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  • M.T.-v- Lyft, Inc et al Print Other PI/PD/WD Unlimited  document preview
  • M.T.-v- Lyft, Inc et al Print Other PI/PD/WD Unlimited  document preview
  • M.T.-v- Lyft, Inc et al Print Other PI/PD/WD Unlimited  document preview
  • M.T.-v- Lyft, Inc et al Print Other PI/PD/WD Unlimited  document preview
						
                                

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SHEPPARD, MULLIN, RICHTER & HAMPTON LLP A Limited Liability Partnership Including Professional Corporations BROOKE S. PURCELL, Cal. Bar No. 260058 RACHEL J. MOROSKI, Cal. Bar No. 286805 SUSAN HAINES, Cal. Bar No. 224611 NINA MONTAZERI, Cal. Bar No. 335233 Four Embarcadero Center, 17‘“ Floor San Francisco, California 941 1 1-4109 Telephone: 41 5.4349 1 00 Facsimile: 415.434.3947 OOOONOMAWN Email: bpurcell@sheppardmullin.com nnoroski@sheppardmullin.com shaines@sheppardmullin.com nmontazeri@sheppardmullin.com Attorneys for Defendant LYFT, INC. ll 12 SUPERIOR COURT OF THE STATE OF CALIFORNIA l3 IN AND FOR THE COUNTY OF SAN BERNARDINO 14 15 M.T., a minor, by and through her Guardian ad Case N0. ClVSB2028839 Litem, E.T., 16 [Assigned For All Purposes T0 The Hon. Plaintiff, Michael A. Sachs, Dept. S28] l7 v. STIPULATION AND [PRGFO‘S'EU] 18 ORDER TO TAKE THE DEPOSITION 0F DOE LYFT DRIVER; LYFT, INC; JOHN IMPRISONED DEFENDANT MICHAEL 19 MICHAEL ALEJANDRE III; and DOES 1- ALEJANDRE III 50, inclusive, 2O Defendants. Complaint Filed: January 19, 2021 21 FAC Filed: May 28, 2021 SAC Filed: October 28, 202] Trial Date: November 4, 2024 22 23 24 25 26 27 28 - _ Case N0. CIVSB2028839 1 SMRH:4864-4498-l 175.1 STIPULATION AND 9WD] ORDER ToDEFENDANT TAKE DEPOSITION 0F IMPRISONED MICHAEL ALEJANDRE III TO THE HONORABLE COURT, ALL PARTIES AND THEIR ATTORNEYS 0F RECORD: PlaintiffM.T., through hcr Guardian ad litem, E.T. (“Plaintiff"), and Defendant Lyft, Inc. (“Defendant” and/or “Lyft") by and through their attorneys of record (collectively referred to as the “Parties”), stipulate as follows: OOWNO‘LII#UJNH WHEREAS, Defendant Michael Alejandre III (“Defendant” and/or “‘Alejandre”) was convicted of statutory rape for a sexual encounter he had with Plaintiff while she was a minor which forms the basis of Plaintiff’s claims against Lyft; WHEREAS, thc Parties bclicvc it is necessary t0 complete the deposition of Defendant Michael Alejandre Ill based upon his direct involvement in the alleged wrongful conduct; WHEREAS, Alejandre is currently incarcerated at the Richard J. Donovan Correctional Facility (the “Prison”) due to a probation violation and is not eligible for parole until July 2025, which is after the November 4, 2024 trial date in this case; and WHEREAS, a Coun order is therefore required t0 complete his deposition. THEREFORE, thc parties stipulate and request that the Court order as follows: 1. Pursuant to Penal Code section 2623, the deposition of Defendant Alejandre (# BR5180) shall be taken at the Prison on June 19, 2024 at 10:30 a.m., or as otherwise scheduled by the Prison pursuant to section 2025 ofthc Code ofCivil Procedure. NNNNNNNNN—nb—n—nfl—HHH—p—n 2. Said deposition may proceed in person, with the option for counsel for Plaintiff to WNQMAU’N—ONOOONOMAWN— appear remotely. 3. The Parties also agree that this stipulation may be executed in counterparts until completed. 4. The Parties further stipulate that this Stipulation and [Proposed] Order may be presented to the Court for approval via filing of a stipulation and request for order, an ex parte application. 0r similar process to assure it is timely approved. IT IS SO STIPULATED. -2- Case No. CIVSB2028839 SMRH¢486444934 ‘75" STIPULATION AND WORDER TO TAKE DEPOSITION OF IMPRISONED DEFENDANT MICHAEL ALEJANDRE III