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1 Janice D. Dudensing (Bar No. 279561)
The Law Firm ofJan Dudensing 2illlftUGI5 AM 9:0
2 925 G Street
Sacramento, CA 95814 SACRAMENTOCOUR
3 Telephone; (916) 448-3122 DEPT. /?5U
Facsmiile: (916) 448-1004
4 Attomeys for Defendant,
Dr. James Longoria
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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IN AND FOR THE COUNTY OF SACRAMENTO
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CHARLES SOMERS, individually and as Case No.: 34-2018-229212
10 tmstee for the CHARLES SOMERS LIVING
TRUST,
11 JOINT STIPULATION TO CONTINUE
Plaintiff, HEARING ON MOTION TO
12 DISQUALIFY WILLIAM R. WARNE
vs. AND DOWNEY BRAND, LLP 0^^B\^
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DR. JAMES LONGORIA, an individual, and
14 DOES 1-10,
15 Defendants.
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STIPULATION AND [PROPOSED] ORDER
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1 Defendant Dr. JAMES LONGORL\ ("Defendant") and Plaintiff CHARLES SOMERS,
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individually and as trustee for CHARLES SOMERS LIVING TRUST ("PlaintifF*), by and
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through their respective coimsel, hereby stipulate and agree as follows:
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5 1. On July 06, 2018, Defendant noticed a motion to disqualify William R. Wame
6 and Downey Brand LLP as coimsel for Plaintiff in this matter.
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2. The hearing on the motion to disqualify was originally noticed for August 8,
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2018, and was later continued to August 17, 2018, pursuant to a stipulation
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10 between the parties.
II 3. Defendant's counsel was traveling in Europe, and on August 9, 2018, as she was
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attempting to return home for the scheduled hearing set for August 17, 2018, she
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was unable to board herflightbecause it was closed due to a bomb threat at the
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Paris airport.
16 4. Therefore, Ms. Dudensing met and conferred with plaintiffs counsel and
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requested to stipulate to continue the hearing set for August 17, 2018.
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5. The parties agreed to continue the hearing to September 07, 2018, at 9:00 a.m., in
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2Q Department 54 of the Sacramento Coimty Superior Court, before the Honorable
21 Christopher E. Krueger.
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6. The partiesftutheragree that the briefing schedule for the motion to disquahfy
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has already closed and, therefore, continuing the hearing to September 7, 2018,
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STIPULATION AND (PROPOSED] ORDER
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1 shall not change the briefing schedule pr otherwise entitle the parties to submit
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any additional briefs not already on file.
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Dated: August 13,2018 THE LAW FIRM OF JAN DUDENSING
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5 By:
JANICI
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Attorneys £6T Defibdant
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DR. JAMES LONGORIA
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9 Dated: y//y//r DOWNEY BRAND LLP
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By:
11 ^William R, Wame
• • Attomey for Plaintiff
12 CflARLES SOMERS, individually and as trustee
for the CHARLES SOMERS LIVING TRUST
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I T IS SO O R D E R E D .
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Dated:
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JUDGE OF THE STOTRIOR COURT
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CHRISTOPHER E. KRUEGER
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STIPULATION AND [PROPOSED] ORDER
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1 II PROOF O F S E R V I C E
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Charles Somer V. Dr. fames hongoria, Sacramento Superior Court, Case No.: 34-2018-00229212
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I, Patty Paniagua, am a Legal Resident of the United States and employed in the
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I County of Sacramento. I am over the age of eighteen (18) years and not a party to the
