Moore v. King of Central Valley et al

Filing 10

STIPULATION and ORDER For Extension of Time to Respond to Complaint and to Reschedule Scheduling Conference, signed by Magistrate Judge Barbara A. McAuliffe on 7/30/2013. (Initial Scheduling Conference previously set for 8/13/2013, has been CONTINUED to 9/24/2013, at 09:00 AM in Courtroom 8 (BAM) before Magistrate Judge Barbara A. McAuliffe. Defendants' deadline to respond to Plaintiffs complaint is hereby extended to August 30, 2013.)(Gaumnitz, R)

1 MOORE LAW FIRM, P.C.
TANYA E. MOORE, SBN 206683
2 [e-mail]
332 North Second Street
3 San Jose, California 95112
Telephone: [phone]
4 Facsimile: [phone]
5 Attorneys for Plaintiff
RONALD MOORE
6
HANSON BRIDGETT LLP
7 KURT A. FRANKLIN, SBN 172715
MEGAN OLIVER THOMPSON, SBN 256654
8 425 Market Street, 26th Floor
San Francisco, California 94105
9 Telephone: [phone]
Facsimile: [phone]
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Attorneys for Defendants King of Central
11 Valley and Central Valley Group, Inc.
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13

UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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16 RONALD MOORE,

CASE NO. 13-CV-00611-AWI-BAM

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STIPULATION AND ORDER FOR
EXTENSION OF TIME TO RESPOND TO
COMPLAINT AND TO RESCHEDULE
SCHEDULING CONFERENCE

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Plaintiff,
v.

19 KING OF CENTRAL VALLEY, a California
General Partnership; CENTRAL VALLEY
20 GROUP, INC., a California corporation,
dba BURGER KING #7705;,
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Defendants.
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Pursuant to Local Rules 143 and 144, Plaintiff Ronald Moore and Defendants King

24 of Central Valley and Central Valley Group, Inc., through their undersigned counsel,
25 hereby stipulate as follows:
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WHEREAS, Defendants waived service on May 28, 2013;

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5244405.1

WHEREAS, this action was filed on April 26, 2013;

WHEREAS, Defendants' answer to the Complaint is currently due on July 19,
STIP AND ORDER TO EXTEND TIME TO
-1-

RESPOND TO COMPLT AND RESCHEDULE
SCHED CONF

1 2013;
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WHEREAS, the Court's Mandatory Scheduling Conference is currently set for

3 August 13, 2013 at 9:00 a.m.;
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WHEREAS, the parties are in the process of negotiating a settlement of this action

5 and, therefore, have agreed to extend Defendants' time to respond to the complaint to
6 August 30, 2013;
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NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED by the parties,

8 through their counsel, as follows:
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1)

Defendants shall have to and including August 30, 2013 to answer or

10 otherwise respond to the complaint; and
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2)

In the interest of judicial economy and efficient use of resources, the parties

12 hereby request that the Court reschedule the Mandatory Scheduling Conference to a
13 date after September 1, 2013 that is convenient for the Court’s calendar.
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IT IS SO STIPULATED.

15 DATED: July 30, 2013

MOORE LAW FIRM, P.C.

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17

By:

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/S/ Tanya E. Moore
(as authorized on July 18, 2013)
TANYA E. MOORE
Attorneys for Plaintiff
RONALD MOORE

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20 DATED: July 30, 2013

HANSON BRIDGETT LLP

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25 / / /

By:

/S/ Megan Oliver Thompson
KURT A. FRANKLIN
MEGAN OLIVER THOMPSON
Attorneys for Defendants KING OF CENTRAL
VALLEY and CENTRAL VALLEY GROUP,
INC.

26 / / /
27 / / /
28 / / /
5244405.1

-2-

STIP AND ORDER TO EXTEND TIME TO
RESPOND TO COMPLT AND RESCHEDULE
SCHED CONF

1
2

ORDER
Based on the above Stipulation, and for good cause shown, Defendants' deadline

3 to respond to Plaintiff’s complaint is hereby extended to August 30, 2013. Further, the
4 Scheduling Conference currently scheduled for August 13, 2013 is continued to
5 September 24, 2013.
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7 IT IS SO ORDERED.
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9

Dated:

/s/ Barbara

July 30, 2013

A. McAuliffe

_

UNITED STATES MAGISTRATE JUDGE

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5244405.1

-3-

STIP AND ORDER TO EXTEND TIME TO
RESPOND TO COMPLT AND RESCHEDULE
SCHED CONF