Document for JUAREZ ALVAREZ -v- HUNT PRISCILLA LIVING TRUST et al Print

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                                Lawrence Levy, Esq. SBN 55845
     Thomas Murphy, Esq. SBN 44068
     Ethan Ysais, Esq. SBN 235813                                                  SUPERIOR COURT OF CALIFORNIA,
                                                                                     COUNTY OF SAN BERI   ‘DINO:
     THE LAWYERS GROUP, INC.                                                          SAN BERNARDINO DISTRICT
     505 East First Street, Suite E
     Tustin, California 92780                                                               SEP 08 2023
     Telephone: 714.672.0899
     Facsimile: 714.672.0677
                                                                              BY
                                                                                         DEBRA PEDROSA, DEPUTY
     Attorneys for Plaintiff,
     Yolanda Juarez Alvarez



                              SUPERIOR COURT OF THE STATE OF CALIFORNIA

10                                  FOR THE COUNTY OF SAN BERNARDINO
il
     YOLANDA JUAREZ ALVAREZ, an                              Case No.: CIVDS1916334
12   individual,
13                                                           Assigned for all purposes to
                 Plaintiff,                                  Hon. Thomas S. Garza
14                                                           Dept. S-27
     Vv
15                                                           JOINT STIPULATION TO CONTINUE
     HUNT PRISCILLA LIVING TRUST; CITY                       MSJ, TRIAL, AND TRIAL-RELATED
16
     OF FONTANA,              and DOES | through 100,        DATES; PROPOSED] ORDER
17   inclusive
                                                             TRC:     November 2, 2023
18                                                           Dept.: S-27
                 Defendants,                                 Time: 8:30 AM
19
          -and                                               Trial:   November 6, 2023
20                                                           Dept.:   8-27
                                                             Time:    10:00 AM
     JUAN HERNANDEZ, an individual,
21

22               Nominal Defendant

23
24

25        TO THE HONORABLE                COURT:
                                                                                     SD
26               Plaintiff, YOLANDA      ALVAREZ      (hereinafter, “Plaintiff’); Defendant, CITY OF

27   FONTANA (hereinafter, “Defendant CITY”); Defendants PRISCILLA HUNT and BESSEMER
28   TRUST COMPANY, N.A., as Co-Trustees of the Donald G. Hunt Living Trust; and Defendant



                                                             1
      JOINT STIPULATION          TO CONTINUE   MSJ, TRIAL   AND     TRIAL-RELATED       DATES;   [PROPOSED]   ORDER
w~


     HUNT    ENTERPRISES,       (hereinafter, “BESSEMER      Defendants”), and collectively (hereinafter,

     Plaintiff
            and all Defendants together, “the PARTIES”) hereby stipulate and agree as follows:




             WHEREAS, the BESSEMER Defendants two (2) Motions for Summary Judgment are

     currently set for September 12, 2023, at 8:30 a.m. in Department S-27;
             WHEREAS, the Trial Readiness Conference date in this matter is currently set for

     November 2, 2023, at 8:30 a.m. in Department S-27;
             WHEREAS,       the Trial date in this matter is currently set for November 6, 2023, at 10:00

10   a.m. in Department S-27;
1            WHEREAS, counsel for THE PARTIES have met and conferred in good faith with
12   respect to a continuance of the Trial Readiness Conference and Trial dates in this matter
13   considering the upcoming steps in the litigation of this matter;
14           WHEREAS, the parties have been diligently litigating the case at bar;
15           WHEREAS the last hearing in this matter was held in Department S-27 before the
16   Honorable Thomas S. Garza on or about July 13, 2023, on the BESSEMER Defendants Motion
17   for Leave to File Cross Complaint;
18           WHEREAS, at the hearing of the above-stated motion on or about July 13, 2023,
19   Honorable Thomas S. Garza informed all counsel telephonically present and representing THE

20   PARTIES, that if THE PARTIES needed a continuance on any pending motions or on the trial

21   date, that THE PARTIES should stipulate to such a continuance and the Court did not foresee

22   any issues with granting such stipulation, and that the court would accommodate THE PARTIES
23   with their request;
24           WHEREAS, PLAINTIFF still needs to depose the BESSEMER Defendants’ PMQ prior

25   to the MSJ hearings;
26           WHEREAS        PLAINTIFF'S counsel (Ethan Ysais, Esq.) and counsel for the BESSEMER
27   Defendants (Marlys Braun, Esq.) met and conferred, and the BESSEMER Defendants graciously
28   agreed to a short continuance of at least thirty (30) days, but no more than sixty (60) days, of



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     JOINT STIPULATION TO CONTINUE        MSJ, TRIAL, AND TRIAL-RELATED DATES; [PROPOSED] ORDER