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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
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- _ 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.
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2. Said deposition may proceed in person, with the option for counsel for Plaintiff to
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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
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Dept:
53
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County of Los Angeles Central District
Department 53
mugihiko morijiri
, et al.;
Plaintiffs
,
vs.
24 cmn llc
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.
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Motion to Strike Portions of Complaint
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[1]
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_____________________________
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[1]
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(Notice of Mot., p. 2, ¶ 3.)
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