARTZ 215 North Marengo Avenue JUN 0 2 2021 Third Floor ‘ Pasadena, California 91 101-1504 (626) 844—6777; Fax (626) 795-0353 By K / GRACE RIOS, D.V.M., Attorneys for Defendants and ANIMAL EMERGENCY CLINIC \oooqoxmeNH SUPERIOR COURT OF THE STATE 0F CALIFORNIA COUNTY 0F SAN BERNARDINO HO ILLYA HARDY, an individual; Case No.: CIV DS 2002744 JOHANNA BARLUND HARDY, an [\J individual; TOPLINE K9 SERVICES, Unlimited Jurisdiction - Claim Exceeds $25,000 U) Plaintiffs, [Assignedfor allgurposes t0 the Honorable Lynn oncin, Dept. S28] vs. Com Iaint Filed: January 27, 2020 mm-b GRACE RIOS, D.V.M., an Individual; Tria Date: August 16, 2021 ANIMAL ENIERGENCY CLINIC; and DOES 1- 50, inclusive, STIPULATION AND [PRGPOSEB] ' NNNNNNr—dr—dv—dt—Hp—np—tr—Hy—n ORDER TO CONTINUE TRIAL AND Defendants. PRETRIAL DATES OOOOQ H The parties to this action, through their respective attorneys of record, stipulate as follows: UI-hUJN Stipulation and [Proposed] Order Continuing Trial — 1 2020. 1. Plaintiffs filed this veterinary malpractice action on January 27, 2. On September 11, 2020, the Court conducted a Trial Setting trial to begin on August 16, Conference and scheduled the case for a 3-5 day jury with a Final 2021, at 8:30 a.m. in Department $28 of the above—entitled Court, \oooqo‘mhwwy—I Status Conference to be held August 12, 2021, at 8:30 a.m. in Department $28 of the Court. cooperation on 3. Despite diligent efforts on the part of all parties, and both sides in those efforts, necessary discovery and depositions have not yet been completed, and will not be completed in advance of the upcoming pretrial parties themselves have discovery cut-ofis. In particular, the depositions ofthe of percipient been tentatively scheduled, but not yet conducted. The depositions witnesses may affect the parties’ expert disclosures and discovery as well. In the circumstances, all parties, by and through their respective counsel, are seeking a continuance of the trial and pretrial dates, and of discovery and motion cut-offs, for approximately four months beyond the existing dates. 4. As all parties are in agreement concerning the continuance, there NNNNNNHHHHo—AHp—Ap—aHp—n would be no prejudice to any party in further continuing trial in this matter. The patties therefore respectfully request this court to continue the start of trial from UI-PWNh‘OKOOOflO\UIhWNFO August 16, 2021, to a date convenient and acceptable to the Court’s calendar in December, 2021, and propose either December 6 or December 13, 2021 for early that purpose, with Final Status Conference being continued for a similar period of time, e.g. to a date during the week of November 29, 2021. A11 parties further discovery, motion, and other pretrial cut-off dates and deadlines be request that all extended, and that they be calculated per Code from the new trial date. Stipulation and [Proposed] Order Continuing Trial — 2