On January 31, 2013 a
Stipulation,Agreement
was filed
involving a dispute between
Investment Concepts Inc,
Summerridge 121 Lp,
Perez, Lorena Ann,
and
Investment Concepts Inc,
Liberty Landscaping, Inc,
Summerridge 121 Lp,
for PI personal injury not MV
in the District Court of San Bernardino County.
Preview
r
i
S 1
i
t1wj FS M 6 Fb
FILED
1 LEWIS BRISBOIS BISGAARD SMITH LLr
SUPERIOR COURT
JAMES C PACKER SB 77675 SAN B
C RNARDNNO DS CT
R
2 Mail
E com
packer@lbbslaw
FEB 18 2014
650 East Hospitality Lane Suite 600
3 San Bernardino California 92408
Y
1130
387
909
Telephone
4 1138
387
909
Facsimile DEPl1TY
5 Attorneys for Defendants
complainants
cross
SUMMERRIDGE 121 LP dba SUMMER
6 RIDGE APARTMENTS and 1NVESTMENT
CONCEPTS
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF SAN BERNARDINO
10 LORENA ANN PEREZ CASE NO CIWS 1300296
1
Plaintiff STIPULATION TO CONTINUE
HEARING DATE ON MOTION TO
vs COMPEL FURTHER RESPONSES OF
m a PLAINTIFF LORENA ANN PEREZ TO
SUMMER RIDGE APARTMENTS SPECIAL INTERROGATORIES SET
al ONE 1ORDER
et
15
Defendants Date March 19 2014
16 Time 8
30 m
a b
j
Dept D
S31
17 AND RELATED CROSS
ACTIONS
Trial Date None Set
18
19 IT IS HEREBY STIPULATED by and between the arties hereto through their respective
20 counsel of record that the hearing on calendar in the above matter shall be continued
21 WHEREAS Defendants SUMMERRIDGE 121 LP dba SUMMER RIDGE
22 APARTMENTS and INVESTMENT CONCEPTS Motion to Compel Further Responses of
23 Plaintiff Lorena Ann Perez to Special Interrogatories Set One currently on calendar for February
24 19 2014 at 8
30 a
m in Department D
S31 of the San Bernardino Superior Court located at 303
25 W 3 Street San Bernardino California 92415
26 WHEREAS parties are making efforts to resolve this discovery dispute outside the Court
27 IT IS HEREBY STIPULATED by and between the parties through their attorneys of
2g records as follows
LEWIS
1
6216
5229
4811
BRISBOIS
STIPULATION TO CONTINUE l
IOTION TO COMPEL PLAINTIFF
SFURTHER RESPONSES TO SPECIAL
B
AIIORNE15A INTERROGATORIES SET ONE PROPOSED ORDER
r
1 The parties agree and request that the Motion to Compel Further Responses of Plaintiff
2 Lorena Ann Perez to Special Interrogatories Set One presently scheduled for February 19 2014
3 BE CONTINUED to March 19 2014 or a date and time that is agreeable to the court
4 All deadlines to file oppositions and replies shall be moved to correspond with the new
5 hearing date
6 This stipulation may be signed in counterparts and a facsimile signature may be accepted
7 as an original
8 IT IS SO STIPULATED
9
10 DATED February 2014 Respectfully submitted
11
JIM SIEPLER
BANAFSHEH DANESH JAVID PC
12
13
14 By
Jim Sieplier
15
Attorneys for Plaintiff
LORENA ANN PEREZ
16
17
DATED February 2014 Respectfully submitted
ig
19 JAMES C PACKER
LEWIS BRISBOIS BISGAARD SMITH Lr
P
20
21
a
22 By
James C Packer
23 Attorneys for Defendants
SUMMERRIDGE 121 LP dba SUMMER RIDGE
24
APARTMENTS and INVESTMENT CONCEPTS
25
26
27
28
LEWIS
BRISBOIS 2
BISGAARD STIPULATION TO CONTINUE MOTION TO COMPEL PLAINTIFF
