On December 08, 2021 a
Stipulation,Agreement
was filed
involving a dispute between
Macias, Monique,
San Bernardino City Unified School District,
and
Ccs Contractors, Inc.,
Couts Heating And Cooling, Inc.,
Couts Heating & Cooling, Inc.,
Doe 1,
Doe 2,
Doe 3,
Doe 4,
Doe 5,
Doe 6,
Doe 7,
Doe 8,
Doe 9,
Does 11 To 100,
for Other PI/PD/WD Unlimited
in the District Court of San Bernardino County.
Preview
Todd A. Chamberlain (SBN 135623) F LED
I
MURCHISON 8. CUMMING, LLP SUPERIOR coumorcmmm“
801 South Grand Avenue, Ninth Floor CSOAPmSSAiAD’wERmDmo
Los Angeles, California 9001 7-4613 ° D'STR'CT
Telephone: (213) 623-7400
Facsimile: (213) 623-6336
AUG U g 2023
E-Mail tchamberlain@murchisonlaw.com ”
@mNOthN-i
Attorneys for Defendant .DOpuy
and Cross-Complainant.
CCS CONTRACTORS. INC.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO, CENTRAL DISTRICT
MONIQUE MACIAS, CASE NO. CIVSBZ133542
STIPULATION TO CONTINUE TRIAL
vs.
Plaintiff,
AND [PW] ORDER
Assigned to Hon. Michael A. Sachs.
COUTS HEATING AND COOLING, |NC., Dept. 828
a corporation; DOE 1, DOE 2, DOE 3,
DOE 4 and DOE 5. individually, and d/b/a Action Filed: December 8, 2021
COUTS HEATING AND COOLING; CCS Trial Date: October 16. 2023
CONTRACTORS, |NC., a corporation;
DOE 6, DOE 7, DOE 8, DOE 9, DOE 10, $10, (D
individually, and d/b/a CCS 9?
CONTRACTORS; and DOES 11 through SLJHWVUI
100, inclusive,
Defendants.
QNQCIIfiODN—KOOQKIOSUI-hwhiéo
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CCS CONTRACTORS, |NC.,
Cross-Complainant,
vs.
COUTS HEATING AND COOLING, |NC.,
ROES 1 TO 20,
a corporation, and
Inclusive,
Cross-Defendants.
TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
The Parties submit the following Stipulation and [Proposed] Order:
1
STIPULATION TO CONTINUE TRIAL AND [PROPOSED] ORDER
1. WHEREAS, the Court has set a Trial date in this matter for October 16, 2023
and a Trial Readiness Conference date for October 12, 2023; and
2. WHEREAS, Defendants need to conduct and complete discovery into
Plaintiff's claims, injuries and damages and obtain an independent medical examination(s)
@mNGm#wN-\
of the plaintiff, and file dispositive motion(s); and
3. WHEREAS, in addition to completing discovery, the Parties wish to explore
private mediation; and
4. WHEREAS, this is the first request for continuance of trial; and
5. WHEREAS, the Parties have agreed to a trial date certain (or as certain as
they can be pending the Court's calendar) that will provide the Parties the opportunity to
complete discovery, conduct a supplemental mediation(s).
NOW THEREFORE, IT IS HEREBY STIPULATED by and between Plaintiff,
MONIQUE MACIAS, Defendant and Cross-Complainant, CCS CONTRACTORS, INC.,
and Defendant and Cross-Defendant, COUTS HEATING AND COOLING, |NC., by and
through their respective counsel of record, that the current Trial Readiness Conference
date of October 12, 2023 be continued to April 11, 2024 and the Trial date October 16,
2023 be continued to April 15, 2024, or such other date thereafter as ordered by the Court.
It is hereby further stipulated that all other trial-related dates and deadlines shall be
NNNMNNNNNAAAAAAaaaa
mNmUI-th-KOOQNGUI#wN-AO
continued in accordance with the new trial date and pursuant to Code.
