Preview
Frank Perez [SBN 205377]
Cindy Panuco [SBN 266921]
Heribe1to Veliz [SBN 311591]
2 PEREZ & PEREZ, APC
1150 S. Olive Street, Suite 600
3 Los Angeles, CA 90015
Tel: (213) 745-6300
4 Fax: (213) 745-6060
5 Attomeys for Plaintiff,
TRACY GILMORE
6
7
SUPERIOR COURT OF THE STATE OF CALIFORNIA
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COUNTY OF KERN - METROPOLIT AN DIVISION JUSTICE BUILDING
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TRACY GILMORE, ) Case No.: BCV-22-101758
10
) Assigned to: Hon. David R. Zulfa
II Plaintiff, ) Dept. No.: J
V.
12 )
JAKOV DULCICH AND SONS, LLC; and )
13
DOES I through 50, inclusive, ) STIPULATION TO CONTINUE TRIAL,
14 ) FSC, MSC, AND ALL RELATED
Defendants. ) MOTION/DISCOVERY DATES
15 )
16 )
)
17 _______________)
18 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
19 STIPULATION OF PARTIES TO CONTINUE THE TRIAL DATE AND MSC
20 WHEREAS the parties hereto, through their respective attorneys ofrecord, hereby stipulat
21 that:
22 l. The Trial Date be continued from January 22, 2024, to June 24, 2024;
23 2. The Final Status Conference be continued from January 19, 2024, to June 17, 2024;
24 3. The Mandatory Settlement Conference be continued from December 21, 2023, to
25 May 20, 2024; and
26 4. Further, the parties stipulate that the discovery cut-off and all other pre-trial deadline
27 be continued pursuant to the new trial date, including expert witness related discovery
28
STIPULATION TO CONTINUE TRIAL, FSC, �ISC, AND ALL RELATED MOTION/DISCOVERY DATES
WHEREAS this is the parties' first ( I st) request for a trial continuance of the original trial
2 date.
3 WHEREAS this request is being made in good faith as it will allow the patties to engag
4 in meaningful settlement discussions and complete the necessary remaining discovery.
5 IT IS HEREBY STIPULATED.
6 Dated: October 24, 2023 PEREZ & PEREZ, APC
7
8
By:_U� �-4?_1 ___
9 Frank Perez
10 Heriberto Veliz
Attorneys for Plaintiff,
1I TRACY GILMORE
12 Dated: October 24, 2023 SKANE MILLS LLP
13
14
By: � �-,- �
15 /1feather L. Mills, Esq.
16 Jonathan E. Tarkowski, Esq.
Keith F. Gallarzo, Esq.
17 Attorneys for Defendant,
JAKOV DULCICH AND SONS, LLC
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19
20
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27
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STIPULATION TO CONTINUE TRIAL, FSC, i\lSC, AND ALL RELATED i\lOTION/DISCOVERY DATES
PROOF OF SERVICE
Tracy Gilmore v. Jakov D11/cicfl & S011s, et al.
Case No.: BCV-22-101758
STATE OF CALIFORNIA )
) ss.
COUNTY OF LOS ANGELES )
I am employed in the County of Los Angeles, State of California. I am over the age of 18
and not a party to the within action. My business address is 1150 South Olive Street, Suite 600,
Los Angeles, CA 90015.
On October 24, 2023, I served the foregoing documents described as:
STIPULATION TO CONTINUE TRIAL, FSC, MSC, AND ALL RELATED
MOTION/DISCOVERY DATES
on all on all interested parties in this action by sending [X] a true copy [ ] the original thereof
enclosed in sealed envelopes addressed as follows:
[SEE ATTACHED SERVICE LIST]
[] (BY MAIL) I am "readily familiar" with firm's practice of collection and processing
correspondence by mailing. Under that practice it would be deposited with U.S. postal service
on that same day with postage fully prepaid at Los Angeles, California in the ordinary course of
business. I am aware that on motion of the patty served, service is presumed invalid if postal
cancellation date or postage meter date is more than one day after date deposit for mailing
affidavit.
[X] (ONLY BY ELECTRONIC TRANSMISSION) Only by e-mailing the document(s) to the
persons at the e-mail address(es) listed based on notice provided that, during the Coronavirus
(COVID-19) pandemic, this office will be working remotely, not able to send physical mail as
usual, and is therefore using only electronic mail. No electronic message or other indication that
the transmission was unsuccessful was received within a reasonable time after the transmission.
[) (BY PERSONAL SERVICE) I delivered the foregoing envelope by hand to the offices of
the addressee.
[X] (STATE) I declare under penalty of pe1jury under the laws of the State of California that the
above is true and correct.
Executed on October 24, 2023 at Los Angeles, California
SERVICE LIST
Tracy Gilmore v. Jakov Dulcicll & Sons, et al.
