Document for GILMORE VS JAKOV DULCICH AND SONS, LLC

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                                Frank Perez [SBN 205377]
     Cindy Panuco [SBN 266921]
     Heriberto Veliz [SBN 311591]
 2   PEREZ & PEREZ, APC
     1150 S. Olive Street, Suite 600
 3   Los Angeles, CA 90015
     Tel: (213) 745-6300
 4   Fax: (:21 J) '/4:i-6060
 5   Attorneys for Plaintiff,
     TRACY GILMORE
 6
 7
                               SUPERIOR COURT OF THE STATE OF CALIFORNIA
 8
                 COUNTY OF KERN - METROPOLITAN DIVISION JUSTICE BUILDING
 9
     TRACY GILMORE,                   )                                       Case No.:    BCV-22-101758
10
                                      )                                       Assigned to: Hon. Gregory Pulskamp
11                        Plaintiff,  )                                       Dept. No.: J
                V.                    )
12                                    )
     JAKOV DULCICH AND SONS, LLC; and )
13
     DOES I through 50, inclusive,    )                                       STIPULATION TO CONTINUE TRIAL,
14                                    )                                       FSC, MSC, AND ALL RELATED
                         Defendants.  )                                       MOTION/DISCOVERY DATES
15                                    )
16                                    )
                                      )
17   ___________)
18               TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

19             STIPULATION OF PARTIES TO CONTINUE THE TRIAL DATE AND MSC

70               WHEREAS the Parties hereto, through their respective attorneys ofrecord, hereby stipulat

21   that:

22               I. The Trial Date be continued from July 08, 2024, to November 04, 2024.

23               2. The Final Status Conference be continued from July 05, 2024, to October 31, 2024.

24               3. The Mandatory Settlement Conference be continued from June 07, 2024, to

25                    August 20, 2024.

26               4. Further, the Parties stipulate that the discovery cut-off and all other pre-trial deadline

27                    be continued pursuant to the new trial date, including expert witness related discovery

28
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             SI I l'lll.A I ION IO ('(IN I INlll! I1{I/\l., FS< , MS<'. Al'l/ll /\l.L IH l./\ l HI MO I ION/UIS( '0\111 I{\' LI/\ I !I'S
 1          5. WHEREAS Counsel for Defendant has been engaged in a separate trial sine
 2               November 20, 2023, and such trials have affected Defendant's Counsel's 2024 trial
 3               schedule.
 4          6. WHEREAS Plaintiffs underlying workers' compensation treatment has no
 5               concluded.
 6          7. WHEREAS despite the Parties' best-efforts discovery, including expert discovery, th
 7                Parties have not completed necessary discovery.
 8          8. WHEREAS this is only the parties' second (2nd) request for a trial continuance of th
 9               original trial date.
10          9. WHEREAS this request is being made in good faith as it will allow the parties to engag
11               in meaningful settlement discussions and complete the necessary remaining discovery.
12          IT IS HEREBY STIPULATED.
13   Dated: February 19, 2024                                            PEREZ & PEREZ, APC
14                                                                                             /
15
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                                                                               �ff
                                                                   By -------------
                                                                      Frank Perez
                                                                      Heriberto Veliz
17
                                                                      Attorneys for Plaintiff,
18                                                                    TRACY GILMORE

19   Dated: February 20, 2024                                            SKANE MILLS LLP
20
21                                                                                                          ---
                                                                 By:� -�----<1111111◄�.
22
                                                                 /Heather Mills
23                                                                  Jon Tarkowski
                                                                    Attorneys for Defendant,
24                                                                  JAKOV DULCICH AND SONS, LLC
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