Moore v. Zamzami et al

Filing 13

Third 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 Amira M. Alzamzami to respond to the complaint; Order, signed by Magistrate Judge Stanley A. Boone on 6/12/2015. (Response due by 6/30/2015) (Rosales, O)

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

THIRD 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 30, 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 third extension of time as Defendants have retained a CASp
consultant and a contractor, and have approached Plaintiff’s counsel to discuss settlement.

7
8
9
10
11
12

Plaintiff’s counsel has scheduled a Rule 26 meet and confer call for Tuesday, June 16, 2015. 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: June 12, 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: June 12, 2015

MOORE LAW FIRM, P.C.

24
25
26
27

By: /s/ Tanya E. Moore____________________
Tanya E. Moore, Esq.
Attorneys for Plaintiff
RONNALD 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
9

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 30, 2015 to respond to Plaintiff RONALD MOORE’s
Complaint.
IT IS SO ORDERED.

10
11

Dated:

June 12, 2015
UNITED STATES MAGISTRATE JUDGE

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

3