Martinez, et al., v. SCC Florin Road Bingo, et al.,

Filing 28

STIPULATION and ORDER 27 for continuance signed by Judge Garland E. Burrell, Jr. on 3/25/2011. Expert Disclosure is now due 4/11/2011 and Supplemental Expert Disclosures to be submitted by 4/25/2011. (Marciel, M)

Martinez, et al., v. SCC Florin Road Bingo, et al.,

Doc. 28

1 PAUL L. REIN, Esq. (SBN 43053)

2 CATHERINE M. CABALO (SBN 248198) 3 200 Lakeside Drive, Suite A 4 Telephone: [phone]

CELIA McGUINNESS, Esq. (SBN 159420) LAW OFFICES OF PAUL L. REIN Oakland, CA 94612 Facsimile: [phone] Attorneys for Plaintiffs JOSE MARTINEZ

5

6 CONNIE MARTINEZ and 7 8 GREVE, CLIFFORD, WENGEL & PARAS, LLP

Sacramento, CA 95833-4324 [e-mail] Telephone: [phone] Facsimile: [phone]
10 E-Mail: 12 Attorneys for Defendants 13 dba Florin Road Bingo, incorrectly sued as

9 2870 Gateway Oaks Drive, Suite 210

SCOTT E. COFER, Esq. (SBN 121212)

SACRAMENTO CONSOLIDATED CHARITIES, SCC FLORIN ROAD BINGO; KEVIN BEERS; identified following caption]

14 and SHAW MARTINEZ, incorrectly sued as SHAWN MARTINEZ 15 [Counsel for additional Defendant 16 17 18 19 CONNIE MARTINEZ and

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA JOSE MARTINEZ, v. SECOND STIPULATION AND [PROPOSED] ORDER TO CONTINUE PRE-TRIAL DEADLINES FOR INITIAL EXPERT WITNESS DISCLOSURE REPORTS AND SUPPLEMENTAL EXPERT DISCLOSURE REPORTS CASE NO. 2:10-cv-01647 GEB-GGH GEB-GGH Civil Rights

20 21 22 23

Plaintiffs,

SCC FLORIN ROAD BINGO; 24 SACRAMENTO CONSOLIDATED CHARITIES; KEVIN BEERS; 25 SHAWN MARTINEZ; ARC PROPERTIES, INC.; AND DOES 26 1-10, INCLUSIVE,
27 28
L A W O F F IC E S O F

Defendants. /
-1Dockets.Justia.com

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

4826-9073-2297.1

1 LEWIS, BRISBOIS, BISGAARD 2 MELISSA T. OMANSKY, Esq. (SBN 227451) 3 Los Angeles, CA 90012

& SMITH LLP E-Mail:

221 North Figueroa Street, Suite 1200 [e-mail] Facsimile: (213) 2507900 Attorneys for Defendant

4 Telephone: [phone]

6 ARC PROPERTIES, INC. 7

Plaintiffs CONNIE MARTINEZ and JOSE MARTINEZ and Defendants

8 SACRAMENTO CONSOLIDATED CHARITIES dba Florin Road Bingo 9 (incorrectly sued as SCC FLORIN ROAD BINGO), KEVIN BEERS, SHAW 10 MARTINEZ and ARC PROPERTIES, INC., by and through their respective counsel, 11 hereby jointly stipulate and request, through their attorneys of record, as follows: 12

The parties have been working cooperatively to settle injunctive relief aspects

13 of this case and believe that there is a good likelihood that the parties will be able to 14 settle all issues of injunctive relief, damages, and attorneys' fees, litigation expenses 15 and costs if given more time. Specifically, and with the expectation that it will 16 expedite settlement discussions, counsel for SACRAMENTO CONSOLIDATED 17 CHARITIES dba Florin Road Bingo (incorrectly sued as SCC FLORIN ROAD 18 BINGO) desires to circulate to counsel for Plaintiffs its expert report for review prior 19 to being required to file and serve its formal Expert Witness Disclosure 20 Statement/Reports. 21

Plaintiff has indicated that it will convey a demand to Defendant Arc

22 Properties, Inc. within the next week and the parties are hopeful that a satisfactory 23 resolution can be reached as a result. On March 9, 2011, the parties stipulated to a 24 two week continuance of the deadlines for the initial Expert Disclosure and 25 Supplemental Expert Disclosure. They parties now request that, as a result of the 26 continued settlement activity, the dates be continued a second time for an additional 27 two (2) week period. 28
L A W O F F IC E S O F

