Moore v. Topoozian et al
Filing
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STIPULATION to Extend Time for Mark Topoozian, Thomas H. Topoozian, Ajmer S. Bains, and Stevie S. Ghag to Respond to the Complaint; ORDER - responsive pleading deadlines for Defendants due by April 27, 2015. At the time each defendant files a res ponse to the complaint, that defendant shall alsofile the Magistrate Judge consent form indicating whether that defendant consents or declines Magistrate Judge jurisdiction. signed by Magistrate Judge Barbara A. McAuliffe on 3/12/2015. (Herman, H)
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Tanya E. Moore, SBN 206683
MOORE LAW FIRM, P.C.
332 North Second Street
San Jose, California 95112
Telephone (408) 298-2000
Facsimile (408) 298-6046
E-mail: tanya@moorelawfirm.com
Attorneys for Plaintiff
Ronald Moore
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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Plaintiff,
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vs.
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MARK TOPOOZIAN, Co-Trustee of the
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HARRY TOPOOZIAN 2011 TRUST dated )
August 22, 2011; THOMAS H. TOPOOZIAN, )
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Co-Trustee of the HARRY TOPOOZIAN
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2011 TRUST dated August 22, 2011; HARRY )
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TOPOOZIAN, Co-Trustee of the HARRY
TOPOOZIAN 2011 TRUST dated August 22, )
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2011; AJMER S. BAINS dba KEVIN &
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ALEX LIQUOR DELI; STEVIE S. GHAG
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dba KEVIN & ALEX LIQUOR DELI;
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Defendants.
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RONALD MOORE,
No. 1:15-CV-00244---BAM
STIPULATION TO EXTEND TIME FOR
MARK TOPOOZIAN, THOMAS H.
TOPOOZIAN, AJMER S. BAINS, AND
STEVIE S. GHAG TO RESPOND TO THE
COMPLAINT; ORDER
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Plaintiff, Ronald Moore (“Plaintiff”), by and through his counsel; Defendants, Mark
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Topoozian, Thomas H. Topoozian, and Harry Topoozian (“the Topoozians”), by and through
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their counsel; and Defendants Ajmer S. Bains (“Bains”), and Stevie S. Ghag (“Ghag,” and
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together with the Topoozians and Bains, collectively referred to as “Defendants”), who are
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presently self-represented, hereby stipulate as follows:
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1.
The current responsive pleading deadlines for Defendants are as follows:
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Mark Topoozian: March 16, 2015
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Thomas H. Topoozian: March 18, 2015
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Harry Topoozian: April 27, 2015
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Ajmer S. Bains: March 30, 2015
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Stevie S. Ghag: March 30, 2015
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2.
Plaintiff and Defendants are currently exploring settlement, and wish to avoid
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the costs associated with Defendants preparing and filing responsive pleadings while they
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exhaust such efforts. As such, they wish to extend the deadline for Defendants Mark
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Topoozian, Thomas Topoozian, Ajmer S. Bains and Stevie S. Ghag to respond to Plaintiff’s
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complaint to coincide with the responsive pleading deadline for Harry Topoozian, namely
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April 27, 2015.
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3.
This extension of time does not alter any date or event already set by Court
order, including the May 12, 2015 Status/Scheduling Conference.
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For these reasons, the parties hereby stipulate that all Defendants may have to
and including April 27, 2015 within which to file their responsive pleadings.
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IT IS SO STIPULATED.
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Dated: March 11, 2015
MOORE LAW FIRM, P.C.
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/s/ Tanya E. Moore
Tanya E. Moore
Attorneys for Plaintiff
Ronald Moore
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Dated: March 10, 2015
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GILMORE MAGNESS LEIFER,
a Professional Corporation
/s/ William H. Leifer
William H. Leifer, Attorneys for
Defendants, Mark Topoozian,
Thomas H. Topoozian, Harry
Topoozian
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Dated: March 10, 2015
/s/ Ajmer S. Bains
Ajmer S. Bains, Defendant in
Propria Persona
Dated: March 10, 2015
/s/ Stevie S. Ghag
Stevie S. Ghag, Defendant in
Propria Persona
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I attest that the original facsimile signatures of the persons whose electronic signatures are
shown above are maintained by me, and that their concurrence in the filing of this document
and attribution of their signatures was obtained.
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/s/ Tanya E. Moore
Tanya E. Moore, Attorney for
Plaintiff, Ronald Moore
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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 the responsive pleading deadlines for Defendants
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Mark Topoozian, Thomas H. Topoozian, Ajmer S. Bains, and Stevie S. Ghag are hereby
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continued to April 27, 2015.
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At the time each defendant files a response to the complaint, that defendant shall also
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file the Magistrate Judge consent form indicating whether that defendant consents or declines
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Magistrate Judge jurisdiction.
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IT IS SO ORDERED.
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Dated:
March 12, 2015
/s/ Barbara
A. McAuliffe
UNITED STATES MAGISTRATE JUDGE
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