Kalani v. Khatri, Inc. et al

Filing 13

SECOND STIPULATION Extending Time by More Than 28 Days for Defendant Mak, LLC to Respond to Complaint; ORDER signed by Magistrate Judge Gary S. Austin on 1/10/2014. (Martinez, A)

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Tanya E. Moore, SBN 206683
MOORE LAW FIRM, P.C.
332 North Second Street
San Jose, California 95112
Telephone [phone]
Facsimile [phone]
E-mail: [e-mail]
Attorneys for Plaintiff
Robert Kalani

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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ROBERT KALANI,

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Plaintiff,
vs.
KHATRI, INC., dba CLARION INN, et al.;

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Defendants.

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No. 1:13-cv-01786-LJO-GSA
SECOND STIPULATION EXTENDING
TIME BY MORE THAN 28 DAYS FOR
DEFENDANT MAK, LLC TO RESPOND
TO COMPLAINT; ORDER

WHEREAS, Plaintiff, Robert Kalani (“Plaintiff”), and Defendant, Mak, LLC, dba
Clarion Inn (“Defendant”, and together with Plaintiff, “the Parties”) previously entered into a

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stipulation granting Defendant to and including January 2, 2014 within which to file a
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responsive pleading (ECF No. 9);
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WHEREAS, Plaintiff and Defendant are presently engaged in meaningful settlement
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negotiations. Defendant has agreed to provide a full certified access specialist report for the
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subject property which report the Parties believe will likely form the basis for a resolution of
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Plaintiff’s claims for injunctive relief;

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WHEREAS, the Parties desire to conserve judicial resources and attorney fees attendant
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with preparing and filing a responsive pleading, and desire instead to apply those resources
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towards settlement in the cautiously optimistic belief that such a settlement is likely;
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SECOND STIPULATION EXTENDING TIME FOR DEFENDANT MAK, LLC TO RESPOND TO
COMPLAINT; ORDER
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NOW, THEREFORE, IT IS HEREBY STIPULATED by and between Plaintiff, by

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and through his attorney, and Defendant Mak, LLC, by and through counsel who is specially

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appearing for Defendant for the sole purpose of obtaining this stipulation, that Defendant may

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have to and including January 17, 2014 to file a responsive pleading in this matter. This

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extension of time does not alter the date of any event or any deadline already fixed by Court

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order.

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Dated: January 10, 2014

MOORE LAW FIRM, P.C.

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/s/ Tanya E. Moore
Tanya E. Moore
Attorneys for Plaintiff
Robert Kalani

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/s/ Michael Karimi
Michael Karimi
Specially Appearing for Defendant
Mak, LLC, dba Clarion Inn

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ORDER

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The Parties having so stipulated and good cause appearing, Defendant Mak, LLC, dba

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Clarion Inn, shall file a responsive pleading to Plaintiff’s complaint on or before January 17,
2014.

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IT IS SO ORDERED.
Dated:

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January 10, 2014

/s/ Gary S. Austin
UNITED STATES MAGISTRATE JUDGE

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DEAC_Signature-END:

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SECOND STIPULATION EXTENDING TIME FOR DEFENDANT MAK, LLC TO RESPOND TO
COMPLAINT; ORDER
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