Jones v. Kwong et al

Filing 19

STIPULATION and ORDER signed by Judge John A. Mendez on 3/4/2011 GRANTING extension of trial and pretrial deadlines. Expert Disclosure due by 8/1/2011. Discovery due by 11/7/2011. Dispositive Motions filed by 12/14/2011. Final Pretrial Conference set for 2/24/2012 at 11:00 AM. Trial set for 4/2/2012 at 09:00 AM in Courtroom 6 (JAM) before Judge John A. Mendez. (Zignago, K.)

Jones v. Kwong et al

Doc. 19

PAUL L. REIN, Esq., (SBN 43053) CELIA McGUINNESS, Esq. (SBN 159420) 2 CATHERINE M. CABALO, Esq. (SBN 248198) LAW OFFICES OF PAUL L. REIN 3 200 Lakeside Drive, Suite A Oakland, CA 94612 4 Telephone: [phone] Facsimile: 510/832-4787
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Attorneys for Plaintiff GUY JONES

SID M. ROSENBERG, Esq. (SBN 129158) LAW OFFICES OF ROSENBERG & LINK 725 30th St., Suite 107 9 Sacramento, CA 95816 Telephone: [phone] Facsimile: 916/447-4750 Attorney for Defendants BRYAN KWONG; SPENCER KWONG; IRENE 12 KWONG; EL PUERTO RESTAURANT, INC.; ISIDRO MARTIN RODRIGUEZ
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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA

GUY JONES, Plaintiff, v.

CASE NO. 2:10-CV-01200 JAM/KJN Civil Rights STIPULATION AND ORDER TO CONTINUE TRIAL AND PRETRIAL DEADLINES

BRYAN KWONG; SPENCER 21 KWONG; IRENE KWONG; EL PUERTO RESTAURANT, INC.; 22 ISIDRO MARTIN RODRIGUEZ; and DOES 1-10, Inclusive,
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L A W O F F IC E S O F

Defendants.

/

Plaintiff GUY JONES ("Plaintiff") and Defendants BRYAN KWONG; SPENCER KWONG; IRENE KWONG; EL PUERTO RESTAURANT, INC.; ISIDRO MARTIN RODRIGUEZ (together sometimes
STIPULATION AND [PROPOSED] ORDER TO CONTINUE TRIAL AND PRE-TRIAL DEADLINES CASE NO. 2:10-CV-01200 JAM/KJN

PAUL L. REIN
200 L A K E S ID E D R ., S U IT E A O A K L A N D , C A 94612-3503 [phone]

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Dockets.Justia.com

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"Defendants"), by and through their respective counsel, jointly stipulate and request through their attorneys of record as follows: On January 14, 2011, Plaintiff forwarded Defendants a draft Consent Decree & Proposed Order addressing all of Plaintiff's injunctive relief claims in this case. On February 9, 2011, the parties met and conferred and made progress toward settling Plaintiff's injunctive relief claims. The parties have been working cooperatively to settle injunctive relief aspects of this case and believe that there is a good likelihood that the parties will be able to settle all issues of injunctive relief, damages, and attorneys' fees, litigation expenses, and costs if given more time ­ specifically time to prepare for and participate in a settlement conference to be set by the Court pursuant to the stipulated order to set a settlement conference in this case, which will be filed contemporaneously with this stipulated order to continue deadlines. The current deadlines in this case are as follows: Expert disclosure: Supplemental expert disclosure: Joint Mid-Litigation Statement: Discovery cut-off: Dispositive Motion filing deadline: Joint Pre-trial Statement: Final Pre-trial Conference: Trial: March 11, 2011 March 18, 2011 May 6, 2011 May 20, 2011 June 22, 2011 August 19, 2011 August 26, 2011 October 3, 2011. Based on the above, the parties hereby agree and stipulate to the continuation of the above-noted deadlines in this case to the following: Expert disclosure: Supplemental expert disclosure: Joint Mid-Litigation Statement:
STIPULATION AND [PROPOSED] ORDER TO CONTINUE TRIAL AND PRE-TRIAL DEADLINES CASE NO. 2:10-CV-01200 JAM/KJN

Dispositive Motion hearing deadline: July 20, 2011

August 1, 2011 August 8, 2011 October 10, 2011
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PAUL L. REIN
200 L A K E S ID E D R ., S U IT E A O A K L A N D , C A 94612-3503 [phone]

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Discovery cut-off: Dispositive Motion filing deadline: Joint Pre-trial Statement: Final Pre-trial Conference: Trial:

November 7, 2011 December 14, 2011 February 17, 2012 February 24, 2012 at 11:00 a.m. April 2, 2012 at 9:00 a.m.

Dispositive Motion hearing deadline: January 11, 2012 at 9:30 a.m.

IT IS SO STIPULATED. Dated: March 3, 2011 LAW OFFICES OF PAUL L. REIN /s/ Catherine M. Cabalo By: CATHERINE M. CABALO Attorneys for Plaintiff GUY JONES

Dated: March 3, 2011

LAW OFFICES OF ROSENBERG & LINK /s/ Sid Rosenberg By: SID M. ROSENBERG Attorney for Defendants BRYAN KWONG; SPENCER KWONG; IRENE KWONG; EL PUERTO RESTAURANT, INC.; ISIDRO MARTIN RODRIGUEZ

PAUL L. REIN
200 L A K E S ID E D R ., S U IT E A O A K L A N D , C A 94612-3503 [phone]

STIPULATION AND [PROPOSED] ORDER TO CONTINUE TRIAL AND PRE-TRIAL DEADLINES CASE NO. 2:10-CV-01200 JAM/KJN

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ORDER (as modified by the Court) Good cause having been shown, the Court grants the parties' stipulation and request to continue deadline s in this case to the following: Expert disclosure: Supplemental expert disclosure: Joint Mid-Litigation Statement: Discovery cut-off: Dispositive Motion filing deadline: Joint Pre-trial Statement: Final Pre-trial Conference: Trial: August 1, 2011 August 8, 2011 October 10, 2011 November 7, 2011 December 14, 2011 February 17, 2012 February 24, 2012 at 11:00 a.m. April 2, 2012 at 9:00 a.m. PURSUANT TO STIPULATION, IT IS SO ORDERED.

Dispositive Motion hearing deadline: January 11, 2012 at 9:30 a.m.

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Dated: 3/4/2011

/s/ John A. Mendez Honorable JOHN A. MENDEZ United States District Court Judge

PAUL L. REIN
200 L A K E S ID E D R ., S U IT E A O A K L A N D , C A 94612-3503 [phone]

STIPULATION AND [PROPOSED] ORDER TO CONTINUE TRIAL AND PRE-TRIAL DEADLINES CASE NO. 2:10-CV-01200 JAM/KJN

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