S FURTHER RESPONSES TO SPECIAL
An
oaN INTERROGATORIES SET ONE PROPOSED ORDER
Document Filed Date
February 18, 2014
Case Filing Date
January 31, 2013
Category
PI personal injury not MV
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r i S 1 i t1wj FS M 6 Fb FILED 1 LEWIS BRISBOIS BISGAARD SMITH LLr SUPERIOR COURT JAMES C PACKER SB 77675 SAN B C RNARDNNO DS CT R 2 Mail E com packer@lbbslaw FEB 18 2014 650 East Hospitality Lane Suite 600 3 San Bernardino California 92408 Y 1130 387 909 Telephone 4 1138 387 909 Facsimile DEPl1TY 5 Attorneys for Defendants complainants cross SUMMERRIDGE 121 LP dba SUMMER 6 RIDGE APARTMENTS and 1NVESTMENT CONCEPTS 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF SAN BERNARDINO 10 LORENA ANN PEREZ CASE NO CIWS 1300296 1 Plaintiff STIPULATION TO CONTINUE HEARING DATE ON MOTION TO vs COMPEL FURTHER RESPONSES OF m a PLAINTIFF LORENA ANN PEREZ TO SUMMER RIDGE APARTMENTS SPECIAL INTERROGATORIES SET al ONE 1ORDER et 15 Defendants Date March 19 2014 16 Time 8 30 m a b j Dept D S31 17 AND RELATED CROSS ACTIONS Trial Date None Set 18 19 IT IS HEREBY STIPULATED by and between the arties hereto through their respective 20 counsel of record that the hearing on calendar in the above matter shall be continued 21 WHEREAS Defendants SUMMERRIDGE 121 LP dba SUMMER RIDGE 22 APARTMENTS and INVESTMENT CONCEPTS Motion to Compel Further Responses of 23 Plaintiff Lorena Ann Perez to Special Interrogatories Set One currently on calendar for February 24 19 2014 at 8 30 a m in Department D S31 of the San Bernardino Superior Court located at 303 25 W 3 Street San Bernardino California 92415 26 WHEREAS parties are making efforts to resolve this discovery dispute outside the Court 27 IT IS HEREBY STIPULATED by and between the parties through their attorneys of 2g records as follows LEWIS 1 6216 5229 4811 BRISBOIS STIPULATION TO CONTINUE l IOTION TO COMPEL PLAINTIFF SFURTHER RESPONSES TO SPECIAL B AIIORNE15A INTERROGATORIES SET ONE PROPOSED ORDER r 1 The parties agree and request that the Motion to Compel Further Responses of Plaintiff 2 Lorena Ann Perez to Special Interrogatories Set One presently scheduled for February 19 2014 3 BE CONTINUED to March 19 2014 or a date and time that is agreeable to the court 4 All deadlines to file oppositions and replies shall be moved to correspond with the new 5 hearing date 6 This stipulation may be signed in counterparts and a facsimile signature may be accepted 7 as an original 8 IT IS SO STIPULATED 9 10 DATED February 2014 Respectfully submitted 11 JIM SIEPLER BANAFSHEH DANESH JAVID PC 12 13 14 By Jim Sieplier 15 Attorneys for Plaintiff LORENA ANN PEREZ 16 17 DATED February 2014 Respectfully submitted ig 19 JAMES C PACKER LEWIS BRISBOIS BISGAARD SMITH Lr P 20 21 a 22 By James C Packer 23 Attorneys for Defendants SUMMERRIDGE 121 LP dba SUMMER RIDGE 24 APARTMENTS and INVESTMENT CONCEPTS 25 26 27 28 LEWIS BRISBOIS 2 BISGAARD STIPULATION TO CONTINUE MOTION TO COMPEL PLAINTIFF S FURTHER RESPONSES TO SPECIAL An oaN INTERROGATORIES SET ONE PROPOSED ORDER