Preview
Thomas R. Bradford. Esq., Bar No.: 110230
Vincent Contreras, Esq., Bar No.: 340132
Michael T. Gebreestifanos, Esq., Bar No. 345044
F
ggum oF D
PETERSON, BRADFORD. BURKWITz l L E
sup
GREGORIo, BURKWITz & su, LLP COEURhggYR CAupoawm
100 North First Street. Suite 300 RANCHo cuci%?§%§”$‘.5$m0
° R'CT
Burbank, California 91502
T: 818.562.5800 JAN 2 5 2024
@mVO’m-fiwwfi F: 818.562.5810
'
BY
9. f)
Attorneys for Defendant, M. ISHAN KAYALI, D.D.S.
CUAUHTEMOG , Epuw
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO - CIVIL DIVISION
ROBERT JONES Case No.: CIVSBZZ1 1046 ‘TON 3 Rkfi-HKQ
Assigned to the Honorable: Jaaet-Mrfiang’re
LLP
Plaintiff, .[Dopk—SQQ} __\ ’\ R
BURKWITZ.
300
vs. JOINT STIPULATION T0 CONTINUE TRIAL AND
SU.
Suite
91502 ALL DISCOVERY AND TRIAL-RELATED CUT-OFF
& MAHER AZZAWI, DDS; M. IHSAN KAYALI, DDS; and DATES; [PROPOSED] ORDER
DOES 1 through 10, inclusive,
818.562.5800
Street,
California
BURKWITZ
BRADFORD.
Defendants. Trial: February 5, 2024
First
Complaint Filed: June 2, 2022
Telephone
Burbank.
North
GREGORIO.
PETERSON.
100
IT IS HEREBY STIPULATED between Plaintiff, ROBERT JONES, and Defendant, M. ISHAN KAYALI,
D.D.S... by and through their attorneys of record. to continue the trial presently scheduled to commence on
NNNNNNNNN-AAA—xé—n—aéfig
mNQm§w~AC®mN®thN—IO
February 5, 2024, for approximately 60 days, to April 5, 2024, or to the first available date shortly thereafter
convenient for the Court and all counsel.
Good cause exists to continue the presently scheduled trial date as the parties need additional time to
conduct the necessary discovery to sufficiently litigate the matter. scheduling conflicts of counsel in unrelated
matters, and procedural delays in getting this matter at issue. No party will be prejudiced by the continuance.
IT IS FURTHER AGREED AND STIPULATED by and among the parties herein and their counsel of
record that all other dates, including, but not limited to, all statutory cut-off dates (e.g., discovery cut-off date,
motion cut-off date. and expert exchange date), also be continued and made contingent upon the requested
trial continuance.
1
JOINT STIPULATION T0 CONTINUE TRIAL AND ALL DISCOVERY AND TRIAL RELATED CUT-OFF
DATES; [PROPOSED] ORDER
IT IS FURTHER AGREED AND STIPULATED that this document may be executed in counterparts
and exchanged via fax or email and all parts or copies shall constitute the agreement among the parties and
their counsel.
PETERSON, BRADFORD, BURKWITZ,
(Dmflamkwm—l
DATED: December 13 2023
,
GREGORIO, BURKWITZ & SU, LLP
By:
Thomas
WWW¢R. Bradfo‘fd, Esq.
Vincent Contreras. Esq.
Michael T. Gebreestifanos, Esq.
Attorne sforDefendant,
M. ISH N KAYALI, D.D.S.
December
LLP
300 Koo LAW’APC
BURKWITZ.
SU,
91502
DATEnzmm 12 .2023
Suite
&
818.562.5800
59W fl?
Street.
California
BURKWITZ
BRADFORD,
By:
First
Sonny HFKOO Esq.
Attorneys for
Telephone
Burbank,
Plaintiff.
North
GREGORIO.
ROBERT JONES
PETERSON.
100 NNNNNNNNNAAA-L—xé-a—x-x-x
Law Office °f Jerry S' Ak'ta
mVGm-FWNAOCOmNQm#mN—‘O
DATED: November .2023
By:
Jerry S. Akita, Esq.
Attorneys for Co-Defendant,
MAHER AZZAWI, D.D.S.
