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(SPACE BELOW FOR FILING STAMP ONLY)
1 SHAVER, KORFF & CASTRONOVO LLP
16255 Ventura Boulevard, Suite 850
2 Encino, California 91436
Phone: (818) 905-6001 / Fax: (818) 905-6004
3
4 THOMAS W. SHAVER, STATE BAR NO. 67506
LILIT MKRTCHYAN, STATE BAR NO. 328434
5
Defendant/Cross-Complainant ERIC SERTIC
6 Attorneys for
7
8
9 SUPERIOR COURT OF CALIFORNIA
10 COUNTY OF KERN
11
NO. BCV-19-103330 JEB lead
ERIC SERTIC,
12 [consolidated with
BCV-20-102977 DRL and BCV-21-101449]
Plaintiffs,
13
[Hon. David R. Zulfa, Div. J]
v.
14
NOE GARCIA, an individual; LAURA
15 STIPULATION TO CONTINUE THE
GUIDO, an individual dba D&L TRIAL, FINAL STATUS
TRUCKING, and DOES 1 -20
16 CONFERENCE, AND RELATED
MOTION/DISCOVERY DATES;
Defendants.
17 [PROPOSED] ORDER
__________________________________
18 AND ALL RELATED ACTIONS. Trial Date: 3/11/24
19 Complaint Filed: 2/4/21
Location: 1800 30th St. 4th Floor
20 Bakersfield, CA 93301
21 TO THE COURT:
22
23 PLEASE BE ADVISED that the parties hereby stipulate that the trial date set for March 11,
24 2024, at 8:30 a.m., in Division J of the above entitled court be continued to October 7, 2024 at 9:30
25 a.m., or to such a date and time as the court deems appropriate ______________________, 2024
26 at 8:30 a.m., the Final Status Conference from March 8, 2024 at 1:30 p.m. to October 1, 2024 at 1:30
27 p.m., or to a date as the court deems appropriate __________________________, 2024, at 1:30
28
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Moss\plds\STIP 2 CONTINUE STIPULATION TO CONTINUE THE TRIAL, FINAL STATUS CONFERENCE AND RELATED MOTION/DISCOVERY DATES;
THE TRIAL #2.wpd [PROPOSED] ORDER
p.m., and that all discovery and motion cut-off dates be based on the new trial date.
2 REASON FOR CONTINUANCE: Pending criminal trial presently set for June IO, 2024.
3 This stipulation may be executed in counterparts.
4
DATED: January 23, 2024
5
6
By:
7 Ned Defnphy _
Attorneys for Plain I fs (BROOKL]:N DEANN
8 MOSS, by and through her-Gti-a:rtl1an Ad Litem
GREGORY HOLDER, LEVI COLE MOSS, and
9 AIDEN LEE MOSS
10
11
DATED: January 23, 2024 LAW OFFICES OF JUSTIN T. LOWTRIP
12
13
By
14 Ju=sr=IN=r~.~L=o=w=r=ru=p..-- - - -- - - -
Attomeys for DefondantS/Cross-Complainants/Cross-
15 Defendants LAURA GUIDO and NOE GARCIA
AND D&L TRUCKING DOE 1
16
17
18 DATED: January 23, 2024 SWEET JAMES, LLP
19
20 By
AS""'HKAHN==-"'-==~M~O'""'H.,,...A,....,,MAD-=--~1- - - -- --
21 Attorneys for Plaintiff ERIC SERTIC
Related Case No. BCV-19-103330
22
23
DATED: January 23, 2024 SHAVER, KORFF & CASTRONOVO LLP
24
25
By
26 TH"""o=MA~S~w-.-=sHA
~ -=--v=E=R--- - -- - -
Attorneys for Defendant/Cross-Complainant ERlC
27 SERTIC
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N:\W\TWS\MC\1370
Moss\plds\STIP 2 CONTINUE
STIPULATION TO CONTINUE THE TRIAL, FL'IAL STATUS CONFERENCE AND RELATED MOTION/DISCOVERY DATES;
THE TRIAL.wpd !PROPOSED] ORDER
1 p.m., and that all discovery and motion cut-off dates be based on the new trial date.
