Korndobler, et al. v. DNC Parks & Resorts

Filing 52

STIPULATION and ORDER EXTENDING DEADLINE TO FILE DISMISSAL. The parties are hereby ORDERED to file appropriate papers to dismiss this action in its entirety on or before April 17, 2017. Order signed by Magistrate Judge Sheila K. Oberto on 3/31/2017. (Timken, A)

SEYFARTH SHAW LLP
Joshua A. Rodine, SBN 237774
[e-mail]
2029 Century Park East, Suite 3500
Los Angeles, California 90067-3021
Telephone:
[phone]
Facsimile:
[phone]
SEYFARTH SHAW LLP
Justin T. Curley, SBN 233287
[e-mail]
Elizabeth J. MacGregor, SBN 267326
[e-mail]
560 Mission Street, 31st Floor
San Francisco, California 94105
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendant
DNC PARKS & RESORTS AT SEQUOIA, INC.
WAGNER, JONES, KOPFMAN & ARTENIAN LLP
Nicholas Wagner, SBN 109455
Andrew B. Jones, SBN 076915
Daniel Kopfman, SBN 192191
Lawrence Artenian, SBN 103367
1111 East Herndon, Suite 317
Fresno, California 93720
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Plaintiffs
MARTIN KORNDOBLER, et al.
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
MARTIN KORNDOBLER, STEPHAN
ERNST, MATT MILLER, CHRISTOPHER
CRUZ, AND GREGORY CHANEY,
Plaintiffs,
v.
DNC PARKS & RESORTS AT SEQUOIA;
and DOES 1 to 100, inclusive,

Case No. 1:15-cv-459-LJO-SKO
STIPULATION AND ORDER
EXTENDING DEADLINE TO FILE
DISMISSAL
Complaint Filed:
SAC Filed:
Trial Date:

March 25, 2015
July 1, 2015
None Set

Defendants.

STIP. TO EXTEND DEADLINE TO FILE DISMISSAL; ORDER / CASE NO. 1:15-cv-459

Pursuant to E.D. Cal. Local Rule 160(b), Plaintiffs Martin Korndobler, Stephan Ernst,
Matt Miller, Christopher Cruz, and Gregory Chaney (“Plaintiffs”), and Defendant DNC Parks &
Resorts at Sequoia, Inc. (“Delaware North”) (collectively, the “Parties”), respectfully request that
the Court extend the deadline to file the appropriate papers to dismiss this action three weeks to
April 17, 2017.
On February 24, 2017, Plaintiffs notified the Court of the Parties’ settlement of this
matter. See Dkt. No. 49. On February 27, 2017, in response to Plaintiffs’ Notice of Settlement,
the Court ordered the Parties to file the appropriate dismissal documents by March 27, 2017. See
Dkt. No. 50. Since that time, the Parties have diligently finalized the terms of a settlement
agreement and release of claims. The settlement agreement has been mailed to all five Plaintiffs
for review and signature, however several Plaintiffs have yet to return a signed copy of the
settlement agreement, due in part to the remote location where they live and work.
As such, because the terms of the settlement agreement have been finalized and the
Parties are simply waiting for the signatures of several of the five Plaintiffs who live and work in
a remote location, good cause exists for the Court to extend the deadline to file the appropriate
papers to dismiss this action. In addition, the requested extension would not delay these
proceedings, nor cause harm or prejudice to the Parties or their counsel because all pending dates
in this matter have been vacated by this Court. See Dkt. No. 50.
Based on the foregoing, the Parties respectfully request that the Court extend the deadline
for the Parties to file dismissal documents to conclude this action three weeks to April 17, 2017.
DATED: March 27, 2017

SEYFARTH SHAW LLP

By:

/s/ Justin Curley
Justin T. Curley
Attorneys for Defendant
DNC PARKS & RESORTS AT
SEQUOIA, INC.

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STIP. TO EXTEND DEADLINE TO FILE DISMISSAL; ORDER / CASE NO. 1:15-cv-459

DATED: March 27, 2017

WAGNER, JONES, KOPFMAN &
ARTENIAN LLP
By:

/s/ Daniel Kopfman as
authorized on March 27, 2017
Daniel Kopfman
Attorneys for Plaintiffs
MARTIN KORNDOBLER, et al.

I, Justin Curley, attest that concurrence in the filing of this stipulation has been obtained from the
signatory Daniel Kopfman, counsel for Plaintiffs.
/s/ Justin T. Curley
Justin T. Curley

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STIP. TO EXTEND DEADLINE TO FILE DISMISSAL; ORDER / CASE NO. 1:15-cv-459

ORDER
Pursuant to the above-stipulation of the Parties (Doc. 51), and good cause appearing, the
Parties are hereby ORDERED to file appropriate papers to dismiss this action in its entirety on or
before April 17, 2017.
IT IS SO ORDERED.
Dated:

March 31, 2017

/s/

Sheila K. Oberto

UNITED STATES MAGISTRATE JUDGE

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STIP. TO EXTEND DEADLINE TO FILE DISMISSAL; ORDER / CASE NO. 1:15-cv-459

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