Kozak et al v. Chabad-Lubavitch Inc. et al

Filing 86

STIPULATION and ORDER signed by Chief Judge Morrison C. England, Jr. on 7/22/2014 ORDERING that any opposition or cross motions to the pending 78 motion for summary judgment are to be filed no later than 7/24/2014, and any reply and cross motion o pposition papers are to be filed no later than 8/7/2014. No other dates or deadlines in this Court's Pretrial Scheduling Order are altered. Reply briefing, if any, to a cross-motion remains due at least one week prior to the 8/21/14 hearing. (Zignago, K.)

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MARK J. WERKSMAN (Cal. Bar No. 120767)
MARK M. HATHAWAY (Cal. Bar No. 151332)
LAW OFFICES OF MARK J. WERKSMAN
888 West Sixth Street, Fourth Floor
Los Angeles, California 90017
Telephone: [phone]
Facsimile: [phone]
E-mail:
[e-mail]
[e-mail]

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Attorneys for Defendant Chabad of California

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UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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THE UNITED STATES OF
AMERICA and STATE OF
CALIFORNIA ex rel. ARIA KOZAK
and DONNA KOZAK,

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Plaintiffs,
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vs.
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CHABAD-LUBAVITCH INC.;
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CHABAD OF CALIFORNIA;
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CHABAD RUNNING SPRINGS
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RESIDENTIAL CAMP; CHABAD
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CHEDER MENACHEM; YESHIVA )
OHR ELCHONON CHABAD; BAIS )
CHANA HIGH SCHOOL; CHABAD )
OF MARINA; AND BAIS CHAYA
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MUSHKA,
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Defendant
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NO. 2:10-cv-01056-MCE-EFB
STIPULATION FOR ORDER RE
FURTHER PLEADINGS AND
HEARING ON PLAINTIFF’S
MOTION FOR SUMMARY
JUDGMENT; ORDER

STIPULATION RECITALS

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Per the PreTrial Scheduling Order, the last day to hear dispositive motions

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was set for September 4, 2014. On June 26, 2014 Plaintiff filed a Notice of Motion

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and Motion For Summary Judgment, Or, Alternatively, Partial Summary

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Judgment, and related pleadings, which motion is set for hearing on August 21,

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2014.

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The defendants’ opposition and any cross motion are due to be filed five
weeks prior to the August 21, 2014, or no later than July 17, 2014.
The plaintiff’s reply and opposition to cross-motion are due to be filed at
least three weeks prior to hearing, or no later than July 31, 2014.

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During private mediation on July 11, 2014, and in a good faith effort to

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assist in possible settlement of the entire case, the parties agreed to seek a one

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week extension of deadlines to file further motion for summary judgment papers;

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to July 24, 2014 for any opposition papers, and to August 7, 2014 for any reply.

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STIPULATION
IT IS HEREBY STIPULATED by and between the parties, acting by and

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through their counsel of record, that the deadline to file any opposition or cross

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motion be extended to July 24, 2014 and the deadline for any reply and opposition

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to cross motions be extended to August 7, 2014.

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Respectfully submitted,

BENJAMIN B. WAGNER
United States Attorney

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By:

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/s/ Glen F. Dorgan
Glen F. Dorgan
Assistant U.S. Attorney

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HIRST LAW GROUP, PC

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By:

/s/ Michael A. Hirst
Michael A. Hirst
Attorneys for the Relators

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LAW OFFICES OF MARK J. WERKSMAN

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By:

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/s/ Mark M. Hathaway
Mark J. Werksman
Mark M. Hathaway
Attorneys for Defendant
CHABAD OF CALIFORNIA

DONALD L. SALTZMAN, PLC

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By:

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/s/ Donald L. Saltzman
Donald L. Saltzman
Attorneys for Defendant and CrossClaimant, Yeshiva Ohr Elchonon Chabad

LAW OFFICES OF ANDREW J. STERN

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By:

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/s/ Andrew J. Stem
Andrew J. Stem
Attorneys for Defendants Chabad of the
Marina and Bais Chaya Mushka

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ORDER
As set forth in the parties’ above stipulation, any opposition or cross motions

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to the pending motion for summary judgment are to be filed no later than July 24,

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2014, and any reply and cross motion opposition papers are to be filed no later than

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August 7, 2014. No other dates or deadlines in this Court’s Pretrial Scheduling

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Order are altered. Reply briefing, if any, to a cross-motion remains due at least

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one week prior to the 8/21/14 hearing.

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IT IS SO ORDERED.
Dated: July 22, 2014

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