On March 06, 2019 a
Stipulation,Agreement
was filed
involving a dispute between
Hyle, John,
and
Aguilar, Elia M,
Rodriguez, Arianna Athena,
Rodriguez, Arianne Athena,
Rodriguez, David J,
for PI Motor Vehicle
in the District Court of San Bernardino County.
Preview
RIZIO LIPINKSY LAW FIRM PC
Gregory G. Rizio, Bar No. 157008
gfizio@riziqlawfirm.com
{“yfipf’aiéhsifi‘"
Bf—“N°'127537 F I L E D
W- t QC 10 3W lIm.COIn S&Elfimesgggmazgckgazsm
2677 North Main Street, Ste. 225 SAN BERNARD'NO D'STR'CT
Santa Ana, CA 92705
Phone.- (714) 505—2468 MAR 0 5 202’
Facsimile: (714) 547—1245
7
‘
’
BY I
Attorneys for Plaintifflohn Hyle CHRIS GOLDSTEIN. DEPUTY
SUPERIOR COURT 0F THE STATE 0F CALIFORNIA
COUNTY 0F SAN BERNARDINQ
10
'
11 JOHN HYLE, Case No. CIVDSI 907037
12 Plaintiffi
STIPULATED REQUEST To CONTINUE
13 ‘
V“
JURY TRIAL AND ALL TRIAL
RELATED DATES
14 ARIANNA ATHENA RODRIGUEZ;
DAVID J. RODRIGUZ; ELIA' M. Complamt
i _
Flled: 3/6/19
15 AGUILAR; and DOES through 100, 1 Trial: 4/5/21
inclusive, TRC: 4/2/21
‘15
Defendants.
17
*B‘YFFKX
18
Comes now the parties hereto t'o request that the Court grant them a continuance 0f the trial
19
and trial related dates, and submit the following in support thereof;
20
1. This matter involves a claim for personal injuries arising fi'om
a motor vehicle collisinn.
21
Trial is cuflenfly scheduled for April 5, 202, and the triai readiness conference is set for April 2,-
22
2021. The parties have diligently engaged in discovery, as well as
23 settlement discussions,
including through the court’s mediation program on October
24 30, 2019. The parties were unable to
settle. Discovery and litigation continued in preparation for the April 202 I
25 5-, ,. trial date. Expert
designations were exchanged pursuant to CCP section 2034 on February
26 12, 202i. The parties
have been attempting to schedule the depositions 0f their respective designated experts, as
27 wen as
some ofplaintiff’s non—designated health care
providers, and ethar witnesses, includingbut not
23
-1 _
Stipulation to Continue Trial and Trial Related Dates
limited to defendant Arianna Rodriguez. The parties need some additional time to complete this
process. There have been no other such continuances requested by the parties.
2. The parties have met and conferred, including with their experts, on a trial date suitable for
LJI-BUJN
all involved. The parties request a continuance of the tn'al date t0 August 23;, 202 l, and the trial
readiness-conference to August 20, 2021, or to dates available on the court’s calendar. The parties
request that all other deadlines, including discovery deadlines, be cominued to dates
commenwr‘at'eiwith the new trial date.
\COONJOK
IT IS SO STIPULATED.
10
11
5" ”’9“
12 Dated: By:
6’13 . Whinock
13- ‘
tomeys for Plaintiff
14
15
HATES
16
17
Dated; March 3, 2021
2/ W?”
Attorneys for Deiéndants
18
19
20
21
22
23
24
25
26
27
28
-2-
Stipulation to Continue Trial and Trial Reimed Dates
Document Filed Date
March 05, 2021
Case Filing Date
March 06, 2019
Category
PI Motor Vehicle
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RIZIO LIPINKSY LAW FIRM PC Gregory G. Rizio, Bar No. 157008 gfizio@riziqlawfirm.com {“yfipf’aiéhsifi‘" Bf—“N°'127537 F I L E D W- t QC 10 3W lIm.COIn S&Elfimesgggmazgckgazsm 2677 North Main Street, Ste. 225 SAN BERNARD'NO D'STR'CT Santa Ana, CA 92705 Phone.- (714) 505—2468 MAR 0 5 202’ Facsimile: (714) 547—1245 7 ‘ ’ BY I Attorneys for Plaintifflohn Hyle CHRIS GOLDSTEIN. DEPUTY SUPERIOR COURT 0F THE STATE 0F CALIFORNIA COUNTY 0F SAN BERNARDINQ 10 ' 11 JOHN HYLE, Case No. CIVDSI 907037 12 Plaintiffi STIPULATED REQUEST To CONTINUE 13 ‘ V“ JURY TRIAL AND ALL TRIAL RELATED DATES 14 ARIANNA ATHENA RODRIGUEZ; DAVID J. RODRIGUZ; ELIA' M. Complamt i _ Flled: 3/6/19 15 AGUILAR; and DOES through 100, 1 Trial: 4/5/21 inclusive, TRC: 4/2/21 ‘15 Defendants. 17 *B‘YFFKX 18 Comes now the parties hereto t'o request that the Court grant them a continuance 0f the trial 19 and trial related dates, and submit the following in support thereof; 20 1. This matter involves a claim for personal injuries arising fi'om a motor vehicle collisinn. 21 Trial is cuflenfly scheduled for April 5, 202, and the triai readiness conference is set for April 2,- 22 2021. The parties have diligently engaged in discovery, as well as 23 settlement discussions, including through the court’s mediation program on October 24 30, 2019. The parties were unable to settle. Discovery and litigation continued in preparation for the April 202 I 25 5-, ,. trial date. Expert designations were exchanged pursuant to CCP section 2034 on February 26 12, 202i. The parties have been attempting to schedule the depositions 0f their respective designated experts, as 27 wen as some ofplaintiff’s non—designated health care providers, and ethar witnesses, includingbut not 23 -1 _ Stipulation to Continue Trial and Trial Related Dates limited to defendant Arianna Rodriguez. The parties need some additional time to complete this process. There have been no other such continuances requested by the parties. 2. The parties have met and conferred, including with their experts, on a trial date suitable for LJI-BUJN all involved. The parties request a continuance of the tn'al date t0 August 23;, 202 l, and the trial readiness-conference to August 20, 2021, or to dates available on the court’s calendar. The parties request that all other deadlines, including discovery deadlines, be cominued to dates commenwr‘at'eiwith the new trial date. \COONJOK IT IS SO STIPULATED. 10 11 5" ”’9“ 12 Dated: By: 6’13 . Whinock 13- ‘ tomeys for Plaintiff 14 15 HATES 16 17 Dated; March 3, 2021 2/ W?” Attorneys for Deiéndants 18 19 20 21 22 23 24 25 26 27 28 -2- Stipulation to Continue Trial and Trial Reimed Dates