Green v. Ashlan Park Center, LLC et al

Filing 7

Stipulation To Extend Time For Koroosh Zaghi To Respond To The Complaint By More Than 28 Days; ORder signed by Magistrate Judge Michael J. Seng on 12/19/2014. (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]
E-mail: [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,

)
)
Plaintiff,
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vs.
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ASHLAN PARK CENTER, LLC, a Delaware )
limited liability company; KOROOSH ZAGHI )
)
dba ARBY’S #5524,
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)
Defendants.
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)

No. 1:14-CV-01824---MJS
STIPULATION TO EXTEND TIME FOR
KOROOSH ZAGHI TO RESPOND TO
THE COMPLAINT BY MORE THAN 28
DAYS; ORDER

WHEREAS, Plaintiff, Lawrence Green (“Green”) alleges that a responsive pleading of
Defendant, Koroosh Zaghi (“Zaghi”), is due January 8, 2015;

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WHEREAS, Green and Zaghi are exploring settlement which would resolve all of

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Green’s claims against all Defendants, which settlement negotiations include obtaining a report

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of a 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 Zaghi therefore wish to extend the time Zaghi’s responsive

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

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STIPULATION TO EXTEND TIME FOR KOROOSH ZAGHI TO RESPOND TO THE COMPLAINT;
[PROPOSED] ORDER
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plaintiff alleges that his responsive pleading was due, thereby requiring approval of the Court

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under Local Rule 144;

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WHEREAS, continuing the deadline for Zaghi’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 Zaghi,

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by and through their attorneys, that Zaghi shall have to and including February 9, 2015 within

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which to file his responsive pleading in this matter.

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Dated: December 19, 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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/s/ Anthony E. Goldsmith
Anthony E. Goldsmith
Attorney for Defendant,
Koroosh Zaghi

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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 Koroosh Zaghi may have to and
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including February 9, 2015 within which to file a responding pleading in case
No. 1:14-CV-01824---MJS.

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IT IS SO ORDERED.

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Dated:

December 19, 2014

/s/

Michael J. Seng

UNITED STATES MAGISTRATE JUDGE

STIPULATION TO EXTEND TIME FOR KOROOSH ZAGHI TO RESPOND TO THE COMPLAINT;
[PROPOSED] ORDER
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STIPULATION TO EXTEND TIME FOR KOROOSH ZAGHI TO RESPOND TO THE COMPLAINT;
[PROPOSED] ORDER
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