Mano v. Rolfe

Filing 10

STIPULATION and ORDER signed by Judge Garland E. Burrell, Jr on 11/12/15: The parties shall complete discovery on or before December 19, 2015. (Kaminski, H)

Mark A. Vegh, SBN 173414
Tyler Lalaguna, SBN 223028
WELLS, SMALL, FLEHARTY & WEIL
A Law Corporation
292 Hemsted Drive
P.O. Box 991828
Redding, CA 96099-1828
[phone]
Fax: [phone]
Attorneys for Defendant Marsha A. Rolfe, a sole proprietor, dba End Zone Bar and Grill
Galen T. Shimoda (Cal. State Bar No. 226752)
Justin P. Rodriguez (Cal. State Bar No. 278275)
Shimoda Law Corp.
9401 East Stockton Blvd., Suite 200
Elk Grove, CA 95624
Telephone: [phone]
Fax: [phone]
Attorneys for Plaintiff Peace Mano

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

PEACE MANO, an individual,

)
)
Plaintiff
)
)
vs.
)
)
MARSHA A. ROLFE, a sole proprietor,
)
d/b/a END ZONE BAR AND GRILL; and )
DOES 1 to 100, inclusive,
)
)
Defendant
)
_____________________________________)

Case No. 2:14-CV-02919-GEB-CMK
STIPULATION AND [PROPOSED]
EXTENDING PERCIPIENT

1
___________________________________________________________________________
STIPULATION AND [PROPOSED] ORDER EXTENDING DISCOVERY CUTOFF

This Stipulation and [Proposed] Order is based on the following facts:
1.

Pursuant to the Court=s February 13, 2015 Scheduling Order, the discovery

cutoff date in this matter is currently set for November 19, 2015.
2.

The parties desire to extend the cutoff for discovery for one month. The

extension of the closure date for discovery is necessary because the parties have had extensive
settlement discussions, which have delayed the taking of the depositions of Plaintiff and
Defendant=s key employees. The parties respectfully request a one-month extension of the
discovery cutoff date so that counsel for both Plaintiff and Defendant can take key witness
depositions, while the parties continue to discuss potential settlement.
3.

No prior continuances have been requested in this matter.

Based upon the foregoing, in order to facilitate this continuing discovery and
evaluation of the case, Plaintiff, Peace Mano, and Defendant, Marsha A. Rolfe, dba End Zone
Bar and Grill, hereby stipulate and seek an order of the Court modifying the Court=s February
13, 2015 Scheduling Order as follows:
(1)

The parties will complete discovery on or before December 19, 2015, and

(2)

All other dates contained within the February 13, 2015 Scheduling Order or

otherwise previously modified are to remain as ordered and are unmodified, altered, or
changed.
This Stipulation may be executed in counter-part and faxed and/or authorized
electronic signature shall be deemed the same as an original execution.

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___________________________________________________________________________
STIPULATION AND [PROPOSED] ORDER EXTENDING DISCOVERY CUTOFF

Dated: November 4, 2015

WELLS, SMALL, FLEHARTY & WEIL

By: /s/ Mark A. Vegh
Mark A. Vegh, Esq.
Tyler Lalaguna, Esq.
Attorneys for Defendant Marsha A. Rolfe
d/b/a End Zone Bar and Grill

Dated: November 4, 2015

SHIMODA LAW CORP.

By: /s/ Justin P. Rodriguez
(As authorized on 11/4/15)
Galen T. Shimoda, Esq.
Justin P. Rodriguez, Esq.
Attorneys for Plaintiff

PURSUANT TO THE ABOVE STIPULATION, IT IS HEREBY ORDERED THAT:
(1)

The parties will complete discovery on or before December 19, 2015; and

(2)

All other dates contained within the February 13, 2015 Scheduling Order or

otherwise previously modified are to remain as ordered and are unmodified, altered, or
changed.
Dated: November 12, 2015

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STIPULATION AND [PROPOSED] ORDER EXTENDING DISCOVERY CUTOFF