On March 30, 2021 a
Stipulation,Agreement
was filed
involving a dispute between
Delgadillo, Sandra Martinez,
and
Cardenas Markets Llc,
Cardenas Markets, Llc,
Does 1 Through 50,
for Other PI/PD/WD Unlimited
in the District Court of San Bernardino County.
Preview
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. '
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. ORIGINAL
DANISH] SHEA RAVIPUDI LLP I
ROBERT S. GLASSMAN, State Bar No. 269816
rglassman@psbr.law
ERIKA CONTRERAS, Bar N0. 260230
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11111 Santa Monica Boulevard, Suite 700
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Telephone: 3 1 0.477. 1700
Facsimile: 3 1 0.477. 1 699
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M LAW GROUP, LLP
-R| BY: Deputy
Matthew Smite,
JASON MARTINEZ, State Bar No. 302684
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jmartz'nez@rmlawgroupllp. com
151 11 Whittier Boulevard, Suite 3 1 0
Whittier, California 90603
Telephone: 562.693.2032
HP
Attorneys for Plaintiff
RAVIPUDI'
SUPERIOR COURT 0F THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO
1 BY FAX
BOYLE
SANDRA MARTINEZ DELGADILLO, an Case N0. CIVSB2108997
I psbriawmm
individual, Assigned for A11 Purposes to:
Hon. Tony Raphael, Dept. R17
Plaintiff,
SHEA
STIPULATION OF THE PARTIES
I v.
CARDENAS MARKETS, LLC, a limited Action Filed: March 30, 2021
PANISH company, and DOES through 50,
liability 1 Trial Date: March 4, 2024
inclusive,
Defendant.
IT IS HEREBY STIPULATED by the parties as follows:
1. On August 8, 2019 Plaintiff Sandra Martinez Delgadillo was injured when she
slipped and fell at a Cardenas Markets grocery store.
2. Defendant Cardenas Markets admits its negligence cauged Plaintiff to fall;
3. N0 other person, party or entity was negligent or responsible fdr the August 8, 2019
incident.
4. As a result of the August 8, 20 1 9 incident, Plaintiff Sandra Martinez Delgadillo
STIPULATION OF THE PARTIES
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underwent an emergency two level cervical fusion at C4-5 and C5-6.
5. Defendant Cardenas Markets does not dispute that the August 8, 20219 incident
caused the need for the surgery August 8, 2019.
6. The cost for the August 8, 2019 surgery and all related hospital care was
$ 1 5,681 .53. Plaintiff and Defendant Cardenas Markets stipulate to this amount.
7. The only issue to be determined at trial is the nature and extent of the injuries and
damages to Plaintiff Sandra Maninez Delgadillo arising out 0f or related to the August 8, 2019
OOOQO
incident in excess of the $15,681 .53 cost for the August 8, 2019 surgery and all related hospital
care.
UP
10
RAVIPUDI 11 DATED: February 27, 2024 PANISH SHEA RAVIPUDI LLP
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12
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BOYLE
psbrlaw.com
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14
By=
Erika
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Commas
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Attorneys for Plaintiff
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SHEA
16
DATED: February 27, 2024 DUNBAR & ASSOCIATES
I 17
PANISH 18
By=
19
Demfii
evin Dunbar
2O
Attorneys for Defendant
21
22
23
24
25
26
27
28
2
STIPULATION OF THE PARTlES
Document Filed Date
February 28, 2024
Case Filing Date
March 30, 2021
Category
Other PI/PD/WD Unlimited
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‘ . ' ' . ORIGINAL DANISH] SHEA RAVIPUDI LLP I ROBERT S. GLASSMAN, State Bar No. 269816 rglassman@psbr.law ERIKA CONTRERAS, Bar N0. 260230 g: i , E [3 State SUPERIQR mfg? OF mmflmqm econtreraS@PSbr- 10W caegre’rv OF BERNARDem ‘ 11111 Santa Monica Boulevard, Suite 700 A Los Angeles, California 90025 FEB 2 8 2&2}; Telephone: 3 1 0.477. 1700 Facsimile: 3 1 0.477. 1 699 i ”,5’“ ”WM“ i " (:EL-wwawm M LAW GROUP, LLP -R| BY: Deputy Matthew Smite, JASON MARTINEZ, State Bar No. 302684 \OOOQQUI jmartz'nez@rmlawgroupllp. com 151 11 Whittier Boulevard, Suite 3 1 0 Whittier, California 90603 Telephone: 562.693.2032 HP Attorneys for Plaintiff RAVIPUDI' SUPERIOR COURT 0F THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO 1 BY FAX BOYLE SANDRA MARTINEZ DELGADILLO, an Case N0. CIVSB2108997 I psbriawmm individual, Assigned for A11 Purposes to: Hon. Tony Raphael, Dept. R17 Plaintiff, SHEA STIPULATION OF THE PARTIES I v. CARDENAS MARKETS, LLC, a limited Action Filed: March 30, 2021 PANISH company, and DOES through 50, liability 1 Trial Date: March 4, 2024 inclusive, Defendant. IT IS HEREBY STIPULATED by the parties as follows: 1. On August 8, 2019 Plaintiff Sandra Martinez Delgadillo was injured when she slipped and fell at a Cardenas Markets grocery store. 2. Defendant Cardenas Markets admits its negligence cauged Plaintiff to fall; 3. N0 other person, party or entity was negligent or responsible fdr the August 8, 2019 incident. 4. As a result of the August 8, 20 1 9 incident, Plaintiff Sandra Martinez Delgadillo STIPULATION OF THE PARTIES g h v underwent an emergency two level cervical fusion at C4-5 and C5-6. 5. Defendant Cardenas Markets does not dispute that the August 8, 20219 incident caused the need for the surgery August 8, 2019. 6. The cost for the August 8, 2019 surgery and all related hospital care was $ 1 5,681 .53. Plaintiff and Defendant Cardenas Markets stipulate to this amount. 7. The only issue to be determined at trial is the nature and extent of the injuries and damages to Plaintiff Sandra Maninez Delgadillo arising out 0f or related to the August 8, 2019 OOOQO incident in excess of the $15,681 .53 cost for the August 8, 2019 surgery and all related hospital care. UP 10 RAVIPUDI 11 DATED: February 27, 2024 PANISH SHEA RAVIPUDI LLP I | 12 l BOYLE psbrlaw.com 13 14 By= Erika 8 O: Commas ”g: ~ I 15 Attorneys for Plaintiff W SHEA 16 DATED: February 27, 2024 DUNBAR & ASSOCIATES I 17 PANISH 18 By= 19 Demfii evin Dunbar 2O Attorneys for Defendant 21 22 23 24 25 26 27 28 2 STIPULATION OF THE PARTlES