2 REASON FOR CONTINUANCE: Pending criminal trial presently set for June 10, 2024.
3 This stipulation may be executed in counterparts.
4
DATED: January 23, 2024 YOUNG WOOLDRIDGE LLP
5
6
By:
7 Ned Dunphy
Attorneys for Plaintiffs BROOKLYN DEANN
8 MOSS, by and through her Guardian Ad Litem
GREGORY HOLDER, LEVI COLE MOSS, and
9 AIDEN LEE MOSS
10
11
DATED: January 23, 2024 LAW OFFICES OF JUSTIN T. LOWTRIP
12
13
By
14 Ju·~
sT=IN=-c-;T=.~L~o=w
= T=
R=IPc----- - - - - - -
Attomeys for Defendants/Cross-Complainants/Cross-
15 Defendants LAURA GUIDO and NO E GARCIA
AND D&L TRUCKING DOE 1
16
17
18 DATED: January 23, 2024 SWEET JAMES, LLP
19
20 By
AS=H=KAHNc--,--c
c=-=--=-M"="'O~HAMAD---I-- - - -- - -
21 Attomeys for Plaintiff ERIC SERTIC
Related Case No. BCV-19-103330
22
23
DATED: January 23, 2024 SHAVER, KORFF & CASTRONOVO LLP
24
25
By
26 TH""""O,-c-MA
---=--,-S=-=
w-=-.~s=H~A~V=E=R- - - -- - -- -
Attomeys for Defendant/Cross-Complainant ERIC
27 SERTIC
28
2
N:IWITWSIMC\1370
Mosslplds\STIP 2 CONTINUE
STIPULATION TO CONTINUE THE TRIAL, FINAL STATUS CONFERENCE AND RELATED MOTION/DISCOVERY DATES;
THE TRIAL.wpd [PROPOSED] ORDER
1 p.m., and that all discovery and motion cut-off dates be based on the new trial date.
2 REASON FOR CONTINUANCE: Pending criminal trial presently set for June 10, 2024.
3 This stipulation may be executed in counterparts.
4
DATED: January 23, 2024 YOUNG WOOLDRIDGE LLP
5
6
By:
7 Ned Dunphy
Attorneys for Plaintiffs BROOKLYN DEANN
8 MOSS, by and through her Guardian Ad Litem
GREGORY HOLDER, LEVI COLE MOSS, and
9 AIDEN LEE MOSS
10
11
DATED: January 23, 2024 LAW OFFICES OF JUSTIN T. LOWTRIP
12
13
By
JU~ST
~
. IN~T-_~LO~W_TRIP
_ _ __ __ _ __ _
14
Attorneys for Defendants/Cross-Complainants/Cross-
15 Defendants LAURA GUIDO and NOE GARCIA
AND D&L TRUCKING DOE 1
16
17
18 DATED: January 23, 2024 SWEET JAMES, LLP
19
20 ByA~J,;1e~-
ASHKAHN MOHAMAD I
21 Attorneys for Plaintiff ERIC SERTIC
Related Case No. BCV-19-103330
22
23
DATED: January 23, 2024 SHAVER, KORFF & CASTRONOVO LLP
24
25
By
26 TH"""o=MA
...,,..,..=-
s =w=-.~s=HA~·~V~E=R~ - -- - - - - -
Attorneys for Defendant/Cross-Complainant ERIC
27 SERTIC
28
2
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Moss\plds\STIP 2 CONTINUE STIPULATION TO CONTINUE THE TRIAL, FINAL STATUS CONFERENCE AND RELATED MOTION/DISCOVERY DATES;
THE TRIALwpd [PROPOSED] ORDER
1 ORDER
2 IT IS HEREBY ORDERED that trial in the above matter is continued from March 11,
3 2024 at 9:30 a.m. to October 7, 2024, at 9:30 a.m., or to a date and a time the court deems
4 appropriate______________________________, 2024, at 8:30 a.m., and the Final Status
5 Conference from March 8, 2024 at 1:30 p.m. to October 1, 2024 at 1:30 p.m. or to a date as the
6 court deems appropriate ______________________________________________________,
7 2024, at 10:00 a.m., and the Mandatory Settlement Conference from February 9, 2024 at 11:00
8 a.m. in Division H, or to a date and time as the court deems appropriate
9 _________________________________________________, and that all discovery and motion
10 cut-off dates will be based on the new trial date.
