Shaw v. Bhakta, et al.

Filing 9

SECOND STIPULATION and ORDER 8 for Extension of Time to Respond to Complaint, signed by Magistrate Judge Jennifer L. Thurston on 2/27/2015. (Hall, S)

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1 2 3 4 5 Bruce A. Neilson #096952 7108 N. Fresno St. #410 Fresno, California 93720 Telephone (559) 432-9831 Facsimile (559) 432-1837 Attorney for Defendants Suman D. Bhakta and Nutan S. Bhakta,both individually and dba Caprice Motel 6 7 UNITED STATES DISTRICT COURT 8 EASTERN DISTRICT OF CALIFORNIA 9 ***** )))) 10 ) ) ) Plaintiff, ) vs. ) ) SUMAN D. BHAKTA, individually and dba ) CAPRICE MOTEL; NUTAN S. BHAKTA, ) individually and dba CAPRICE MOTEL; ) ) Defendants. ) ____________________________________ ) CASE NO. 1: 14-cv-01965---JLT CECIL SHAW, 11 12 13 14 15 SECOND STIPULATION AND PROPOSED ORDER FOR EXTENSION OF TIME FOR SUMAN D. BHAKTA, individually and dba CAPRICE MOTEL; and NUTAN S. BHAKTA, individually and dba CAPRICE MOTEL TO RESPOND TO COMPLAINT (Doc 8) 16 WHEREAS: 17 18 1. Plaintiff CECIL SHAW filed this action on December 10, 2014. 19 2. This is the second request for an extension of time for SUMAN D. BHAKTA, individually 20 and dba CAPRICE MOTEL; and NUTAN S. BHAKTA, individually and dba CAPRICE MOTEL 21 (“Defendants”). A previous extension of time was granted by the plaintiff within the statutory 22 allowance; thus, court approval is required for a further extension of time. 23 3. Plaintiff and Defendants are in settlement negotiations at this time. 24 4. Defendants have obtained a CASp inspection, and are waiting for the report to be written so 25 that a proposed plan of remediation and settlement can be agreed upon. 26 5. The parties agree that settlement of this case would save valuable court time and resources. 27 6. The parties have agreed to extend Defendants’ time to respond to the complaint until March 28 11, 2015, subject to the court's approval, and believe that the case can be settled within that Shaw v. Suman D. Bhakta, et al 2nd Stipulation For Extension of Time 1 Case No. 1: 14-cv-01965 1 time. 2 7. 3 the mandatory scheduling conference. 4 This extension of time will not alter any date or event already set by Court order, including NOW THEREFORE, Defendants through their attorneys, and Plaintiff Cecil Shaw, through 5 his attorneys, hereby stipulate and agree that the time for Defendants SUMAN D. BHAKTA, 6 individually and dba CAPRICE MOTEL; and NUTAN S. BHAKTA, individually and dba 7 CAPRICE MOTEL to answer or otherwise respond to the Complaint shall be extended up to and 8 including March 11, 2015, pending court approval. 9 10 IT IS SO STIPULATED. 11 12 Dated: February 25, 2015 MOORE LAW FIRM, PC ______/s/Tanya Moore Tanya Moore, Attorney for Plaintiff Cecil Shaw 13 14 15 Dated: February 25, 2015 16 ______/s/Bruce A. Neilson Bruce A. Neilson, Attorney for Defendants Suman D. Bhakta and Nutan S. Bhakta,both individually and dba Caprice Motel 17 18 19 IT IS SO ORDERED. Dated: February 27, 2015 /s/ Jennifer L. Thurston UNITED STATES MAGISTRATE JUDGE 20 21 22 23 24 25 26 27 28 Shaw v. Suman D. Bhakta, et al 2nd Stipulation For Extension of Time 2 Case No. 1: 14-cv-01965

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