Johnson v. Park Management Corp.

Filing 6

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 3/24/15. Park Management Corp shall respond to the complaint by 4/13/15. (Manzer, C)

SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
A Limited Liability Partnership
Including Professional Corporations
2 HAYLEY S. GRUNVALD, Cal. Bar No. 227909
12275 El Camino Real, Suite 200
3 San Diego, California 92130-2006
Telephone: [phone]
4 Facsimile: 858.509.3691
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5 Attorneys for Defendant
PARK MANAGEMENT CORP.
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA, FRESNO DIVISION

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SCOTT JOHNSON,
Plaintiff,

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Case No. 2:15-CV-00487-WBS-CKD

v.

PARK MANAGEMENT CORP., a
16 California corporation; and DOES 1-10,

STIPULATION TO EXTEND TIME
FOR DEFENDANT PARK
MANAGEMENT CORP. TO
RESPOND TO PLAINTIFF’S
COMPLAINT
[Complaint Filed: March 5, 2015]

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Defendants.

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SMRH:204098152.3

STIPULATION TO EXTEND TIME FOR DEFENDANT
PARK MANAGEMENT CORP. TO RESPOND TO PLAINTIFF’S COMPLAINT

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Defendant Park Management Corp. ("Defendant") and Plaintiff Scott

2 Johnson, an individual ("Plaintiff"), through their respective, undersigned counsel,
3 stipulate to extend the time for Defendant to file a response to Plaintiff's Complaint.
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Plaintiff filed his complaint on March 5, 2015 and served Defendant with the

5 complaint on March 9, 2015. Defendant must file and serve an answer or otherwise
6 respond to Plaintiff's Complaint by March 30, 2015.
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Defendant needs additional time to investigate adequately the claims alleged

8 in this matter, as well as all potential defenses and/or counterclaims to those claims, and
9 the parties require additional time to discuss possible settlement of claims.
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Accordingly, for good cause appearing, the parties now jointly move the

11 Court for an order extending the time for Defendant to file a response to Plaintiff's
12 Complaint through and including April 13, 2015.
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Counsel for Plaintiff has assented to the electronic filing of this Joint Motion

14 and requested that Defendant's counsel submit an electronic signature on his behalf.
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16 Dated: March 24, 2015

CENTER FOR DISABILITY ACCESS

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By

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/s/ Phyl Grace
MARK POTTER
PHYL GRACE

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Attorneys for Plaintiff
SCOTT JOHNSON

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-1SMRH:204098152.3

JOINT MOTION FOR AN ORDER EXTENDING TIME FOR DEFENDANT
PARK MANAGEMENT CORP. TO RESPOND TO PLAINTIFF’S COMPLAINT

1 Dated: March 24, 2015

SHEPPARD, MULLIN, RICHTER & HAMPTON

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LLP

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By

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/s/ Hayley S. Grunvald
HAYLEY S. GRUNVALD
Attorneys for Defendant
PARK MANAGEMENT CORP.

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-2SMRH:204098152.3

JOINT MOTION FOR AN ORDER EXTENDING TIME FOR DEFENDANT
PARK MANAGEMENT CORP. TO RESPOND TO PLAINTIFF’S COMPLAINT

ORDER

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The Court, having reviewed the Joint Stipulation of plaintiff SCOTT

3 JOHNSON and defendant PARK MANAGEMENT CORP. and finding good cause
4 therefor;
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IT IS HEREBY ORDERED that defendant PARK MANAGEMENT CORP.

6 has until April 13, 2105 to respond to the Complaint.
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IT IS SO ORDERED.

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Dated: March 24, 2015

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-3SMRH:204098152.3

JOINT MOTION FOR AN ORDER EXTENDING TIME FOR DEFENDANT
PARK MANAGEMENT CORP. TO RESPOND TO PLAINTIFF’S COMPLAINT