Jose Escobedo v. Ali et al

Filing 18

STIPULATION and ORDER signed by Chief Judge Morrison C. England, Jr. on 6/2/2015 ORDERING that the Defendant RL & KM, INC. shall have until on or before 6/30/2015 to file an answer or otherwise respond in this action, and that the due date for the filing of the joint status report in this action is continued to 7/15/2015. (Zignago, K.)

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Bruce A. Neilson #096952
7108 N. Fresno St. #410
Fresno, California 93720
Telephone [phone]
Facsimile [phone]
Attorney for Defendant
RL & KM, INC.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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*****
))))))
) CASE NO. 1:15-cv-00499 -MCE-GSA
JOSE ESCOBEDO,
)
) STIPULATION AN ORDER FOR
Plaintiff,
) EXTENSION OF TIME TO RESPOND
) AND TO CONTINUE DUE DATE FOR
vs.
) JOINT STATUS REPORT
)
MAJID ALI dba DUB CUSTOM TIRE;
)
RL & KM, INC.; DUB CUSTOM TIRE &
)
WHEEL dba DUB CUSTOM TIRE,
)
)
Defendants.
)
____________________________________

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WHEREAS:

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1.

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Plaintiff Jose Escobedo filed this action on March 31, 2015, and filed an Amended

Complaint on May 12, 2015.
2.

Plaintiff and Defendant RL & KM, INC. are in settlement negotiations at this time,

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however, the CASp inspection and report needed to finalize a settlement is not yet completed.

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Further the complaint was amended to add the current tenant of the subject property and the old

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tenant has been dismissed. As a result, no defendants have filed responses to the amended

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complaint with Defendant RL & KM, INC.’s response due May 29, 2015 and the tenant, Dub

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Custom Tire & Wheel’s response due June 9, 2015 (which is after the current due date (June 5,

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2015) of the joint status report). No prior extensions for any response to the amended complaint

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have been given.

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3. Accordingly, the parties agree that settlement of this case would save valuable court
time and resources and make preparation of the joint status report conference unnecessary. Further,
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Jose Escobedo v. Majid Ali, et al.
Stip and Proposed Order For Ext of Time and For Due Date of Status Report

Case No. 1: 15-cv-00499

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preparation of the joint status report will add to the costs of the case and make it more difficult to

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reach a settlement.

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4. In order to facilitate settlement, and to allow for the joining of the recently added

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defendant, the parties propose that the time for filing of defendant RL & KM, INC.’s response be

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extended to June 30, 2015 and that the joint status report due date be continued to July 15, 2015.

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NOW THEREFORE, Defendant RL & KM, INC. through its attorney, and Plaintiff Jose

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Escobedo, through his attorneys, hereby stipulate and agree that the new deadline for Defendant

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RL & KM, INC. to file an answer or otherwise respond to the complaint is June 30, 2015, and that

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the due date for the joint status report in this matter shall be continued to July 15, 2015, pending

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court approval.

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IT IS SO STIPULATED.

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Dated: June 1, 2015

MOORE LAW FIRM, PC
/s/Tanya Moore
Tanya Moore, Attorney for Plaintiff JOSE ESCOBEDO

Dated: June 1, 2015

/s/Bruce A. Neilson
Bruce A. Neilson, Attorney for Defendant RL & KM, INC.

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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 Defendant RL & KM, INC. shall have until on or before June

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30, 2015 to file an answer or otherwise respond in this action, and that the due date for the filing of

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the joint status report in this action be continued to July 15, 2015.

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IT IS SO ORDERED.
Dated: June 2, 2015

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Jose Escobedo v. Majid Ali, et al.
Stip and Proposed Order For Ext of Time and For Due Date of Status Report

Case No. 1: 15-cv-00499