Moore v. Hieng et al

Filing 24

Second Stipulation for Extension Of Time For Defendants To Respond To Complaint, And To Continue Mandatory Scheduling Conference. The Initial Scheduling Conference is now set for May 7, 2015 at 10:30 AM in Courtroom 6 (MJS) before Magistrate Judge Michael J. Seng., signed by Magistrate Judge Michael J. Seng on 03/06/2015. (Yu, L)

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Amy R. Lovegren-Tipton (SBN 258697)
LAW OFFICE OF AMY R.
LOVEGREN-TIPTON, APLC
5703 N. West Avenue, Suite 103
Fresno, California 93711
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Defendants TOM HIENG, GORDON K. TESSMAN, JEAN A. TESSMAN,
DOUGLAS ARNOLD JORISSEN, KIMBER LEA JORISSEN, STACEY LANE WALTER,
RITHY SOK

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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)
)
)
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RONALD MOORE,
)
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Plaintiff,
)
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v.
)
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TOM HIENG dba SUNSHINE DONUTS;
GORDON K. TESSMAN, Co-Trustee of the )
)
GORDON K. TESSMAN and JEAN A.
TESSMAN REVOCABLE FAMILY TRUST )
)
u/d/t November 18, 2010; JEAN A.
)
TESSMAN, Co-Trustee of the GORDON K. )
TESSMAN and JEAN A. TESSMAN
)
REVOCABLE FAMILY TRUST u/d/t
)
November 18, 2010; DOUGLAS ARNOLD )
JORISSEN, Co-Trustee of the DOUGLAS
)
ARNOLD JORISSEN AND KIMBER LEA )
JORRISON REVOCABLE TRUST
)
)
AGREEMENT u/d/t August 12, 2010;
KIMBER LEA JORISSEN, Co-Trustee of the )
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DOUGLAS ARNOLD JORISSEN AND
)
KIMBER LEA JORRISEN REVOCABLE
TRUST AGREEMENT u/d/t August 12, 2010; )
)
STACEY LANE WALTER TRUST u/d/t
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November 23, 2010; RITHY SOK dba
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SUNSHINE DONUTS,
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Defendants.
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Case No.: 1:14-CV-01968
SECOND STIPULATION FOR
EXTENSION OF TIME FOR
DEFENDANTS TOM HIENG, GORDON
K. TESSMAN, JEAN A. TESSMAN,
DOUGLAS ARNOLD JORISSEN,
KIMBER LEA JORISSEN, STACEY
LANE WALTER AND RITHY SOK TO
RESPOND TO COMPLAINT, AND TO
CONTINUE MANDATORY
SCHEDULING CONFERENCE

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STIPULATION
-1-

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WHEREAS, Plaintiff, RONALD MOORE (“Plaintiff”), and Defendants TOM HIENG,

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GORDON K. TESSMAN, JEAN A. TESSMAN, DOUGLAS ARNOLD JORISSEN, KIMBER

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LEA JORISSEN, STACEY LANE WALTER and RITHY SOK (“Defendants”) acknowledge

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that the parties previously stipulated to an extension of time wherein Defendants’ response to

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the First Amended Complaint is currently due on or before March 4, 2015;

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WHEREAS, the above-referenced parties are engaged in meaningful settlement

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negotiations, and wish to avoid incurring additional fees and unnecessarily utilizing judicial

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resources while Defendants obtain and share with Plaintiff their CASp report(s), and while

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Plaintiff and Defendants explore, and hopefully finalize, a settlement as between them;

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WHEREAS, the Mandatory Scheduling Conference is currently set for April 2, 2015,

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and the Mandatory Joint Scheduling Conference Statement must therefore be filed on or before

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March 26, 2015;

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WHEREAS, the parties do not object to continuing the Mandatory Scheduling
Conference;
NOW, THEREFORE, the parties, by and through their counsel of record, hereby
stipulate as follows:
1. To an extension of time (i.e., a second extension which, in total, exceeds 28 days)

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for Defendants to respond to the First Amended Complaint herein, through and including

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March 30, 2015, which extension exceeds the maximum 28 days permissible without leave of

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Court; and

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2. That the Mandatory Scheduling Conference currently set for April 2, 2015, be
continued to a date after May 1, 2015, at the Court’s convenience.

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Dated: March 4, 2015

LAW OFFICE OF AMY R.
LOVEGREN-TIPTON, APLC

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By/s/Amy R. Lovegren-Tipton
AMY R. LOVEGREN-TIPTON
Attorney for Defendants

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STIPULATION
-2-

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Dated: March 4, 2015

MOORE LAW FIRM, P.C.

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By/s/ Tanya E. Moore_________
TANYA E. MOORE
Attorney for Plaintiff

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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 Defendants’ response to the First Amended Complaint

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is now due on or before March 30, 2015.
IT IS FURTHER ORDERED that the Mandatory Scheduling Conference currently set

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for April 2, 2015 is continued to May 7, 2015 at 10:30 AM , in Courtroom 6, before United

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States Magistrate Judge Michael J. Seng. The Joint Scheduling Conference Statement is to be

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filed no more than seven (7) days prior to the date of the conference.

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IT IS SO ORDERED.

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Dated:

March 6, 2015

/s/

Michael J. Seng

UNITED STATES MAGISTRATE JUDGE
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STIPULATION
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