Lobato v. Bhandal et al

Filing 8

SECOND STIPULATION AND ORDER TO EXTEND TIME FOR ALL DEFENDANTS TO RESPOND TO THE COMPLAINT; STIPULATION TO CONTINUE DATE FOR MANDATORY SCHEDULING CONFERENCE TO AFFORD THE PARTIES AN OPPORTUNITY TO FULLY EXPLORE SETTLEMENT - The Initial Scheduling Conference currently set 9/22/2016 is CONTINUED TO 11/9/2016 at 01:30 PM in Courtroom 6 (MJS) before Magistrate Judge Michael J. Seng, signed by Magistrate Judge Michael J. Seng on 9/16/216. (Kusamura, W)

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Bruce A. Neilson #096952
7108 N. Fresno St. #410
Fresno, California 93720
Telephone [phone]
Facsimile [phone]
Attorney for Defendants
Amrik Bhandal and Bhandal Petroleum
Corporation dba Big B’s Travel Center

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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*****

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)
)
)
Plaintiff,
)
vs.
)
)
AMRIK BHANDAL; BHANDAL
)
PETROLEUM CORPORATION dba BIG )
)
B’S TRAVEL CENTER;
)
)
Defendants.
____________________________________ )
RACHEL LOBATO,

CASE NO. 1:16-cv-00833-AWI-MJS
SECOND STIPULATION AND
PROPOSED ORDER TO EXTEND TIME
FOR ALL DEFENDANTS TO RESPOND
TO THE COMPLAINT; STIPULATION
TO CONTINUE DATE FOR
MANDATORY SCHEDULING
CONFERENCE TO AFFORD THE
PARTIES AN OPPORTUNITY TO
FULLY EXPLORE SETTLEMENT

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WHEREAS:
Plaintiff RACHEL LOBATO (“Plaintiff”) filed her complaint in this action on June 16,

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1.

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2016.

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2.

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BHANDAL PETROLEUM CORPORATION dba BIG B’S TRAVEL CENTER (“Defendants”).

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A previous extension of time was granted by Plaintiff within the statutory allowance; thus, court

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approval is required for a further extension of time.

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3.

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been received this week. Time is needed to review the report and finalize a settlement. The parties

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are hopeful a settlement can now be reached if an extension of time is granted to respond and the

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mandatory scheduling conference presently set for September 22, 2016 is continued.

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4.

This is the second request for an extension of time for AMRIK BHANDAL and

Plaintiff and Defendants are in settlement negotiations at this time, and a CASp report has

The parties agree that settlement of this case would save valuable court time and resources.
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Rachel Lobato v. Amrik Bhandal, et al.
Second Stipulation and Proposed Order For Extension of Time

Case No. 1:16-cv-00833-AWI-MJS

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The parties have agreed that the time for all Defendants to answer or otherwise respond to

the Complaint shall be extended up to and including October 13, 2016 pending court approval, and
that the mandatory scheduling conference be continued to a date on or after October 27, 2016 at
the Court’s convenience, also pending court approval.
NOW THEREFORE, Defendants through their attorneys, and Plaintiff RACHEL
LOBATO, through her attorney, hereby stipulate and agree that the time for AMRIK BHANDAL
and BHANDAL PETROLEUM CORPORATION dba BIG B’S TRAVEL CENTER to answer or
otherwise respond to the Complaint shall be extended up to and including October 13, 2016
pending court approval, and that the mandatory scheduling conference be continued to a date on or
after October 27, 2016 at the Court’s convenience, also pending court approval.
IT IS SO STIPULATED.
MOORE LAW FIRM, PC
/s/Tanya E. Moore
Tanya E. Moore, Attorney for Plaintiff Rachel
Lobato

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Dated: September 7, 2016
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Dated: September 7, 2016

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/s/Bruce A. Neilson
Bruce A. Neilson, Attorney for Defendants,
Amrik Bhandal and Bhandal Petroleum Corporation
dba Big B’s Travel Center

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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 mandatory scheduling conference in this action be

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continued from September 22, 2016 to November 9, 2016 at 1:30pm in Courtroom 6 of the above

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entitled court. A joint scheduling report shall be filed no later than seven days prior to this date.

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IT IS ALSO HEREBY ORDERED that the time for all Defendants to answer or otherwise
respond to the Complaint shall be extended up to and including October 13, 2016.

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IT IS SO ORDERED.
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Dated:

September 16, 2016

/s/

Michael J. Seng

UNITED STATES MAGISTRATE JUDGE

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Rachel Lobato v. Amrik Bhandal, et al.
Second Stipulation and Proposed Order For Extension of Time

Case No. 1:16-cv-00833-AWI-MJS

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Rachel Lobato v. Amrik Bhandal, et al.
Second Stipulation and Proposed Order For Extension of Time

Case No. 1:16-cv-00833-AWI-MJS