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

4826-9073-2297.1

-2-

1 2 3 4

The current deadlines in this case are as follows: Expert disclosure: Supplemental expert disclosure: March 28, 2011 April 28, 2011

Based on the above, the parties hereby agree and stipulate to the continuation Expert disclosure: Supplemental expert disclosure: IT IS SO STIPULATED. LAW OFFICES OF PAUL L. REIN By /s/ Catherine M. Cabalo CATHERINE M. CABALO, Esq. Attorneys for Plaintiffs CONNIE MARTINEZ and JOSE MARTINEZ April 11, 2011 April 25, 2011

5 of the above-noted deadlines in this case to the following: 6 7 8 9 10 11 12 Dated: March 9, 2011. 13 14 15 16 17 18 19 Dated: March 9, 2011. 20 21 22 23 24 25 26 Dated: March 10, 2011. 27 28
L A W O F F IC E S O F

GREVE, CLIFFORD, WENGEL & PARAS, LLP

By

/s/ Scott E. Cofer SCOTT E. COFER, Esq. Attorneys for Defendants SACRAMENTO CONSOLIDATED CHARITIES dba Florin Road Bingo, KEVIN BEERS and SHAW MARTINEZ

LEWIS, BRISBOIS, BISGAARD & SMITH LLP

By

/s/ Melissa T. Omansky MELISSA T. OMANSKY, Esq. Attorneys for Defendant ARC PROPERTIES, INC.

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

4826-9073-2297.1

-3-

1 2

ORDER Good cause having been shown, the Court grants the parties' stipulation Expert disclosure: Supplemental expert disclosure: April 11, 2011 April 25, 2011

3 and request to continue deadlines in this case to the following: 4 5 6

PURSUANT TO STIPULATION, IT IS SO ORDERED.

7 Dated: March 25, 2011 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
L A W O F F IC E S O F

GARLAND E. BURRELL, JR. United States District Judge

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

4826-9073-2297.1

-4-

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
L A W O F F IC E S O F

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

4826-9073-2297.1

-5-

1 2 3

FEDERAL COURT PROOF OF SERVICE Connie Martinez, et al. v. SCC Florin Road Bingo, et al. - File No. 28833-32 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES At the time of service, I was over 18 years of age and not a party to the Angeles, California 90012. I am employed in the office of a member of the bar of

4 action. My business address is 221 North Figueroa Street, Suite 1200, Los 5 this Court at whose direction the service was made. 6

On March 25, 2011, I served the following document(s): SECOND STIPULATION AND [PROPOSED] ORDER TO CONTINUE PRE-TRIAL 7 DEADLINES FOR INITIAL EXPERT WITNESS DISCLOSURE REPORTS AND SUPPLEMENTAL EXPERT DISCLOSU
8 9 (including fax numbers and e-mail addresses, if applicable):

I served the documents on the following persons at the following addresses

10 Attorneys for Plaintiffs CONNIE MARTINEZ nd JOSE MARTINEZ: 11 CELIA MCGUINNES, Esq.

PAUL L. REIN, Esq.

12 LAW OFFICES OF PAUL L. REIN 13 Oakland, CA 94612

CATHERINE M. CABALO

200 Lakeside Drive, Suite A Fax: [phone]

14 Tel: [phone]

E-Mail: [e-mail] Attorneys for Defendants SACRAMENTO CONSOLIDATED CHARITIES, dba BEERS; and SHAW MARTINEZ, incorrectly sued as SHAWN MARTINEZ SCOTT E. COFER, Esq. Tel: [phone] Sacramento, Ca 95833-4324

16 Florin Road Bingo, incorrectly sued as SCC FLORIN ROAD BING; KEVIN 17 GREVE, CLIFFORD, WENGEL & PARAS, LLP 18 2870 Gateway Oaks Drive, Suite 210 19 E-Mail: [e-mail] 20 Fax: [phone] [X] 23 24

The documents were served by the following means: (BY COURT'S CM/ECF SYSTEM) Pursuant to Local Rule, I electronically filed the documents with the Clerk of the Court using the CM/ECF system, which sent notification of that filing to the persons listed above. I declare under penalty of perjury under the laws of the United States of Executed on March 25, 2011, at Los Angeles, California. MARY ANN CAMPI

25 America that the above is true and correct. 26 27 28
L A W O F F IC E S O F

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

4826-9073-2297.1