Kuang v. Bel Air Mart

Filing 5

STIPULATION and ORDER signed by Judge John A. Mendez on 3/6/15 ORDERING that Defendant's deadline to respond to the Complaint is EXTENDED to 4/7/15. (Kastilahn, A)

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A PROFESSIONAL CORPORATION
Lindsay A. Goulding, SBN 227195
Colleen R. Howard, SBN 257661
350 University Avenue, Suite 200
Sacramento, California 95825
TEL: [phone]
FAX: [phone]

Attorneys for Defendant
BEL AIR MART

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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PORTER | SCOTT

350 University Avenue, Suite 200
Sacramento, CA 95825
TEL: [phone]
FAX: [phone]

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Civil Action No.: 2:15-cv-00160

JIMMY KUANG, an individual,

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Plaintiff,

STIPULATION AND ORDER TO
EXTEND TIME TO RESPOND TO
COMPLAINT

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v.
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BEL AIR MART; a California Corporation;
and DOES 1 through 50, inclusive,

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Defendant.
____________________________________/

Complaint Filed: 1/20/15

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I

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INTRODUCTION

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Plaintiff alleges wrongful termination in violation of the Labor Management Relations Act

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(LMRA) against his former employer, Defendant BEL AIR MART. Defendant contends that

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Plaintiff’s suit has been filed beyond the statute of limitations. Plaintiff has requested additional

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time to fully analyze this issue.

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II

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STIPULATION

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The Parties hereby stipulate as follows:

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1.

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Plaintiff desires additional time to analyze the arguments raised by defendant,

which plaintiff understands will form the basis of a motion to dismiss should plaintiff fail to
{01373640.DOCX}

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STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT; AND ORDER THEREON

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dismiss his case, with prejudice;
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In light of plaintiff’s need for additional time to analyze this issue, and in an effort

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to avoid unnecessary expenses and litigation, the parties hereby stipulate to an extension of time

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for defendant to respond to the Complaint, which shall now be due by April 7, 2015.

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3.

Neither party is prejudiced by this extension.

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III

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CONCLUSION

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For the foregoing reasons, the parties ask this court to grant an order extending defendant’s
deadline to respond to the Complaint to April 7, 2015.

PORTER | SCOTT

IV

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350 University Avenue, Suite 200
Sacramento, CA 95825
TEL: [phone]
FAX: [phone]

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ATTESTATION

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I hereby attest that I have permission from plaintiff counsel to file this stipulation.

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Dated: March 6, 2015

PORTER SCOTT
A PROFESSIONAL CORPORATION

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By

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/S/ Lindsay A. Goulding
Lindsay A. Goulding
Attorney for Defendant Raley’s

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Dated: March 6, 2015

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By

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/S/ Mona Tashroudian
Mona Tashroudian
Attorney for Plaintiff Jimmy Kuang

ORDER

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TASHROUDIAN LAW GROUP

After considering the parties’ Stipulation and GOOD CAUSE SHOWN, it is ordered that

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Defendant’s deadline to respond to the Complaint shall be extended to April 7, 2015.

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Dated: March 6, 2015

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/s/ John A. Mendez_____
Hon. John A. Mendez
U.S. District Court Judge

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{01373640.DOCX}

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STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT; AND ORDER THEREON