Loskot v. Annie's Panda Garden, et al

Filing 28

STIPULATION and ORDER signed by Judge John A. Mendez on 11/24/14 re: 27 : Plaintiff shall have up to and including 1/5/15 to file a Fee Application in the above-captioned action. (Meuleman, A)

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THOMAS E. FRANKOVICH (State Bar No. 074414)
THOMAS E. FRANKOVICH,
A Professional Law Corporation
4328 Redwood Hwy, Suite 300
San Rafael, CA 94903
Telephone:
415/674-8600
Facsimile:
415/674-9900
Attorney for Plaintiff
MARSHALL LOSKOT

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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)
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Plaintiff,
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v.
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ANNIE’S PANDA GARDEN; SHIH KUN )
WANG and HONG YING WANG, as Co- )
Trustees under that certain DECLARATION )
OF TRUST executed September 21, 1993; )
and SU NI ZHENG, an individual dba
)
ANNIE’S PANDA GARDEN,
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)
Defendants.
)
____________________________________)

CASE NO. 2:13-cv-00213-JAM-JFM

MARSHALL LOSKOT,

REQUEST AND STIPULATION TO
EXTEND TIME FOR FEE APPLICATION;
and ORDER THEREON

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The parties by, through their respective attorney of record, request that this Court

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extend the time to for Plaintiff’s to submit his Fee Application to January 5, 2015, for the

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following reasons:

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1.

Whereas, plaintiff’s counsel will be out of the County of Marin and/or State of

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California from November 22, 2014 through December 10, 2014, and on vacation from

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December 23, 2014 through January 5, 2015; and

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REQUEST AND STIPULATION TO EXTEND TIME TO SUBMIT FEE APPLICATION
CASE NO. 2:13-cv-00213-JAM-JFM

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Whereas, defendants’ counsel, as of the date of this stipulation, is presently out of

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State from November 21, 2014 through December 5, 2014, and his office will be closed from

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December 23, 2014 to January 2, 2015; and

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3.

Whereas, defense counsel Michael Welch, in discussing the settlement aspects

with his clients has to deal with cultural differences.

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IT IS SO STIPULATED:

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It is stipulated and respectfully requested that the plaintiff has up to and including January

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5, 2015, to submit a Fee Application.

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Dated: November 21, 2014

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THOMAS E. FRANKOVICH,
A PROFESSIONAL LAW CORPORATION
By:

/s/ Thomas E. Frankovich
Thomas E. Frankovich
Attorney for Plaintiff CRAIG YATES, an
individual

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Dated: November 20, 2014

MICHAEL WELCH
Michael Welch & Associates

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By:_/s/Michael D. Welch_____________________
Michael D. Welch
Attorney for Defendants ANNIE’S PANDA
GARDEN; SHIH KUN WANG and HONG qYING
WANG, as Co-Trustees under that certain
DECLARATION OF TRUST executed September
21, 1993; and SU NI ZHENG, an individual dba
ANNIE’S PANDA GARDEN

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REQUEST AND STIPULATION TO EXTEND TIME TO SUBMIT FEE APPLICATION
CASE NO. 2:13-cv-00213-JAM-JFM

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ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED: That plaintiff shall have up

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to and including January 5, 2015, to file a Fee Application in the above - captioned action.
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Dated: November 24, 2014

/s/ John A. Mendez____________
Honorable Judge John A. Mendez
United Sates District Court,
Eastern District of California

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REQUEST AND STIPULATION TO EXTEND TIME TO SUBMIT FEE APPLICATION
CASE NO. 2:13-cv-00213-JAM-JFM

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