Moore v. Topoozian et al

Filing 11

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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1 2 3 4 5 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 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ) ) ) Plaintiff, ) ) vs. ) MARK TOPOOZIAN, Co-Trustee of the ) HARRY TOPOOZIAN 2011 TRUST dated ) August 22, 2011; THOMAS H. TOPOOZIAN, ) ) Co-Trustee of the HARRY TOPOOZIAN ) 2011 TRUST dated August 22, 2011; HARRY ) ) TOPOOZIAN, Co-Trustee of the HARRY TOPOOZIAN 2011 TRUST dated August 22, ) ) 2011; AJMER S. BAINS dba KEVIN & ) ALEX LIQUOR DELI; STEVIE S. GHAG ) dba KEVIN & ALEX LIQUOR DELI; ) ) ) Defendants. ) ) ) 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 1 Plaintiff, Ronald Moore (“Plaintiff”), by and through his counsel; Defendants, Mark 2 Topoozian, Thomas H. Topoozian, and Harry Topoozian (“the Topoozians”), by and through 3 their counsel; and Defendants Ajmer S. Bains (“Bains”), and Stevie S. Ghag (“Ghag,” and 4 together with the Topoozians and Bains, collectively referred to as “Defendants”), who are 5 presently self-represented, hereby stipulate as follows: 6 1. The current responsive pleading deadlines for Defendants are as follows: 7  Mark Topoozian: March 16, 2015 8  Thomas H. Topoozian: March 18, 2015 9  Harry Topoozian: April 27, 2015 10  Ajmer S. Bains: March 30, 2015 11  Stevie S. Ghag: March 30, 2015 12 2. Plaintiff and Defendants are currently exploring settlement, and wish to avoid 13 the costs associated with Defendants preparing and filing responsive pleadings while they 14 exhaust such efforts. As such, they wish to extend the deadline for Defendants Mark 15 Topoozian, Thomas Topoozian, Ajmer S. Bains and Stevie S. Ghag to respond to Plaintiff’s 16 complaint to coincide with the responsive pleading deadline for Harry Topoozian, namely 17 April 27, 2015. 18 19 20 21 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. 4. 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. 22 23 IT IS SO STIPULATED. 24 25 Dated: March 11, 2015 MOORE LAW FIRM, P.C. 26 27 28 /s/ Tanya E. Moore Tanya E. Moore Attorneys for Plaintiff Ronald Moore 1 Dated: March 10, 2015 2 3 GILMORE MAGNESS LEIFER, a Professional Corporation /s/ William H. Leifer William H. Leifer, Attorneys for Defendants, Mark Topoozian, Thomas H. Topoozian, Harry Topoozian 4 5 6 7 8 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 9 10 11 12 13 14 15 16 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. 17 /s/ Tanya E. Moore Tanya E. Moore, Attorney for Plaintiff, Ronald Moore 18 19 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 /// 1 ORDER 2 The parties having so stipulated and good cause appearing, 3 IT IS HEREBY ORDERED that the responsive pleading deadlines for Defendants 4 Mark Topoozian, Thomas H. Topoozian, Ajmer S. Bains, and Stevie S. Ghag are hereby 5 continued to April 27, 2015. 6 At the time each defendant files a response to the complaint, that defendant shall also 7 file the Magistrate Judge consent form indicating whether that defendant consents or declines 8 Magistrate Judge jurisdiction. 9 10 IT IS SO ORDERED. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: March 12, 2015 /s/ Barbara A. McAuliffe UNITED STATES MAGISTRATE JUDGE

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