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within action. My business address is 925 G Street, Sacramento, CA 95814
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Today, the following document was sent via IVIAIL to the interested party below:
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„ ,, JOINT STIPULATION TO CONTINUE HEARING ON MOTION TO DISQUALIFY
^ II WILLIAM R. WARNE AND DOWNEY BRAND, L L P
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Attomey for Plaintiff:
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William R. Warne
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Downey Brand LLP
13 II 621 Capitol Mall, 18th Floor
Sacramento, CA 95814
14 bwarne(g),downeybrand.com
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16 II I declare under penalty of perjury under the laws of the .State of Califomia that
17 the foregoing is tme and correct, and that this declaration was executed on August 14, 2018
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Proofof Service
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Preview
1 Janice D. Dudensing (Bar No. 279561) The Law Firm ofJan Dudensing 2illlftUGI5 AM 9:0 2 925 G Street Sacramento, CA 95814 SACRAMENTOCOUR 3 Telephone; (916) 448-3122 DEPT. /?5U Facsmiile: (916) 448-1004 4 Attomeys for Defendant, Dr. James Longoria 5 6 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 IN AND FOR THE COUNTY OF SACRAMENTO 9 CHARLES SOMERS, individually and as Case No.: 34-2018-229212 10 tmstee for the CHARLES SOMERS LIVING TRUST, 11 JOINT STIPULATION TO CONTINUE Plaintiff, HEARING ON MOTION TO 12 DISQUALIFY WILLIAM R. WARNE vs. AND DOWNEY BRAND, LLP 0^^B\^ 13 DR. JAMES LONGORIA, an individual, and 14 DOES 1-10, 15 Defendants. 16 17 18 19 20 21 22 23 24 25 STIPULATION AND [PROPOSED] ORDER Page 1 1 Defendant Dr. JAMES LONGORL\ ("Defendant") and Plaintiff CHARLES SOMERS, 2 individually and as trustee for CHARLES SOMERS LIVING TRUST ("PlaintifF*), by and 3 through their respective coimsel, hereby stipulate and agree as follows: 4 5 1. On July 06, 2018, Defendant noticed a motion to disqualify William R. Wame 6 and Downey Brand LLP as coimsel for Plaintiff in this matter. 7 2. The hearing on the motion to disqualify was originally noticed for August 8, 8 2018, and was later continued to August 17, 2018, pursuant to a stipulation 9 10 between the parties. II 3. Defendant's counsel was traveling in Europe, and on August 9, 2018, as she was 12 attempting to return home for the scheduled hearing set for August 17, 2018, she 13 was unable to board herflightbecause it was closed due to a bomb threat at the 14 Paris airport. 16 4. Therefore, Ms. Dudensing met and conferred with plaintiffs counsel and 17 requested to stipulate to continue the hearing set for August 17, 2018. 18 5. The parties agreed to continue the hearing to September 07, 2018, at 9:00 a.m., in 19 2Q Department 54 of the Sacramento Coimty Superior Court, before the Honorable 21 Christopher E. Krueger. 22 6. The partiesftutheragree that the briefing schedule for the motion to disquahfy 23 has already closed and, therefore, continuing the hearing to September 7, 2018, 24 /// . /// STIPULATION AND (PROPOSED] ORDER Page 2 1 shall not change the briefing schedule pr otherwise entitle the parties to submit 2 any additional briefs not already on file. 3 Dated: August 13,2018 THE LAW FIRM OF JAN DUDENSING 4 5 By: JANICI 6 Attorneys £6T Defibdant 7 DR. JAMES LONGORIA 8 9 Dated: y//y//r DOWNEY BRAND LLP 10 By: 11 ^William R, Wame • • Attomey for Plaintiff 12 CflARLES SOMERS, individually and as trustee for the CHARLES SOMERS LIVING TRUST 13 14 I T IS SO O R D E R E D . 15 Dated: 16 JUDGE OF THE STOTRIOR COURT 17 CHRISTOPHER E. KRUEGER 18 19 20 21 22 23 24 25 STIPULATION AND [PROPOSED] ORDER Page 3 1 II PROOF O F S E R V I C E 2 Charles Somer V. Dr. fames hongoria, Sacramento Superior Court, Case No.: 34-2018-00229212 3 I, Patty Paniagua, am a Legal Resident of the United States and employed in the 4 I County of Sacramento. I am over the age of eighteen (18) years and not a party to the 5 within action. My business address is 925 G Street, Sacramento, CA 95814 6 Today, the following document was sent via IVIAIL to the interested party below: 7 „ ,, JOINT STIPULATION TO CONTINUE HEARING ON MOTION TO DISQUALIFY ^ II WILLIAM R. WARNE AND DOWNEY BRAND, L L P 9 10 Attomey for Plaintiff: 11 William R. Warne 12 Downey Brand LLP 13 II 621 Capitol Mall, 18th Floor Sacramento, CA 95814 14 bwarne(g),downeybrand.com 15 16 II I declare under penalty of perjury under the laws of the .State of Califomia that 17 the foregoing is tme and correct, and that this declaration was executed on August 14, 2018 18 19 20 21 22 23 24 25 Proofof Service Page 1