Chandler et al v. Carmichael Care, Inc. et al

Filing 15

STIPULATION and ORDER 13 for extension of time signed by Judge John A. Mendez on 4/15/2015. The deadline for parties to conduct Rule 26(f) Conference and to submit Joint Status Report is EXTENDED to and including 7/6/2015. (Marciel, M)

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1 2 3 4 5 6 DAVID L. NEALE (SBN 141225) KRIKOR J. MESHEFEJIAN (SBN 255030) LEVENE, NEALE, BENDER, YOO & BRILL L.L.P. 10250 Constellation Boulevard, Suite 1700 Los Angeles, California 90067 Telephone: (310) 229-1234; Facsimile: (310) 229-1244 Email: dln@lnbyb.com; kjm@lnbyb.com Attorneys for Chapter 11 Debtors and Debtors in Possession /Removing Parties 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 SACRAMENTO DIVISION 11 12 13 14 ESSIE CHANDLER, KENNETH CHANDLER and BRENDA LUKER GILMAN, Plaintiffs, 15 16 vs. 17 CARMICHAEL CARE, INC., a Nevada corporation, NORTH AMERICAN HEALTH CARE, INC., a Nevada corporation, JOHN SORENSEN, and DOES 1 through 50, inclusive, 18 19 20 Case No. 2:15-CV-00411- JAM-AC STIPULATION TO EXTEND DEADLINE TO CONDUCT RULE 26(f) CONFERENCE AND TO SUBMIT JOINT STATUS REPORT FROM APRIL 20, 2015 TO JULY 6, 2015; ORDER Date: Time: Ctrm: Judge: May 6, 2015 9:30 a.m. 6, 14th Floor Hon. John A. Mendez Defendants. 21 22 23 24 25 26 27 28 STIPULATION TO EXTEND DEADLINE TO FILE JOINT STATUS REPORT; [PROPOSED] ORDER 698165.2 1 RECITALS 2 The Court’s Order Requiring Joint Status Report [Dkt. No. 6] (the “Order”) compels the 3 Plaintiffs and the Defendants (together, the “Parties”) to conduct the Rule 26(f) conference and to 4 submit a joint status report within 60 days of the February 19, 2015 removal of this action. As a 5 result, the deadline for the Parties to submit a joint status report is April 20, 2015. 6 Plaintiffs filed a Motion to Remand (“Motion”) on March 24, 2015. Plaintiffs selected a 7 hearing date of May 6, 2015, the earliest available hearing date on the Court’s calendar. 8 Defendants may oppose the Motion. 9 10 The Court’s ruling on the Motion may render the submission of a joint status report moot, because if the Court grants the Motion, no joint status report will be necessary. 11 In order to avoid unnecessary expense, the Parties wish to extend the deadline for 12 conducting the Rule 26(f) conference and submitting a joint status report from April 20, 2015 to 13 and including July 6, 2015 (60 days after the May 6 hearing on the Motion). This is the first 14 request for an extension of this deadline. 15 STIPULATION 16 17 The Parties hereby stipulate to an extension of the deadline for conducting the Rule 26(f) conference and submitting a joint status report from April 20, 2015 to and including July 6, 2015. 18 19 Dated: April 13, 2015 20 BOUTIN JONES, INC. By: /s/ Bashar S. Ahmad Attorneys for Essie Chandler, Kenneth Chandler and Brenda Luker Gilman 21 22 23 24 25 26 27 28 -2698165.2 STIPULATION TO EXTEND DEADLINE TO FILE JOINT STATUS REPORT; [PROPOSED] ORDER 1 Dated: April 13, 2015 2 LEVENE, NEALE, BENDER, YOO & BRILL L.L.P. By:___/s/__________________________ David L. Neale Krikor J. Meshefejian Bankruptcy Attorneys for Defendants Carmichael Care, Inc. and North American Health Care, Inc. 3 4 5 6 7 8 GOOD CAUSE HAVING BEEN SHOWN, the Court orders that the deadline for the 9 10 Parties to conduct the Rule 26(f) conference and to submit a joint status report be extended from 11 April 20, 2015, to and including July 6, 2015. IT IS SO ORDERED. 12 13 14 Dated: 4/15/2015 /s/ John A. Mendez____________ Hon. John A. Mendez United States District Court Judge 15 16 17 18 19 20 21 22 23 24 25 26 27 28 OHSUSA:761591096.1 698165.2 -3- STIPULATION TO EXTEND DEADLINE TO FILE JOINT STATUS REPORT; [PROPOSED] ORDER

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