11
12 ____________________________________
13 JUDGE OF THE SUPERIOR COURT
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Moss\plds\STIP 2 CONTINUE STIPULATION TO CONTINUE THE TRIAL, FINAL STATUS CONFERENCE AND RELATED MOTION/DISCOVERY DATES;
THE TRIAL #2.wpd [PROPOSED] ORDER
Preview
(SPACE BELOW FOR FILING STAMP ONLY) 1 SHAVER, KORFF & CASTRONOVO LLP 16255 Ventura Boulevard, Suite 850 2 Encino, California 91436 Phone: (818) 905-6001 / Fax: (818) 905-6004 3 4 THOMAS W. SHAVER, STATE BAR NO. 67506 LILIT MKRTCHYAN, STATE BAR NO. 328434 5 Defendant/Cross-Complainant ERIC SERTIC 6 Attorneys for 7 8 9 SUPERIOR COURT OF CALIFORNIA 10 COUNTY OF KERN 11 NO. BCV-19-103330 JEB lead ERIC SERTIC, 12 [consolidated with BCV-20-102977 DRL and BCV-21-101449] Plaintiffs, 13 [Hon. David R. Zulfa, Div. J] v. 14 NOE GARCIA, an individual; LAURA 15 STIPULATION TO CONTINUE THE GUIDO, an individual dba D&L TRIAL, FINAL STATUS TRUCKING, and DOES 1 -20 16 CONFERENCE, AND RELATED MOTION/DISCOVERY DATES; Defendants. 17 [PROPOSED] ORDER __________________________________ 18 AND ALL RELATED ACTIONS. Trial Date: 3/11/24 19 Complaint Filed: 2/4/21 Location: 1800 30th St. 4th Floor 20 Bakersfield, CA 93301 21 TO THE COURT: 22 23 PLEASE BE ADVISED that the parties hereby stipulate that the trial date set for March 11, 24 2024, at 8:30 a.m., in Division J of the above entitled court be continued to October 7, 2024 at 9:30 25 a.m., or to such a date and time as the court deems appropriate ______________________, 2024 26 at 8:30 a.m., the Final Status Conference from March 8, 2024 at 1:30 p.m. to October 1, 2024 at 1:30 27 p.m., or to a date as the court deems appropriate __________________________, 2024, at 1:30 28 1 N:\W \TWS\MC\1370 Moss\plds\STIP 2 CONTINUE STIPULATION TO CONTINUE THE TRIAL, FINAL STATUS CONFERENCE AND RELATED MOTION/DISCOVERY DATES; THE TRIAL #2.wpd [PROPOSED] ORDER p.m., and that all discovery and motion cut-off dates be based on the new trial date. 2 REASON FOR CONTINUANCE: Pending criminal trial presently set for June IO, 2024. 3 This stipulation may be executed in counterparts. 4 DATED: January 23, 2024 5 6 By: 7 Ned Defnphy _ Attorneys for Plain I fs (BROOKL]:N DEANN 8 MOSS, by and through her-Gti-a:rtl1an Ad Litem GREGORY HOLDER, LEVI COLE MOSS, and 9 AIDEN LEE MOSS 10 11 DATED: January 23, 2024 LAW OFFICES OF JUSTIN T. LOWTRIP 12 13 By 14 Ju=sr=IN=r~.~L=o=w=r=ru=p..-- - - -- - - - Attomeys for DefondantS/Cross-Complainants/Cross- 15 Defendants LAURA GUIDO and NOE GARCIA AND D&L TRUCKING DOE 1 16 17 18 DATED: January 23, 2024 SWEET JAMES, LLP 19 20 By AS""'HKAHN==-"'-==~M~O'""'H.,,...A,....,,MAD-=--~1- - - -- -- 21 Attorneys for Plaintiff ERIC SERTIC Related Case No. BCV-19-103330 22 23 DATED: January 23, 2024 SHAVER, KORFF & CASTRONOVO LLP 24 25 By 26 TH"""o=MA~S~w-.-=sHA ~ -=--v=E=R--- - -- - - Attorneys for Defendant/Cross-Complainant ERlC 27 SERTIC 28 2 N:\W\TWS\MC\1370 Moss\plds\STIP 2 CONTINUE STIPULATION TO CONTINUE THE TRIAL, FL'IAL STATUS CONFERENCE AND RELATED MOTION/DISCOVERY DATES; THE TRIAL.wpd !PROPOSED] ORDER 1 p.m., and that all discovery and motion cut-off dates be based on the new trial date. 2 REASON FOR CONTINUANCE: Pending criminal trial presently set for June 10, 2024. 