DATED: August 4, 2023
By:
Todd
@ ML
MURCHISON & CUMMING, LLP
A. Chamberlain
a
Attorneys for Defendant and Cross-
Complainant, CCS CONTRACTORS, INC.
2
STIPULATION TO CONTINUE TRIAL AND [PROPOSED] ORDER
Preview
Todd A. Chamberlain (SBN 135623) F LED I MURCHISON 8. CUMMING, LLP SUPERIOR coumorcmmm“ 801 South Grand Avenue, Ninth Floor CSOAPmSSAiAD’wERmDmo Los Angeles, California 9001 7-4613 ° D'STR'CT Telephone: (213) 623-7400 Facsimile: (213) 623-6336 AUG U g 2023 E-Mail tchamberlain@murchisonlaw.com ” @mNOthN-i Attorneys for Defendant .DOpuy and Cross-Complainant. CCS CONTRACTORS. INC. SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO, CENTRAL DISTRICT MONIQUE MACIAS, CASE NO. CIVSBZ133542 STIPULATION TO CONTINUE TRIAL vs. Plaintiff, AND [PW] ORDER Assigned to Hon. Michael A. Sachs. COUTS HEATING AND COOLING, |NC., Dept. 828 a corporation; DOE 1, DOE 2, DOE 3, DOE 4 and DOE 5. individually, and d/b/a Action Filed: December 8, 2021 COUTS HEATING AND COOLING; CCS Trial Date: October 16. 2023 CONTRACTORS, |NC., a corporation; DOE 6, DOE 7, DOE 8, DOE 9, DOE 10, $10, (D individually, and d/b/a CCS 9? CONTRACTORS; and DOES 11 through SLJHWVUI 100, inclusive, Defendants. QNQCIIfiODN—KOOQKIOSUI-hwhiéo NNNNNNNNNAAJaAAA‘AA CCS CONTRACTORS, |NC., Cross-Complainant, vs. COUTS HEATING AND COOLING, |NC., ROES 1 TO 20, a corporation, and Inclusive, Cross-Defendants. TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: The Parties submit the following Stipulation and [Proposed] Order: 1 STIPULATION TO CONTINUE TRIAL AND [PROPOSED] ORDER 1. WHEREAS, the Court has set a Trial date in this matter for October 16, 2023 and a Trial Readiness Conference date for October 12, 2023; and 2. WHEREAS, Defendants need to conduct and complete discovery into Plaintiff's claims, injuries and damages and obtain an independent medical examination(s) @mNGm#wN-\ of the plaintiff, and file dispositive motion(s); and 3. WHEREAS, in addition to completing discovery, the Parties wish to explore private mediation; and 4. WHEREAS, this is the first request for continuance of trial; and 5. WHEREAS, the Parties have agreed to a trial date certain (or as certain as they can be pending the Court's calendar) that will provide the Parties the opportunity to complete discovery, conduct a supplemental mediation(s). NOW THEREFORE, IT IS HEREBY STIPULATED by and between Plaintiff, MONIQUE MACIAS, Defendant and Cross-Complainant, CCS CONTRACTORS, INC., and Defendant and Cross-Defendant, COUTS HEATING AND COOLING, |NC., by and through their respective counsel of record, that the current Trial Readiness Conference date of October 12, 2023 be continued to April 11, 2024 and the Trial date October 16, 2023 be continued to April 15, 2024, or such other date thereafter as ordered by the Court. It is hereby further stipulated that all other trial-related dates and deadlines shall be NNNMNNNNNAAAAAAaaaa mNmUI-th-KOOQNGUI#wN-AO continued in accordance with the new trial date and pursuant to Code. DATED: August 4, 2023 By: Todd @ ML MURCHISON & CUMMING, LLP A. Chamberlain a Attorneys for Defendant and Cross- Complainant, CCS CONTRACTORS, INC. 2 STIPULATION TO CONTINUE TRIAL AND [PROPOSED] ORDER