Moreno v. Taylor et al

Filing 6

Stipulation to Extend Time to Respond to Complaint and Order Thereon, signed by Magistrate Judge Michael J. Seng on 06/06/2014. (Yu, L)

DANIEL W. ROWLEY, #109408
1 [e-mail]
GILMORE, WOOD, VINNARD & MAGNESS
2 P.O. Box 28907
Fresno, CA 93729-8907
3 Telephone: [phone]
Facsimile: [phone]
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Attorneys for Defendants
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA, FRESNO DIVISION

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12 Juan Moreno,
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CASE NO. 1:14-CV-00556-AWI-MJS
Plaintiff,

v.

Stipulation to Extend Time to Respond
to Complaint and Proposed Order
Thereon

15 Lanny George Taylor, in his individual and
representative capacity as trustee of the
16 Lanlor Trust;
Lorrie Ann Taylor, in her individual and
17 representative capacity as trustee of the
Lanlor Trust;
18 Lanny George Taylor; and Does 1-10,
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Defendants.

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WHEREAS, the Defendants in this action were served with the Complaint

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on April 26, 2014,
WHEREAS, the Defendants are the owners of commercial property
allegedly visited by Plaintiff (the “Property”),
WHEREAS, the Complaint contains allegations of violations of the
Americans with Disabilities Act (“ADA”) and related causes of action,

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GILMORE, WOOD,
VINNARD & MAGNESS

A PROFESSIONAL CORPORATION
P.O. BOX 28907
FRESNO, CA 93729-8907

7354-4\00310659.000

1:14-CV-00556-AWI-MJS
Stipulation to Extend Time to Respond to Complaint

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WHEREAS, the parties are attempting to resolve this matter without further

2 litigation,
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WHEREAS, offers and counteroffers have been exchanged and the parties

4 are making progress,
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WHEREAS, the parties, by and through their attorneys, have previously

6 submitted a Stipulation and Order extending the time to respond to May 30, 2014,
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WHEREAS, additional time is necessary to complete settlement discussions,

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IT IS HEREBY STIPULATED by and between the parties through their

9 respective attorneys of record as follows:
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1.

Defendants shall have until June 13, 2014, to answer or otherwise

11 respond to the Plaintiff’s complaint.
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DATED: May 30, 2014

GILMORE, WOOD, VINNARD & MAGNESS

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By:

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/s/ Daniel W. Rowley
Daniel W. Rowley
Attorneys for Defendants LANNY G.
TAYLOR and LORRIE A. TAYLOR, COTRUSTEES OF LANLOR TRUST DATED
AUGUST 23, 2007; LANNIE G. TAYLOR
dba FOWLER UNION 76 aka FOWLER 76

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22 DATED: May 30, 2014

CENTER FOR DISABILITY ACCESS

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By:

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/s/ Phyl Grace
Phyl Grace
Attorneys for Plaintiff JUAN MORENO

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GILMORE, WOOD,
VINNARD & MAGNESS

A PROFESSIONAL CORPORATION
P.O. BOX 28907
FRESNO, CA 93729-8907

7354-4\00310659.000

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1:14-CV-00556-AWI-MJS
Stipulation to Extend Time to Respond to Complaint

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ORDER

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Good cause appearing, the above Stipulation is approved and adopted as the Order

4 of this Court.
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IT IS SO ORDERED.
Dated:

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June 6, 2014

/s/

Michael J. Seng

UNITED STATES MAGISTRATE JUDGE

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GILMORE, WOOD,
VINNARD & MAGNESS

A PROFESSIONAL CORPORATION
P.O. BOX 28907
FRESNO, CA 93729-8907

7354-4\00310659.000

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1:14-CV-00556-AWI-MJS
Stipulation to Extend Time to Respond to Complaint