Johnson v. Downes et al

Filing 19

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 2/25/16 ORDERING a continuance of the Dispositive Motion Hearing Cut-off to May 12, 2016. (Kastilahn, A)

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CENTER FOR DISABILITY ACCESS
MARK D. POTTER, ESQ., SBN 166317
PHYL GRACE, ESQ., SBN 171771
Mail: P.O. Box 262490
San Diego, CA 92196-2490
Deliveries: 9845 Erma Road, Suite 300
San Diego, CA 92131
Phone: [phone]
Fax: [phone]
[e-mail]

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Attorney for Plaintiff SCOTT JOHNSON

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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Plaintiff,
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v.
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DARLENE RAE DOWNES, in her individual and )
representative capacity as Trustee—Darlene Rae )
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Downes Trust;
)
JEFFRA MCGOWAN;
MICHAEL MCGOWAN; and Does 1-10,
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Defendants.
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Case No.: 2:14-CV-01256-TLN-KJN

SCOTT JOHNSON,

STIPULATION TO CONTINUE
DISPOSITIVE MOTION HEARING CUTOFF
Pretrial Conference: June 30, 2016
Time: 2:00 p.m.
Complaint Filed: December 12, 2013
Honorable Judge Troy Nunley

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JOINT STIPULATION

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Plaintiff Scott Johnson and Defendants Darlene Rae Downes, Jeffra McGowen, and Michael

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McGowan (collectively as “Parties”), jointly request that the court continue the Dispositive Motion

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Hearing Cut-off Date.

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Whereas, Plaintiff filed this lawsuit on May 22, 2014;

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Whereas, the Settlement Conference is currently scheduled for

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Whereas, the Final Pretrial Conference is currently scheduled for June 30, 2016;

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Whereas, the deadline for a hearing on Dispositive Motions is currently scheduled for March

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Joint Stipulation and Order

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Case No.: 2:14-CV-01256-TLN-KJN

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24, 2016;

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Whereas, Parties are actively negotiating settlement and have reached a tentative agreement;

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Whereas Parties wish to avoid incurring unnecessary litigation expenses, but wish to retain

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the right to bring a dispositive motion at a later date should that become necessary;
THEREFORE, in light of the above, the parties respectfully request that the court continue
the Dispositive Motion Hearing Cut-off Date from March 24, 2016 to May 12, 2016.

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Dated: February 23, 2016

CENTER FOR DISABILITY ACCESS

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By:
/s/ Christina Sosa
CHRISTINA SOSA
Attorney for Plaintiff

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Dated: February 23, 2016

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MICHAEL D. WELCH ASSOCIATES
By:
/s/ Michael Welch
MICHAEL D. WELCH
Attorney for Defendant

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Joint Stipulation and Order

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Case No.: 2:14-CV-01256-TLN-KJN

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CENTER FOR DISABILITY ACCESS
MARK D. POTTER, ESQ., SBN 166317
PHYL GRACE, ESQ., SBN 171771
Mail: P.O. Box 262490
San Diego, CA 92196-2490
Deliveries: 9845 Erma Road, Suite 300
San Diego, CA 92131
Phone: [phone]
Fax: [phone]
[e-mail]

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Attorney for Plaintiff SCOTT JOHNSON

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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) Case No.: 2:14-CV-01256-TLN-KJN
)
)
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Plaintiff,
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v.
) ORDER
DARLENE RAE DOWNES, in her individual and )
representative capacity as Trustee—Darlene Rae )
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Downes Trust;
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JEFFRA MCGOWAN;
MICHAEL MCGOWAN; and Does 1-10,
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)
Defendants.
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SCOTT JOHNSON,

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ORDER
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Pursuant to joint stipulation of the parties, and finding good cause therefore, is hereby ordered:
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a continuance of the Dispositive Motion Hearing Cut-off to May 12, 2016.
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IT IS SO ORDERED.
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Dated: February 25, 2016
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Troy L. Nunley
United States District Judge

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Joint Stipulation and Order

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Case No.: 2:14-CV-01256-TLN-KJN

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