Green v. Ashlan Park Center, LLC et al

Filing 10

Stipulation For Extension of Time For Defendant Ashlan Park Center, LLC to Respond to Complaint by More Than 28 Days; Order. signed by Magistrate Judge Michael J. Seng on 12/23/2014. (Yu, L)

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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]
Email: [e-mail]
Attorneys for Plaintiff
Lawrence Green

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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LAWRENCE GREEN,

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Plaintiff,
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vs.
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ASHLAN PARK CENTER, LLC, a Delaware )
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limited liability company, et al.,
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Defendants.
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No. 1:14-cv-01824---MJS
STIPULATION FOR EXTENSION OF
TIME FOR DEFENDANT ASHLAN
PARK CENTER, LLC TO RESPOND TO
COMPLAINT BY MORE THAN 28
DAYS; ORDER

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WHEREAS, Plaintiff, Lawrence Green (“Green”) alleges that a responsive pleading of

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Defendant, Ashlan Park, LLC, a Delaware limited liability company (“Ashlan Park”), was due

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December 15, 2014;

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WHEREAS, the parties are exploring settlement which would resolve all of Green’s

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claims against all defendants, which settlement negotiations include obtaining a report of a

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California Certified Access Specialist, reviewing the consultant’s findings, and discussing

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barrier removal and settlement as appropriate, all of which, given the holidays, is anticipated to

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take at least 45 days;

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WHEREAS, Green and Ashlan Park therefore wish to extend the time Ashlan Park’s

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responsive pleading would be due to February 9, 2015, over twenty-eight days from the initial

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date that plaintiff alleges that its responsive pleading was due, thereby requiring approval of the

STIPULATION FOR EXTENSION OF TIME; ORDER
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Court under Local Rule 144;

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WHEREAS, continuing the deadline for Ashlan Park’s responsive pleading to be filed to

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February 9, 2015 will not interfere with any dates or events already set by the Court, including

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the scheduling conference which is set for February 26, 2015.

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NOW, THEREFORE, IT IS HEREBY STIPULATED by and between Green and

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Ashlan Park, by and through their attorneys, that Ashlan Park shall have to and including

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February 9, 2015 within which to file its responsive pleading in this matter.

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Date: December 23, 2014

MOORE LAW FIRM, P.C.

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/s/ Tanya E. Moore
Tanya E. Moore
Attorneys for Plaintiff
Lawrence Green

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Date: December 23, 2014

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FORD, WALKER, HAGGERTY & BEHAR, LLP

/s/ Tina I. Mangarpan
Tina I. Mangarpan
Attorneys for Defendant
Ashlan Park Center, LLC, a Delaware limited
liability company

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ORDER
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The parties having so stipulated and good cause appearing,
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IT IS HEREBY ORDERED that Defendant Ashlan Park, LLC, a Delaware limited
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liability company, may have to and including February 9, 2015 within which to file a
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responding pleading.
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IT IS SO ORDERED.

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Dated:

December 23, 2014

/s/

Michael J. Seng

UNITED STATES MAGISTRATE JUDGE
STIPULATION FOR EXTENSION OF TIME; ORDER
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STIPULATION FOR EXTENSION OF TIME; ORDER
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