On February 04, 2020 a
Stipulation,Agreement
was filed
involving a dispute between
Valdez, Joann,
and
Seiu Local 121Rn. As A California Organization,
for Wrongful Termination Unlimited
in the District Court of San Bernardino County.
Preview
F l L E D
SUPERIOR count 0F CALIFORNIA
A William D. Naeve (SBN 92270) COUNTY 0F SAN BERNARowo
SAN BERNAHDINO 0|an DIVISION
Elizabeth H. Burnett (SBN 332967)
MURCHISON & CUMMING, LLP
18201 Von Karman Avenue, Suite 950 JUN 15 2023
92612-1077
Irvine, California
Telephone: (714) 972-9977
Facsimile: (714) 972-1404
E-Mail: wnaeve@murchisonlaw.com
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JRIGINAL
eburnett@murchisonlaw.com
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Attorneys for Defendant SEIU LOCAL 121 RN
MichaelJ. Jaurigue (SBN 208123)
S.Sean Shahabi (SBN 204710)
Amanda L. Thompson (SBN 254355)
JAURIGUE LAW GROUP
300 W. Glenoaks Blvd., Suite 300
Glendale, CA 91202
Telephone: (818) 630-7280
Facsimile: (888) 879-1697
E-Mail: service@jlg|awyers.com
E-Mail: michael@jlglawyers.com
E-Mail: sean@j|g|awyers.com
FAX
E-Mail: amanda@jlglawyers.com
Attorneys for Plaintiff JOANN VALDEZ
EV
SUPERIOR COURT OF THE STATE 0F CALIFORNIA
COUNTY OF SAN BERNARDINO, SAN BERNARDINO DISTRICT
JOANN VALDEZ, individually, CASE NO. CIV DS 2003745
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Plaintiff, Assigned to Hon. Michael A. Sachs
Dept. 828
VS.
STIPULATION TO CONTINUE TRIAL
SEIU Local 121 RN., as a California DATE, FINAL STATUS CONFERENCE,
Organization and DOES 1 through 25, AND ALL OTHER TRIAL-RELATED
inclusive, DATES AND DEADLINES
Defendant.
man“ Concurrently With [Proposed] Order]
b [Filed
///
Ni \x
Action Filed:
Trial Date:
February
September
4, 2020
11, 2023
///
///
1
STIPULATION TO CONTINUE TRIAL DATE, FINAL STATUS CONFERENCE, AND ALL OTHER TRIAL-
RELATED DATES AND DEADLINES
TO THE CLERK OF THE ABOVE ENTITLED COURT AND TO ALL PARTIES
AND TO THEIR RESPECITVE ATTORNEYS OF RECORD:
COMES NOW, Plaintiff JOANN VALDEZ and Defendant SEIU Local 121RN, and
each of them, by and through their respective counsel of record and stipulate as follows:
A. Stipulation
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It is hereby stipulated by and between counsel for Plaintiff JOANN VALDEZ and
Defendant, SEIU Local 121 RN, (hereafter referred to as “SEIU") by and through their
respective counsel of record to continue the existing September 11, 2023 trial date to a
date and time of the Court's choosing on and after February 20, 2024. This stipulation is
supported by good cause and is not submitted for purposes of delay as set forth below.
B. Facts Supporting This Stipulation
1. The current trial date assigned to this case is September 11, 2023. The
parties have not previously requested the Court continue that September 11, 2023 trial
date.
2. Plaintiff and Defendants participated in a first voluntary Mediation on
September 29, 2022 which was unsuccessful because, in part, because the parties had to
participate in additional discovery.
3. The parties have engaged in extensive discovery. Defendant SEIU has
mflmmthAOOQNmm-th—‘O
MNNMNNNNNAAAAAAAAAA served second set of Specially Drafted interrogatories to Plaintiff; four sets of Requests for
Production of Documents to Plaintiff; first set of Requests for Admission; and a first set of
Form Interrogatories to Plaintiff. Additionally, the parties have taken two depositions and
contemplate taking several others. By virtue of this completed discovery, the fundamental
facts underlying Plaintiff's claims have been disclosed and explored. Additionally, the
parties have interviewed additional potential percipient witnesses.
4. Since the first mediation, the parties have exchanged and responded to
additional discovery and have further interviewed additional percipient witnesses.
