On August 18, 2020 a
Stipulation & Order filed - To Continue Trial and All Related Deadlines
was filed
involving a dispute between
Dennis-Hill, Donna Lynn,
Hill Iii, Charles Anthony,
and
Does 1-10,
Zuniga, Antonio,
for Personal Injury Motor Vehicle Unlimited
in the District Court of San Bernardino County.
Preview
V x.
ELECTRONICALLY RECEIVED - 1/1 6/2024 4:03 PM -
By: Gilberto Villegas, DEPUTY
William O. Woodland, Esq., Bar No. 175103
FORD, WALKER, HAGGERTY & BEHAR
One World Trade Center
Twenty-Seventh Floor
F I L E
SUPERIOR COURT 0F CALIFORNIA
D
Long Beach, California 9083 1-2700 CSEMSS¢%A¥*95g%/~Tno.~o
" ~ * “'CT
(562) 983-2500
\OOO\lO\UI#UJN-—-
F EB 1 6 202k
Attorneys for Defendant,
ANTONIO ZUNIGA .
RY Monica Root. oouty
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
CHARLES ANTHONY HILL, III and DONNA ) Case No. CIVDSZOI6910
LYNN DENNIS-HILL, )
JUDGE DONALD ALVAREZ
Plaintiffs ’ i
DEPT. 823
)
vs. )
JOINT STIPULATION AND [P-RG'POSED‘I
)
ANTONIO ZUNIGA and DOES 1 through 10, )
ORDER T0 CONTINUE TRIAL AND ALL
)
RELATED DEADLINES
Defendants. ) _ .
Action Fllcd: August 18, 2020
)
Trial: March 11, 2024
NNNNNNNNNflv—r—nr—a—u—n—w—H
WQQMAWN—OVOmQQM$WN—o
Plaintiffs Charles Anthony Hill, III and Donna Lynn Dennis-Hill, by and through their attorneys
of record, and Defendant Antonio Zuniga, by and through his attorney of record, hereby stipulate to the
following:
WHEREAS, the trial date in this matter is currently set for March 1 1, 2024, and the Trial
Readiness Conference for March 7, 2024;
WHEREAS, the Complaint in this matter was filed on August 18, 2020;
WHEREAS, responses by Defendant to any discovery in this matter was stayed by the Court on
March 3, 2021, until the resolution of the criminal proceedings arising out of the subject incident;
JOINT STIPULKTION AND [PROPOSED] ORDER TO CONTINUE TRIAL AND AIL RELATED
DEADLINES
WHEREAS, the criminal matter remains pending disputed, and unresolved with the next hearing
date in that matter presently set for March 2 l , 2024, resulting in a further continuance of the stay past the
current trial date;
WHEREAS, Defendant intends to file a Summary Judgment Motion to be adjudicated prior to
and barred from doing so under the terms of the discovery stay;
OOOQOLIIQWNh‘
trial is
WHEREAS, Plaintiffs' ability to conduct any discovery as it directly relates to Defendant has
been delayed due to the Court's stay, and as a result, Plaintiffs will be prejudiced because ofthe impending
fact discovery deadlines;
WHEREAS, the parties ability to conduct expert discovery is affected by thc discovery stay;
WHEREAS, the parties agree that continuing the trial in this action would facilitate discovery,
settlement discussions, and avoid the unnecessary expenditure ofjudicial resources should a resolution be
reached;
WHEREAS, the parties have met and conferred in light of their respective counsel's trial calendars
and have agreed to continue trial by 150 days, or a datc shortly thereafter;
WHEREAS, the parties have agreed that all pre-trial deadlines will be governed by the new trial
date.
///
///
NNNNNNNNN—u—n—nw—fl—fl——
WNQM#WN_OOW\IQMAMN_C
///
JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE TRIAL AND ALL RELATED
DEADLINES
Document Filed Date
February 16, 2024
Case Filing Date
August 18, 2020
Category
Personal Injury Motor Vehicle Unlimited
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
V x. ELECTRONICALLY RECEIVED - 1/1 6/2024 4:03 PM - By: Gilberto Villegas, DEPUTY William O. Woodland, Esq., Bar No. 175103 FORD, WALKER, HAGGERTY & BEHAR One World Trade Center Twenty-Seventh Floor F I L E SUPERIOR COURT 0F CALIFORNIA D Long Beach, California 9083 1-2700 CSEMSS¢%A¥*95g%/~Tno.~o " ~ * “'CT (562) 983-2500 \OOO\lO\UI#UJN-—- F EB 1 6 202k Attorneys for Defendant, ANTONIO ZUNIGA . RY Monica Root. oouty SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO CHARLES ANTHONY HILL, III and DONNA ) Case No. CIVDSZOI6910 LYNN DENNIS-HILL, ) JUDGE DONALD ALVAREZ Plaintiffs ’ i DEPT. 823 ) vs. ) JOINT STIPULATION AND [P-RG'POSED‘I ) ANTONIO ZUNIGA and DOES 1 through 10, ) ORDER T0 CONTINUE TRIAL AND ALL ) RELATED DEADLINES Defendants. ) _ . Action Fllcd: August 18, 2020 ) Trial: March 11, 2024 NNNNNNNNNflv—r—nr—a—u—n—w—H WQQMAWN—OVOmQQM$WN—o Plaintiffs Charles Anthony Hill, III and Donna Lynn Dennis-Hill, by and through their attorneys of record, and Defendant Antonio Zuniga, by and through his attorney of record, hereby stipulate to the following: WHEREAS, the trial date in this matter is currently set for March 1 1, 2024, and the Trial Readiness Conference for March 7, 2024; WHEREAS, the Complaint in this matter was filed on August 18, 2020; WHEREAS, responses by Defendant to any discovery in this matter was stayed by the Court on March 3, 2021, until the resolution of the criminal proceedings arising out of the subject incident; JOINT STIPULKTION AND [PROPOSED] ORDER TO CONTINUE TRIAL AND AIL RELATED DEADLINES WHEREAS, the criminal matter remains pending disputed, and unresolved with the next hearing date in that matter presently set for March 2 l , 2024, resulting in a further continuance of the stay past the current trial date; WHEREAS, Defendant intends to file a Summary Judgment Motion to be adjudicated prior to and barred from doing so under the terms of the discovery stay; OOOQOLIIQWNh‘ trial is WHEREAS, Plaintiffs' ability to conduct any discovery as it directly relates to Defendant has been delayed due to the Court's stay, and as a result, Plaintiffs will be prejudiced because ofthe impending fact discovery deadlines; WHEREAS, the parties ability to conduct expert discovery is affected by thc discovery stay; WHEREAS, the parties agree that continuing the trial in this action would facilitate discovery, settlement discussions, and avoid the unnecessary expenditure ofjudicial resources should a resolution be reached; WHEREAS, the parties have met and conferred in light of their respective counsel's trial calendars and have agreed to continue trial by 150 days, or a datc shortly thereafter; WHEREAS, the parties have agreed that all pre-trial deadlines will be governed by the new trial date. /// /// NNNNNNNNN—u—n—nw—fl—fl—— WNQM#WN_OOW\IQMAMN_C /// JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE TRIAL AND ALL RELATED DEADLINES