Johnson v. PD Hotel Associates, LLC, et al

Filing 21

STIPULATION and ORDER signed by Judge John A. Mendez on 7/15/2011 ORDERING 18 Settlement Conference set before Magistrate Judge Dale A. Drozd, on 10/20/2011 at 10:00 AM. (Reader, L)

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PAUL L. REIN, Esq. (SBN 43053)
CELIA MCGUINNESS, Esq. (SBN 159420)
CATHERINE M. CABALO, Esq. (SBN 248198)
LAW OFFICES OF PAUL L. REIN
200 Lakeside Drive, Suite A
Oakland, CA 94612
Telephone: [phone]
Facsimile: 510/832-4787
[e-mail]
Attorneys for Plaintiff
ROOSEVELT JOHNSON

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R. LAWRENCE BRAGG, Esq.
VITALE & LOWE
9 3249 Quality Drive, Suite 200
Rancho Cordova, CA 95670-6098
10 Telephone: [phone]
Facsimile: 916/851-3770
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Attorneys for Defendants
PD HOTEL ASSOCIATES, LLC
dba RADISSON HOTEL SACRAMENTO, and
13 DOW PRE II, LLC
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IN THE UNITED STATES DISTRICT COURT
IN AND FOR THE EASTERN DISTRICT OF CALIFORNIA

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ROOSEVELT JOHNSON,
Plaintiff,

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CASE NO. 2:10-cv-1407 JAM-DAD
Civil Rights

v.

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PD HOTEL ASSOCIATES, LLC, a
California limited liability company
22 dba RADISSON HOTEL
SACRAMENTO; DOW PRE II, LLC,
23 a Delaware limited liability company;
and DOES 1-10, INCLUSIVE,

STIPULATION AND ORDER TO
SET SETTLEMENT CONFERENCE

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Defendants.

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/

Plaintiff ROOSEVELT JOHNSON (“Plaintiff”) and Defendants PD

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HOTEL ASSOCIATES, LLC dba RADISSON HOTEL SACRAMENTO and

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DOW PRE II, LLC (together sometimes “Defendants”), by and through their

L A W O F F IC E S O F

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 SET SETTLEMENT CONFERENCE
CASE NO. 2:10-cv-1407 JAM-DAD

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C:\Documents and Settings\HVine\Desktop\10cv1407.o.71511.wpd

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respective counsel, jointly stipulate and request through their attorneys of record

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as follows:

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The parties have recently settled injunctive relief aspects of this case

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and will be filing a Consent Decree and Proposed Order reflecting this settlement.

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The parties believe that there is a good likelihood that the assistance of an

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experienced magistrate judge would contribute to an early settlement of the

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remaining issues of damages, attorneys' fees, litigation expenses, and costs.

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Based on the above, the parties hereby agree and stipulate to a

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settlement conference being set in this case before assigned Magistrate Judge

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Dale A. Drozd as soon as possible. Pursuant to Local Rule 270(b), the parties

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expressly waive any claim of disqualification and agree to have Judge Drozd

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continue to act as Magistrate in this action thereafter.

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IT IS SO STIPULATED.

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Dated: July 6, 2011

LAW OFFICES OF PAUL L. REIN

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/s/ Catherine M. Cabalo
By: CATHERINE M. CABALO
Attorneys for Plaintiff
ROOSEVELT JOHNSON

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Dated: July 6, 2011

VITALE & LOWE

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/s/ R. Lawrence Bragg
By: R. LAWRENCE BRAGG
Attorneys for Defendants
PD HOTEL ASSOCIATES, LLC
dba RADISSON HOTEL SACRAMENTO, and
DOW PRE II, LLC

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L A W O F F IC E S O F

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 SET SETTLEMENT CONFERENCE
CASE NO. 2:10-cv-1407 JAM-DAD

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C:\Documents and Settings\HVine\Desktop\10cv1407.o.71511.wpd

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ORDER
Good cause having been shown, the Court grants the parties’
stipulation and request to set a settlement conference in this case on October 20,
2011 at 10:00 a.m. with Magistrate Judge Dale A. Drozd.
PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated: 7/15/2011

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

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L A W O F F IC E S O F

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 SET SETTLEMENT CONFERENCE
CASE NO. 2:10-cv-1407 JAM-DAD

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C:\Documents and Settings\HVine\Desktop\10cv1407.o.71511.wpd