5. Because of the status of discovery, the attorneys representing the parties
and the parties themselves have agreed to participate in a Second Session of Mediation
2
STIPULATION TO CONTINUE TRIAL DATE, FINAL STATUS CONFERENCE, AND ALL OTHER TRIAL-
RELATED DATES AND DEADLINES
Document Filed Date
June 15, 2023
Case Filing Date
February 04, 2020
Category
Wrongful Termination Unlimited
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Preview
F l L E D SUPERIOR count 0F CALIFORNIA A William D. Naeve (SBN 92270) COUNTY 0F SAN BERNARowo SAN BERNAHDINO 0|an DIVISION Elizabeth H. Burnett (SBN 332967) MURCHISON & CUMMING, LLP 18201 Von Karman Avenue, Suite 950 JUN 15 2023 92612-1077 Irvine, California Telephone: (714) 972-9977 Facsimile: (714) 972-1404 E-Mail: wnaeve@murchisonlaw.com ‘ev ACHLEE amass mm. 05.0w JRIGINAL eburnett@murchisonlaw.com Omflwmth Attorneys for Defendant SEIU LOCAL 121 RN MichaelJ. Jaurigue (SBN 208123) S.Sean Shahabi (SBN 204710) Amanda L. Thompson (SBN 254355) JAURIGUE LAW GROUP 300 W. Glenoaks Blvd., Suite 300 Glendale, CA 91202 Telephone: (818) 630-7280 Facsimile: (888) 879-1697 E-Mail: service@jlg|awyers.com E-Mail: michael@jlglawyers.com E-Mail: sean@j|g|awyers.com FAX E-Mail: amanda@jlglawyers.com Attorneys for Plaintiff JOANN VALDEZ EV SUPERIOR COURT OF THE STATE 0F CALIFORNIA COUNTY OF SAN BERNARDINO, SAN BERNARDINO DISTRICT JOANN VALDEZ, individually, CASE NO. CIV DS 2003745 NNMNNNNNNAAAAAAAAAA mflmtflhWN—icwmflamkwN—‘O Plaintiff, Assigned to Hon. Michael A. Sachs Dept. 828 VS. STIPULATION TO CONTINUE TRIAL SEIU Local 121 RN., as a California DATE, FINAL STATUS CONFERENCE, Organization and DOES 1 through 25, AND ALL OTHER TRIAL-RELATED inclusive, DATES AND DEADLINES Defendant. man“ Concurrently With [Proposed] Order] b [Filed /// Ni \x Action Filed: Trial Date: February September 4, 2020 11, 2023 /// /// 1 STIPULATION TO CONTINUE TRIAL DATE, FINAL STATUS CONFERENCE, AND ALL OTHER TRIAL- RELATED DATES AND DEADLINES TO THE CLERK OF THE ABOVE ENTITLED COURT AND TO ALL PARTIES AND TO THEIR RESPECITVE ATTORNEYS OF RECORD: COMES NOW, Plaintiff JOANN VALDEZ and Defendant SEIU Local 121RN, and each of them, by and through their respective counsel of record and stipulate as follows: A. Stipulation (DmNO)UIhWNi It is hereby stipulated by and between counsel for Plaintiff JOANN VALDEZ and Defendant, SEIU Local 121 RN, (hereafter referred to as “SEIU") by and through their respective counsel of record to continue the existing September 11, 2023 trial date to a date and time of the Court's choosing on and after February 20, 2024. This stipulation is supported by good cause and is not submitted for purposes of delay as set forth below. B. Facts Supporting This Stipulation 1. The current trial date assigned to this case is September 11, 2023. The parties have not previously requested the Court continue that September 11, 2023 trial date. 2. Plaintiff and Defendants participated in a first voluntary Mediation on September 29, 2022 which was unsuccessful because, in part, because the parties had to participate in additional discovery. 3. The parties have engaged in extensive discovery. Defendant SEIU has mflmmthAOOQNmm-th—‘O MNNMNNNNNAAAAAAAAAA served second set of Specially Drafted interrogatories to Plaintiff; four sets of Requests for Production of Documents to Plaintiff; first set of Requests for Admission; and a first set of Form Interrogatories to Plaintiff. Additionally, the parties have taken two depositions and contemplate taking several others. By virtue of this completed discovery, the fundamental facts underlying Plaintiff's claims have been disclosed and explored. Additionally, the parties have interviewed additional potential percipient witnesses. 4. Since the first mediation, the parties have exchanged and responded to additional discovery and have further interviewed additional percipient witnesses. 5. Because of the status of discovery, the attorneys representing the parties and the parties themselves have agreed to participate in a Second Session of Mediation 2 STIPULATION TO CONTINUE TRIAL DATE, FINAL STATUS CONFERENCE, AND ALL OTHER TRIAL- RELATED DATES AND DEADLINES