Curtis v. Dick's Sporting Goods, Inc. et al

Filing 19

STIPULATION and ORDER GRANTING the parties' request for an extension of time to 10/22/2013 for receipt of defendant Dick's Sporting Goods' responsive pleading. Order signed by Magistrate Judge Sandra M. Snyder on 9/26/2013. (Rooney, M)

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1 2 3 4 5 ROBINS, KAPLAN, MILLER & CIRESI L.L.P. Michael A. Geibelson, Bar No. 179970 mageibelson@rkmc.com Jill S. Casselman, Bar No. 266085 jscasselman@rkmc.com 2049 Century Park East, Suite 3400 Los Angeles, CA 90067-3208 Telephone: 310-552-0130 Facsimile: 310-229-5800 6 8 Attorneys for Defendant DICK’S SPORTING GOODS, INC. (erroneously sued and served as DICK’S SPORTING GOODS, INC., dba DICK’S SPORTING GOODS) 9 10 L OS A NGELES A TTORNEYS A T L AW R OBINS , K APLAN , M ILLER & C IRESI L.L.P. 7 UNITED STATES DISTRICT COURT 11 EASTERN DISTRICT OF CALIFORNIA 12 13 ALBERT GEORGE CURTIS, Plaintiff, 14 15 16 17 vs. DICK’S SPORTING GOODS, INC., dba DICK’S SPORTING GOODS; GATEWAY PLAZA PARTNERS, L.P., a California Limited Partnership, Case No. 13-CV-01199-LJO-SMS STIPULATION AND ORDER TO EXTEND TIME OF DICK’S SPORTING GOODS, INC. TO RESPOND TO COMPLAINT Complaint Filed: July 31, 2013 18 Defendants. 19 20 21 22 Pursuant to Local Rules 143 and 144, the undersigned counsel of record for Plaintiff Albert George Curtis (“Plaintiff”), and Defendant Dick’s Sporting Goods, Inc., erroneously sued as Dick’s Sporting Goods, Inc., dba Dick’s Sporting Goods, (“Dick’s Sporting Goods”), stipulate 23 and agree to extend the time for Dick’s Sporting Goods to respond to Plaintiff’s Complaint as 24 25 26 27 follows: WHEREAS, Plaintiff filed his complaint in this action on July 31, 2013 (the “Complaint”); 28 60706428.1 STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT 1 2 WHEREAS, Defendant Dick’s Sporting Goods was served with the Complaint on August 1, 2013; 3 WHEREAS, the response of Dick’s Sporting Goods’ was initially due on August 22, 4 2013, 5 6 WHEREAS, on August 11, 2013, the parties stipulated, pursuant to Local Rule 144, to extend the time for Dick’s Sporting Goods and Defendant Gateway Plaza Partners, L.P. to 8 respond to the Complaint by twenty-eight (28) days until September 18, 2013; 9 10 L OS A NGELES A TTORNEYS A T L AW R OBINS , K APLAN , M ILLER & C IRESI L.L.P. 7 11 WHEREAS, on September 13, 2013, the parties stipulated, pursuant to Local Rule 144, to extend the time for Dick’s Sporting Goods to respond to the Complaint until September 30, 2013, in order to allow the parties more time to engage in settlement discussions to resolve this matter; 12 13 14 15 16 17 18 WHEREAS, the parties have been conducting meaningful settlement discussions and are cautiously optimistic that they will reach a complete settlement prior to October 23, 2013, which is the date that the parties must file their joint scheduling report; WHEREAS, Plaintiff and Dick’s Sporting Goods have met and conferred and have agreed that it is in their best interests, and in the interests of justice, to extend the time for Dick’s Sporting Goods to respond to the Complaint for twenty-two (22) days, until October 22, 2013, to 19 permit meaningful settlement discussions while minimizing litigation expense; 20 21 22 23 24 25 26 WHEREAS, this extension will not alter any other date or deadline set by the Court; WHEREAS, the Plaintiff and Dick’s Sporting Goods agree that this stipulation does not waive any right of the parties to request further extensions from the Court; IT IS STIPULATED AND AGREED THAT Dick’s Sporting Goods’ time to answer or otherwise respond to the Complaint shall be extended until October 22, 2013. Nothing in this Stipulation shall be construed as a waiver of any of Plaintiffs’ or 27 Defendants’ rights, defenses, or arguments they would otherwise have. 28 60706428.1 -2- STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT 1 DATED: September 25, 2013 ROBINS, KAPLAN, MILLER & CIRESI L.L.P. 2 3 By: 4 5 ATTORNEYS FOR DEFENDANT DICK’S SPORTING GOODS, INC. (erroneously sued and served as DICK’S SPORTING GOODS, INC., dba DICK’S SPORTING GOODS) 6 7 8 9 DATED: September 25, 2013 MOORE LAW FIRM, P.C. 10 By: L OS A NGELES A TTORNEYS A T L AW R OBINS , K APLAN , M ILLER & C IRESI L.L.P. /s/ Jill S. Casselman _ Michael A. Geibelson Jill S. Casselman 11 12 /s/ Tanya E. Moore__ Tanya E. Moore ATTORNEYS FOR PLAINTIFF ALBERT GEORGE CURTIS 13 14 IT IS SO ORDERED. 15 16 DATE: September 26, 2013 17 /s/ SANDRA M. SNYDER SANDRA M. SNYDER UNITED STATES MAGISTRATE JUDGE 18 19 20 21 22 23 24 25 26 27 28 60706428.1 -3- STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT

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