Johnson v. Park Management Corp.

Filing 8

STIPULATION and ORDER 7 signed by Senior Judge William B. Shubb on 4/15/2015: Defendant Park Management Corp. has until 4/20/2015 to respond to the Complaint. (Kirksey Smith, K)

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,

SECOND JOINT 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:204141918.1

SECOND 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") (jointly “the Parties”), through their respective,
3 undersigned counsel, stipulate for a second time to extend the time for Defendant to file a
4 response to Plaintiff's Complaint.
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Plaintiff filed his complaint on March 5, 2015 and served Defendant with the

6 complaint on March 9, 2015. Defendant was required to file and serve an answer or
7 otherwise respond to Plaintiff's Complaint by March 30, 2015. The Parties stipulated to
8 allow Defendant to file a response to Plaintiff’s Complaint through and including April 13,
9 2015.
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The Parties request a second extension of time for Defendant to respond to

11 Plaintiff’s Complaint. The Parties are in the process of discussing settlement of the matter
12 and need additional time to conduct settlement negotiations to determine if a settlement is
13 possible of the instant matter. The Parties stipulated to allow Defendant to file a response
14 to Plaintiff’s Complaint through and including April 20, 2015.
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Accordingly, for good cause appearing, the parties now jointly move the

16 Court for an order extending the time for Defendant to file a response to Plaintiff's
17 Complaint through and including April 20, 2015.
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Counsel for Plaintiff has assented to the electronic filing of this Joint Motion

19 and requested that Defendant's counsel submit an electronic signature on his behalf.
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21 Dated: April 13, 2015

CENTER FOR DISABILITY ACCESS

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By

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/s/ Mark Potter
MARK POTTER
PHYL GRACE

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Attorneys for Plaintiff
SCOTT JOHNSON

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-1SMRH:204141918.1

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

1 Dated: April 13, 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:204141918.1

SECOND STIPULATION TO EXTEND 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 20, 2105 to respond to the Complaint.
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IT IS SO ORDERED.

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Dated: April 15, 2015

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-3SMRH:204141918.1

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