Moore v. Zamzami et al

Filing 11

ORDER to extend time for defendants to respond to complaint. Signed by Magistrate Judge Stanley A. Boone on 5/18/2015. (Hernandez, M)

4

EDWARD L. FANUCCHI, Esq., #040786
JAY M. KELLY, Esq., #272061
QUINLAN, KERSHAW & FANUCCHI, LLP
2125 Merced Street
Fresno, California 93721
Tel: [phone]
Fax: [phone]

5

Attorneys for Defendants NAGI MOHSEN ZAMZAMI, individually and dba CITY WIDE

6

MARKET; KHADIGA M. ZAMZAMI; MOHAMED M. MUTHANA, individually and dba
CITY WIDE MARKET; and AMRIA M. ALZAMZAMI

1
2
3

7
8
9

UNITED STATES DISTRICT COURT

10

EASTERN DISTRICT OF CALIFORNIA

11

RONALD MOORE,

CASE NO. 1:15-CV-00480----SAB

12
13
14
15
16
17
18

STIPULATION TO EXTEND TIME
FOR DEFENDANTS NAGI MOHSEN
ZAMZAMI, individually and dba CITY
WIDE MARKET; KHADIGA M.
ZAMZAMI; MOHAMED M.
MUTHANA, individually and dba CITY
WIDE MARKET; and AMRIA M.
ALZAMZAMITO RESPOND TO THE
COMPLAINT; ORDER

Plaintiffs,
vs.
NAGI MOHSEN ZAMZAMI, individually
and dba CITY WIDE MARKET;
KHADIGA M. ZAMZAMI; MOHAMED
M. MUTHANA, individually and dba CITY
WIDE MARKET; and AMRIA M.
ALZAMZAMI,

19
20

Defendants.

21
22
23
24

IT IS HEREBY STIPULATED AND AGREED, by and between the parties hereto, by
and through their respective counsel, that Defendants NAGI MOHSEN ZAMZAMI,
individually and dba CITY WIDE MARKET; KHADIGA M. ZAMZAMI; MOHAMED M.

25
26

MUTHANA, individually and dba CITY WIDE MARKET; and AMRIA M. ALZAMZAMI

27

(collectively “Defendants”), shall have an extension of time, to and including June 15, 2015, to

28

respond to Plaintiff RONALD MOORE’s Complaint.

1

A previous extension was provided to Defendants. A Court Order is required as the
1
2

extension now exceeds twenty-eight (28) days. A court Order will not affect any date or event

3

set by the court Order, including the scheduling conference. This extension is sought to afford

4

the parties an opportunity to explore settlement.

5
6

Good cause exists for this second extension of time as Defendants are gathering the
information necessary to explore an informal resolution with Plaintiff, including meeting with

7
8
9
10
11
12

contractors who specialize in accessing requirements for compliance with the Americans with
Disabilities Act. It is the Parties’ hope to fully exhaust informal settlement efforts before
expending attorneys’ fees and Court resources responding to the complaint.
This Stipulation may be executed in counterpart and by facsimile signature, each
of which when executed shall be an original and all of which together shall constitute one in the

13
14
15

same Stipulation.
Dated: May 15, 2015

QUINLAN, KERSHAW & FANUCCHI, LLP.

16
By: /s/ Edward L. Fanucchi_________________
Edward L. Fanucchi, Esq.
Attorneys for Defendants
NAGI MOHSEN ZAMZAMI, individually
and dba CITY WIDE MARKET;
KHADIGA M. ZAMZAMI; MOHAMED
M. MUTHANA individually and dba CITY
WIDE MARKET; and AMRIA M.
ALZAMZAMI

17
18
19
20
21
22
23

Dated: May 15, 2015

MOORE LAW FIRM, P.C.

24
25
26
27

By: /s/ Tanya E. Moore____________________
Tanya E. Moore, Esq.
Attorneys for Plaintiff
RONNIE MOORE

28

2

1
ORDER

2

Pursuant to stipulation between the parties and good cause appearing,
3
IT IS HEREBY ORDERED that Defendants, NAGI MOHSEN ZAMZAMI, individually
4
5
6
7
8

and dba CITY WIDE MARKET; KHADIGA M. ZAMZAMI; MOHAMED M. MUTHANA,
individually and dba CITY WIDE MARKET; and AMRIA M. ALZAMZAMI , shall have an
extension of time to and including June 15, 2015 to respond to Plaintiff RONALD MOORE’s
Complaint.

9
10
11

IT IS SO ORDERED.
Dated:

May 18, 2015
UNITED STATES MAGISTRATE JUDGE

12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

3