Stipulation,Agreement: Lopez Magallon -v - General Motors, LLC et al Print

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      STRATEGIC LEGAL PRACTICES,             APC
      James L. Carroll (SBN 243684)
      1888 Century Park East, 19th Fl
      Los Angeles, CA 90067
      Telephone: (310) 929-4900                                superior    COURT   OF GALICIA
      Facsimile: (310) 943-3838
                                                                    CAN BERNARDINO Derr
      emailservices@slpattorney.com
       Icarroll@slpattorney.com                                           MAY 1 9 2023
 10
 11   Attorney for Plaintiff,                                                            =
                                                               By
 12   ALICIA LOPEZ MAGALLON                                           CHRIS GOLDSTEIN, DEPUTY
 13
 14   Mary Arens McBride, Esq. (SBN:      282459)
 1S   Ryan Kay, Esq., (SBN: 340354)
 16   The Erskine Law Group, PC.
 17   1592 N. Batavia St., Suite 1A
 18   Orange, California, 92867
19    Telephone: (949) 777-6032
20    Facsimile: (714) 844-9035
21
22    Attorneys for Defendant.
23    GENERAL       MOTORS LLC
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                                     SUPERIOR COURT OF CALIFORNIA
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27                                 FOR THE COUNTY   OF SAN BERNARDINO
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30    ALICIA LOPEZ MAGALLON.                          CASE NO.:     CIVSB2111706
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32                                                    Case Initiated: April 23, 2022
33                    Plaintiff,
34                                                    ASSIGNED FOR ALL PURPOSES TO.
35           V.                                       Honorable GILBERT OCHOA
36                                                    Department S24
37    GENERAL MOTORS, LLC, a Limited
38    Liability Company; and DOES | through 10,       JOINT STIPULATION TO CONTINUE
39    inclusive.                                      TRIAL AND ALL RELATED DATES
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41                    Defendants.
42                                                    TRIAL DATE: May 30, 2023
43                                                    TRC DATE: May 25, 2023
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46

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                  JOINT STIPULATION TO CONTINUE     JURY TRIAL AND ALL RELATED DATES
TO THE HONORABLE             COURT:

            IT IS HEREBY      STIPULATED by and between Plaintiff ALICIA LOPEZ MAGALLON

     (“Plaintiff”) and Defendant GENERAL          MOTORS      LLC     (“Defendant”),      by and through her

     respective counsel of record, as follows:

            WHEREAS, Jury Trial is set for May 30, 2023;
10          WHEREAS,       Trial Readiness Conference is set for May 25, 2023;
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12          WHEREAS,        counsel   for Plaintiff and   Defendant    have   six   (6)   separate   other   trials
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14   commencing May 30, 2023: (1) Carpio v. GM, San Bernardino County Case No. CIVSB2133144,
15   (2) Black v. GM, Kern County Case No. BCV-21-101150, (3) Davis v. GM, Alameda County
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17   Case No. RG21087939,      (4) Chacon v. GM, Los Angeles County Case No. 21STCV29447, (5)
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19   Adams v. GM, Los Angeles County Case No. 21STCV46957, (6) Asadoorian v. GM, Los Angeles
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     County Case No. 2] STCV37652;
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22          WHEREAS, the parties have agreed to mediate this matter before Grant Woodruff, WDRC,
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24   on June 21, 2023; In the event the parties are not able to resolve this matter via mediation, the
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     Parties request sufficient time to conclude discovery and prepare for trial;
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27          WHEREAS,       this is the first request for a trial continuance and the Parties believe that
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29   continuing trial and all related dates, including the discovery cut-offs, for at least 120 days, is in
30   the best interests of the Parties and the Court so there is sufficient time to mediate and resolve
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32   this case or conclude discovery and prepare for trial;
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34           WHEREAS,      due to the aforementioned reasons, the Parties believe there is good cause
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36   for their requested continuance of trial and all related dates, including the non-expert and expert
37   discovery cut-offs.
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39          NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED to by and between
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Al   Plaintiff and Defendant by and through their respective attorneys of record, to continue trial and
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     all related dates, including the non-expert discovery cut-off and expert discovery cutoff, for at
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44   least 120 days.
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46           A [Proposed] Order in a form approved by the parties will be filed concurrently with this

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               JOINT STIPULATION TO CONTINUE JURY TRIAL AND ALL RELATED                        DATES