3 This stipulation may be executed in counterparts. 4 DATED: January 23, 2024 YOUNG WOOLDRIDGE LLP 5 6 By: 7 Ned Dunphy Attorneys for Plaintiffs BROOKLYN DEANN 8 MOSS, by and through her Guardian Ad Litem GREGORY HOLDER, LEVI COLE MOSS, and 9 AIDEN LEE MOSS 10 11 DATED: January 23, 2024 LAW OFFICES OF JUSTIN T. LOWTRIP 12 13 By 14 Ju·~ sT=IN=-c-;T=.~L~o=w = T= R=IPc----- - - - - - - Attomeys for Defendants/Cross-Complainants/Cross- 15 Defendants LAURA GUIDO and NO E GARCIA AND D&L TRUCKING DOE 1 16 17 18 DATED: January 23, 2024 SWEET JAMES, LLP 19 20 By AS=H=KAHNc--,--c c=-=--=-M"="'O~HAMAD---I-- - - -- - - 21 Attomeys for Plaintiff ERIC SERTIC Related Case No. BCV-19-103330 22 23 DATED: January 23, 2024 SHAVER, KORFF & CASTRONOVO LLP 24 25 By 26 TH""""O,-c-MA ---=--,-S=-= w-=-.~s=H~A~V=E=R- - - -- - -- - Attomeys for Defendant/Cross-Complainant ERIC 27 SERTIC 28 2 N:IWITWSIMC\1370 Mosslplds\STIP 2 CONTINUE STIPULATION TO CONTINUE THE TRIAL, FINAL STATUS CONFERENCE AND RELATED MOTION/DISCOVERY DATES; THE TRIAL.wpd [PROPOSED] ORDER 1 p.m., and that all discovery and motion cut-off dates be based on the new trial date. 2 REASON FOR CONTINUANCE: Pending criminal trial presently set for June 10, 2024. 3 This stipulation may be executed in counterparts. 4 DATED: January 23, 2024 YOUNG WOOLDRIDGE LLP 5 6 By: 7 Ned Dunphy Attorneys for Plaintiffs BROOKLYN DEANN 8 MOSS, by and through her Guardian Ad Litem GREGORY HOLDER, LEVI COLE MOSS, and 9 AIDEN LEE MOSS 10 11 DATED: January 23, 2024 LAW OFFICES OF JUSTIN T. LOWTRIP 12 13 By JU~ST ~ . IN~T-_~LO~W_TRIP _ _ __ __ _ __ _ 14 Attorneys for Defendants/Cross-Complainants/Cross- 15 Defendants LAURA GUIDO and NOE GARCIA AND D&L TRUCKING DOE 1 16 17 18 DATED: January 23, 2024 SWEET JAMES, LLP 19 20 ByA~J,;1e~- ASHKAHN MOHAMAD I 21 Attorneys for Plaintiff ERIC SERTIC Related Case No. BCV-19-103330 22 23 DATED: January 23, 2024 SHAVER, KORFF & CASTRONOVO LLP 24 25 By 26 TH"""o=MA ...,,..,..=- s =w=-.~s=HA~·~V~E=R~ - -- - - - - - Attorneys for Defendant/Cross-Complainant ERIC 27 SERTIC 28 2 N:\W\TWS\MC\1370 Moss\plds\STIP 2 CONTINUE STIPULATION TO CONTINUE THE TRIAL, FINAL STATUS CONFERENCE AND RELATED MOTION/DISCOVERY DATES; THE TRIALwpd [PROPOSED] ORDER 1 ORDER 2 IT IS HEREBY ORDERED that trial in the above matter is continued from March 11, 3 2024 at 9:30 a.m. to October 7, 2024, at 9:30 a.m., or to a date and a time the court deems 4 appropriate______________________________, 2024, at 8:30 a.m., and the Final Status 5 Conference from March 8, 2024 at 1:30 p.m. to October 1, 2024 at 1:30 p.m. or to a date as the 6 court deems appropriate ______________________________________________________, 7 2024, at 10:00 a.m., and the Mandatory Settlement Conference from February 9, 2024 at 11:00 8 a.m. in Division H, or to a date and time as the court deems appropriate 9 _________________________________________________, and that all discovery and motion 10 cut-off dates will be based on the new trial date. 11 12 ____________________________________ 13 JUDGE OF THE SUPERIOR COURT 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 N:\W \TWS\MC\1370 Moss\plds\STIP 2 CONTINUE STIPULATION TO CONTINUE THE TRIAL, FINAL STATUS CONFERENCE AND RELATED MOTION/DISCOVERY DATES; THE TRIAL #2.wpd [PROPOSED] ORDER