2
JOINT STIPULATION TO CONTINUE TRIAL AND ALL DISCOVERY AND TRIAL RELATED CUT-OFF
DATES; [PROPOSED] ORDER
Preview
Thomas R. Bradford. Esq., Bar No.: 110230 Vincent Contreras, Esq., Bar No.: 340132 Michael T. Gebreestifanos, Esq., Bar No. 345044 F ggum oF D PETERSON, BRADFORD. BURKWITz l L E sup GREGORIo, BURKWITz & su, LLP COEURhggYR CAupoawm 100 North First Street. Suite 300 RANCHo cuci%?§%§”$‘.5$m0 ° R'CT Burbank, California 91502 T: 818.562.5800 JAN 2 5 2024 @mVO’m-fiwwfi F: 818.562.5810 ' BY 9. f) Attorneys for Defendant, M. ISHAN KAYALI, D.D.S. CUAUHTEMOG , Epuw SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO - CIVIL DIVISION ROBERT JONES Case No.: CIVSBZZ1 1046 ‘TON 3 Rkfi-HKQ Assigned to the Honorable: Jaaet-Mrfiang’re LLP Plaintiff, .[Dopk—SQQ} __\ ’\ R BURKWITZ. 300 vs. JOINT STIPULATION T0 CONTINUE TRIAL AND SU. Suite 91502 ALL DISCOVERY AND TRIAL-RELATED CUT-OFF & MAHER AZZAWI, DDS; M. IHSAN KAYALI, DDS; and DATES; [PROPOSED] ORDER DOES 1 through 10, inclusive, 818.562.5800 Street, California BURKWITZ BRADFORD. Defendants. Trial: February 5, 2024 First Complaint Filed: June 2, 2022 Telephone Burbank. North GREGORIO. PETERSON. 100 IT IS HEREBY STIPULATED between Plaintiff, ROBERT JONES, and Defendant, M. ISHAN KAYALI, D.D.S... by and through their attorneys of record. to continue the trial presently scheduled to commence on NNNNNNNNN-AAA—xé—n—aéfig mNQm§w~AC®mN®thN—IO February 5, 2024, for approximately 60 days, to April 5, 2024, or to the first available date shortly thereafter convenient for the Court and all counsel. Good cause exists to continue the presently scheduled trial date as the parties need additional time to conduct the necessary discovery to sufficiently litigate the matter. scheduling conflicts of counsel in unrelated matters, and procedural delays in getting this matter at issue. No party will be prejudiced by the continuance. IT IS FURTHER AGREED AND STIPULATED by and among the parties herein and their counsel of record that all other dates, including, but not limited to, all statutory cut-off dates (e.g., discovery cut-off date, motion cut-off date. and expert exchange date), also be continued and made contingent upon the requested trial continuance. 1 JOINT STIPULATION T0 CONTINUE TRIAL AND ALL DISCOVERY AND TRIAL RELATED CUT-OFF DATES; [PROPOSED] ORDER IT IS FURTHER AGREED AND STIPULATED that this document may be executed in counterparts and exchanged via fax or email and all parts or copies shall constitute the agreement among the parties and their counsel. PETERSON, BRADFORD, BURKWITZ, (Dmflamkwm—l DATED: December 13 2023 , GREGORIO, BURKWITZ & SU, LLP By: Thomas WWW¢R. Bradfo‘fd, Esq. Vincent Contreras. Esq. Michael T. Gebreestifanos, Esq. Attorne sforDefendant, M. ISH N KAYALI, D.D.S. December LLP 300 Koo LAW’APC BURKWITZ. SU, 91502 DATEnzmm 12 .2023 Suite & 818.562.5800 59W fl? Street. California BURKWITZ BRADFORD, By: First Sonny HFKOO Esq. Attorneys for Telephone Burbank, Plaintiff. North GREGORIO. ROBERT JONES PETERSON. 100 NNNNNNNNNAAA-L—xé-a—x-x-x Law Office °f Jerry S' Ak'ta mVGm-FWNAOCOmNQm#mN—‘O DATED: November .2023 By: Jerry S. Akita, Esq. Attorneys for Co-Defendant, MAHER AZZAWI, D.D.S. 2 JOINT STIPULATION TO CONTINUE TRIAL AND ALL DISCOVERY AND TRIAL RELATED CUT-OFF DATES; [PROPOSED] ORDER