Jose Acosta v. Great American Investments, Inc. et al

Filing 9

Second STIPULATION for Extension of Time for All Defendants to Respond to Complaint; ORDER that Defendants, Great American Investments, Inc., dbaGreat American Car Wash; Zeyad Reyad Elalami; and Mamdouh Reyad Elalami, shall have to and including November 16, 2016 within which to file responsive pleadings. signed by Magistrate Judge Barbara A. McAuliffe on 10/28/2016. (Herman, H)

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Tanya E. Moore, SBN 206683
Zachary M. Best, SBN 166035
MOORE LAW FIRM, P.C.
332 North Second Street
San Jose, California 95112
Telephone [phone]
Facsimile [phone]
Email: [e-mail]

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Attorneys for Plaintiff
Jose Acosta

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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JOSE ACOSTA,

)
)
Plaintiff,
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vs.
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GREAT AMERICAN INVESTMENTS, INC., )
dba GREAT AMERICAN CAR WASH, et al., )
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Defendants.
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)

No. 1:16-cv-01258-LJO-BAM
SECOND STIPULATION FOR
EXTENSION OF TIME FOR ALL
DEFENDANTS TO RESPOND TO
COMPLAINT; [PROPOSED] ORDER

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WHEREAS, Plaintiff Jose Acosta (“Plaintiff”), by and through his attorney of record,

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and Defendants Great American Investments, Inc., dba Great American Car Wash; Zeyad

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Reyad Elalami; and Mamdouh Reyad Elalami (“Defendants,” and together with Plaintiff, “the

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Parties”), who are presently seeking counsel and are specially appearing on their own behalf for

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the sole purpose of obtaining this extension, previously entered into a stipulation granting

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Defendants to and including October 25, 2016 to file a responsive pleading in this matter (Dkt.

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6);

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WHEREAS, the Parties are engaged in settlement negotiations and are hopeful that a

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settlement can be reached informally, and desire to conserve attorney’s fees which would be

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incurred in filing the responsive pleading while they exhaust settlement efforts;

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NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the Parties

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that Defendants may have to and including November 16, 2016 to file responsive pleadings in

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this matter. This extension of time does not alter the date of any event or any deadline already

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fixed by Court order.

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Dated: October 27, 2016

MOORE LAW FIRM, P.C.

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/s/ Tanya E. Moore
Tanya E. Moore
Attorneys for Plaintiff
Arthur Owens

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Dated: October 27, 2016

/s/ AJ Rassamni
Defendant, Great American Investments,
Inc., dba Great American Car Wash
By:
AJ Rassamni

Dated: October 27, 2016

/s/ Zeyad Reyad Elalami
Defendant, Zeyad Reyad Elalami

Dated: October 27, 2016

/s/ Mamdouh Reyad Elalami
Defendant, Mamdouh Reyad Elalami

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I attest that the signatures of the persons whose electronic signatures are shown above are
maintained by me, and that their concurrence in the filing of this document and attribution of
their signatures was obtained.

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/s/ Tanya E. Moore
Tanya E. Moore
Attorneys for Plaintiff,
Jose Acosta

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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 Defendants, Great American Investments, Inc., dba

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Great American Car Wash; Zeyad Reyad Elalami; and Mamdouh Reyad Elalami, shall have to

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and including November 16, 2016 within which to file responsive pleadings.

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IT IS SO ORDERED.

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Dated:

October 28, 2016

/s/ Barbara

A. McAuliffe

UNITED STATES MAGISTRATE JUDGE