On May 29, 2020 a
Motion-Secondary
was filed
involving a dispute between
Gomez, Ricardo,
and
Besheer, Nicholas Adam,
City Of Rialto A Government Entity,
City Of Rialto Police Department A Government Entity,
for Personal Injury Motor Vehicle Unlimited
in the District Court of San Bernardino County.
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Michael Kams, Esq. (SBN 232256)
William Kams, Esq. (SBN 238599)
Timothy Mitchell, Esq. (SBN 234130)
Kams & Kams, LLP F D
suvmon c. MT E
I '.
800 West 6th Street, Suite 800 0F CALIFORNIA
COUNTY OF SAN BERNARDINO
©WNGM$WN
Los Angeles, CA 90017
Tel: (310) 623-9032
Fax: (310) 623-9033
r6 8mm SAN BERNARDINO DISTRICT
APR o5 20;:
Email: tim@kamsandkams.com
Attorneys for Plaintiff RICARDO GOMEZ
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 COUNTY OF SAN BERNARDINO
11
RICARDO GOMEZ, an Individual; Case No.1 CIVD82009827
12 Assigned to Hon. Thomas Garza
Plaintiff,
Dept; $27
13
VS.
14 PLAINTIFF’S OPPOSITION TO
DEFENDANT’S EX PARTE
CITY OF RIALTO POLICE DEPARTMENT.,
15 APPLICATION TO CONTINUE THE
a Government Entity; CITY OF RIALTO, a
Government
TRIAL DATE; DECLARATION OF
16 entity; NICHOLAS ADAM TIMOTHY P. MITCHELL,
BESHEER, ESQ.
an Individual; and DOES 1
17
18
19
through 50, Inclusive;
Defendants AW/ZZ W4
20 Complaint Filed: May 20, 2020
J
Trial Date: May 23, 2022
21
22 TO THE COURT, THE PARTIES, AND THEIR RESPECTIVE
COUNSEL OF
23 RECORD:
24 Plaintiff RICARDO GOMEZ herein opposes the Defendant’s Ex Parte Application to
25 continue the trial date. Defendant has no good causse for the trial continuance due t0 their own
26 lack of diligence in the matter. The discovery Defendant is claiming to need could have been
27 obtained months ago, and Defendant has waite
d until the eve oftrial to seek the information.
The
28 Court should not award a party that lays on their
laurels throughout the process.
1
OPPOSITION TO EX PARTE APPLICATION
I.
A
Document Filed Date
April 05, 2022
Case Filing Date
May 29, 2020
Category
Personal Injury Motor Vehicle Unlimited
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Michael Kams, Esq. (SBN 232256) William Kams, Esq. (SBN 238599) Timothy Mitchell, Esq. (SBN 234130) Kams & Kams, LLP F D suvmon c. MT E I '. 800 West 6th Street, Suite 800 0F CALIFORNIA COUNTY OF SAN BERNARDINO ©WNGM$WN Los Angeles, CA 90017 Tel: (310) 623-9032 Fax: (310) 623-9033 r6 8mm SAN BERNARDINO DISTRICT APR o5 20;: Email: tim@kamsandkams.com Attorneys for Plaintiff RICARDO GOMEZ SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF SAN BERNARDINO 11 RICARDO GOMEZ, an Individual; Case No.1 CIVD82009827 12 Assigned to Hon. Thomas Garza Plaintiff, Dept; $27 13 VS. 14 PLAINTIFF’S OPPOSITION TO DEFENDANT’S EX PARTE CITY OF RIALTO POLICE DEPARTMENT., 15 APPLICATION TO CONTINUE THE a Government Entity; CITY OF RIALTO, a Government TRIAL DATE; DECLARATION OF 16 entity; NICHOLAS ADAM TIMOTHY P. MITCHELL, BESHEER, ESQ. an Individual; and DOES 1 17 18 19 through 50, Inclusive; Defendants AW/ZZ W4 20 Complaint Filed: May 20, 2020 J Trial Date: May 23, 2022 21 22 TO THE COURT, THE PARTIES, AND THEIR RESPECTIVE COUNSEL OF 23 RECORD: 24 Plaintiff RICARDO GOMEZ herein opposes the Defendant’s Ex Parte Application to 25 continue the trial date. Defendant has no good causse for the trial continuance due t0 their own 26 lack of diligence in the matter. The discovery Defendant is claiming to need could have been 27 obtained months ago, and Defendant has waite d until the eve oftrial to seek the information. The 28 Court should not award a party that lays on their laurels throughout the process. 1 OPPOSITION TO EX PARTE APPLICATION I. A