Case No.: BCV-22-101758
ATTORNEY FOR DEFENDANTS
JAKOV DULCICH & SONS
Heather L. Mills
Skane Mills
1055 W. 7 th Street, Suite 1700
Los Angeles, CA 90017
T: (213) 452-1200
F: (213) 452-1201
HMILLS@SKANEMILLS.COM
bevangelista@skanemills.com
jtarkowski@skanemills.com
Jeff Marsilio@Stockwellharris.com
Preview
Frank Perez [SBN 205377] Cindy Panuco [SBN 266921] Heribe1to Veliz [SBN 311591] 2 PEREZ & PEREZ, APC 1150 S. Olive Street, Suite 600 3 Los Angeles, CA 90015 Tel: (213) 745-6300 4 Fax: (213) 745-6060 5 Attomeys for Plaintiff, TRACY GILMORE 6 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 COUNTY OF KERN - METROPOLIT AN DIVISION JUSTICE BUILDING 9 TRACY GILMORE, ) Case No.: BCV-22-101758 10 ) Assigned to: Hon. David R. Zulfa II Plaintiff, ) Dept. No.: J V. 12 ) JAKOV DULCICH AND SONS, LLC; and ) 13 DOES I through 50, inclusive, ) STIPULATION TO CONTINUE TRIAL, 14 ) FSC, MSC, AND ALL RELATED Defendants. ) MOTION/DISCOVERY DATES 15 ) 16 ) ) 17 _______________) 18 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: 19 STIPULATION OF PARTIES TO CONTINUE THE TRIAL DATE AND MSC 20 WHEREAS the parties hereto, through their respective attorneys ofrecord, hereby stipulat 21 that: 22 l. The Trial Date be continued from January 22, 2024, to June 24, 2024; 23 2. The Final Status Conference be continued from January 19, 2024, to June 17, 2024; 24 3. The Mandatory Settlement Conference be continued from December 21, 2023, to 25 May 20, 2024; and 26 4. Further, the parties stipulate that the discovery cut-off and all other pre-trial deadline 27 be continued pursuant to the new trial date, including expert witness related discovery 28 STIPULATION TO CONTINUE TRIAL, FSC, �ISC, AND ALL RELATED MOTION/DISCOVERY DATES WHEREAS this is the parties' first ( I st) request for a trial continuance of the original trial 2 date. 3 WHEREAS this request is being made in good faith as it will allow the patties to engag 4 in meaningful settlement discussions and complete the necessary remaining discovery. 5 IT IS HEREBY STIPULATED. 6 Dated: October 24, 2023 PEREZ & PEREZ, APC 7 8 By:_U� �-4?_1 ___ 9 Frank Perez 10 Heriberto Veliz Attorneys for Plaintiff, 1I TRACY GILMORE 12 Dated: October 24, 2023 SKANE MILLS LLP 13 14 By: � �-,- � 15 /1feather L. Mills, Esq. 16 Jonathan E. Tarkowski, Esq. Keith F. Gallarzo, Esq. 17 Attorneys for Defendant, JAKOV DULCICH AND SONS, LLC 18 19 20 21 22 23 24 25 26 27 28 2 STIPULATION TO CONTINUE TRIAL, FSC, i\lSC, AND ALL RELATED i\lOTION/DISCOVERY DATES PROOF OF SERVICE Tracy Gilmore v. Jakov D11/cicfl & S011s, et al. Case No.: BCV-22-101758 STATE OF CALIFORNIA ) ) ss. COUNTY OF LOS ANGELES ) I am employed in the County of Los Angeles, State of California. I am over the age of 18 and not a party to the within action. My business address is 1150 South Olive Street, Suite 600, Los Angeles, CA 90015. On October 24, 2023, I served the foregoing documents described as: STIPULATION TO CONTINUE TRIAL, FSC, MSC, AND ALL RELATED MOTION/DISCOVERY DATES on all on all interested parties in this action by sending [X] a true copy [ ] the original thereof enclosed in sealed envelopes addressed as follows: [SEE ATTACHED SERVICE LIST] [] (BY MAIL) I am "readily familiar" with firm's practice of collection and processing correspondence by mailing. Under that practice it would be deposited with U.S. postal service on that same day with postage fully prepaid at Los Angeles, California in the ordinary course of business. I am aware that on motion of the patty served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date deposit for mailing affidavit. [X] (ONLY BY ELECTRONIC TRANSMISSION) Only by e-mailing the document(s) to the persons at the e-mail address(es) listed based on notice provided that, during the Coronavirus (COVID-19) pandemic, this office will be working remotely, not able to send physical mail as usual, and is therefore using only electronic mail. No electronic message or other indication that the transmission was unsuccessful was received within a reasonable time after the transmission. [) (BY PERSONAL SERVICE) I delivered the foregoing envelope by hand to the offices of the addressee. [X] (STATE) I declare under penalty of pe1jury under the laws of the State of California that the above is true and correct. Executed on October 24, 2023 at Los Angeles, California SERVICE LIST Tracy Gilmore v. Jakov Dulcicll & Sons, et al. Case No.: BCV-22-101758 ATTORNEY FOR DEFENDANTS JAKOV DULCICH & SONS Heather L. Mills Skane Mills 1055 W. 7 th Street, Suite 1700 Los Angeles, CA 90017 T: (213) 452-1200 F: (213) 452-1201 HMILLS@SKANEMILLS.COM bevangelista@skanemills.com jtarkowski@skanemills.com Jeff Marsilio@Stockwellharris.com