stipulation and order to continue trial date and pretrial deadlinesCal. Super. - 1st Dist.April 23, 2020James J. Zenere, SB#151724 Jennifer A. Wagster, SB#199771 SHEUERMAN, MARTINI, TABARI, ZENERE & GARVIN A Professional Corporation 1033 Willow Street San Jose, California 95125 (408) 288-9700 Fax: (408) 350-1432 Attorneys for Defendants WILLIAM ZHAO and THE ZHAO ACUPUNCTURE CLINIC SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN FRANCISCO LI QUN "TRACY" XU, ) No. CGC-18-572020 ) Plaintiff, ) STIPULATION AND ORDER TO ) CONTINUE TRIAL DATE AND v. ) PRETRIAL DEADLINES ) WILLIAM ZHAO, THE ZHAO ) ACUPUNCTURE CLINIC, and DOES 1 ) Date: July 30,2019 through 50, inclusive, ) Time: 11:00 a.m. ) Dept.: 206 Defendants. ) Judge: Hon. Garrett L. Wong Complaint Filed: 12/20/18 1 s t Amended Complaint Filed: 2/22/19 Plaintiff LI QUN "TRACY" XU, and Defendants WILLIAM ZHAO and THE ZHAO ACUPUNCTURE CLINIC, by and through their respective attorneys of record, hereby stipulate as follows: WHEREAS, this action involves allegations of professional negligence and lack of informed consent. WHEREAS, a jury trial is currently set in this matter for December 9, 2019. This is the first trial setting in this matter. WHEREAS, trial counsel for defendant is currently scheduled to be in trial in San Francisco County in the matter of Presley-Nelson v. Health Diagnostics, et al., Case #CGC17557561 on S'I IPULA'l ION AND ORDER '1'0 CON'I'IN UE TRIAL DATE AND PRETRIAL DEADLINES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ELECTRONICALLY F I L E D Superior Court of California, County of San Francisco 07/26/2019 Clerk of the Court BY: CAROL BALISTRERI Deputy Clerk December 2, 2019, a case that is expected to take 2-3 weeks to try given the number of defendants, experts and treating physicians. It is not likely that the Presley-Nelson matter will settle; all efforts to convince plaintiffs counsel in that matter to dismiss the action have not been successful. Subsequent efforts to Tender the defense in that case were also unsuccessful. Therefore, defense counsel will be engaged in another trial at the time of this stipulation. WHEREAS, the parties have met and conferred regarding a date mutually acceptable to continue the trial date. After meeting and conferring, the parties have agreed they are all available if trial were to commence during the month of April 2020 and have selected April 27, 2020 as a proposed trial date. WHEREAS, the parties submit these circumstances amount to good cause for a continuance of the trial date To April 27, 2020. All parties agree that a continuance of the current trial date will be in the best interest of the parties involved and in the best interests of justice. WHEREAS, all parties agree that discovery cutoff dates and motion deadlines, including expert discovery, shall be continued and reset to correspond with the new trial date. /// /// /// /// /// /// /// /// /// /// /// III HI III 2 STIPULATION AND ORDER TO CONTINUE I RIAL DA I E AND PRETRIAL DEADLINES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Date Dated: 2(7/ STIPULATION THAT FOR GOOD CAUSE SHOWN, the parties have reached the following stipulation: 1. All parties, by and through their respective attorneys of record, hereby stipulate to continue the trial of this matter from its presently scheduled date of December 9, 2019, to a new date commencing on April 27, 2020; 2. All discovery, including expert discovery, dates and deadlines, and all motion deadlines, shall be continued to correspond with the new trial date; 3. This stipulation may be executed in subparts, and a facsimile or scanned copy of any party's signature may be submitted to the Court with the same purpose and effect as if the original signature was available. IT IS SO STIPULATED. THE BRYANT LAW GROUP EDWARD M. HIGGINBOTHAM, ESQ. CONRAD K. WU, ESQ. Attorneys for Plaintiff LI QUN "TRACY" XU SHEUERMAN, MARTINI, TABARI, ZENERE & GARVIN JeejC--. z JAMES J. ZENERE JENNIFER A. WAGSTER Attorney for Defendants WILLIAM ZHAO and THE ZHAO ACUPUNCTURE CLINIC 3 STIPULATION AND ORDER '1'0 CONTINUE TRIAL DATE AND PRETRIAL DEADLINES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28