O'Campo v. Golden Bear Restaurant Group Inc., et al

Filing 16

ORDER signed by District Judge Troy L. Nunley on 9/20/17 GRANTING Request for continuance for Dispositive Motions Hearing. The deadline to hear dispositive Motions is EXTENDED from 10/5/17 to 11/16/2017. (Mena-Sanchez, L)

LEWIS BRISBOIS BISGAARD & SMITH LLP

1 SHANE SINGH, SB# 202733

E-Mail: [e-mail]

2 ASHLEY N. ARNETT, SB# 305162

E-Mail: [e-mail]

3 2020 West El Camino Avenue, Suite 700
Sacramento, California 95833

4 Telephone: [phone]
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Facsimile: 916.564.5444
Attorneys for Defendants, GOLDEN BEAR

6 RESTAURANT GROUP, INC. dba ARBY’S,
JOSEPH POLATI, TRUSTEES of the POLATI

7 FAMILY TRUST DATED JULY 29, 2009;

TRACI POLATI, TRUSTEE of the POLATI

8 FAMILY TRUST DATED JULY 29, 2009
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION

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13 DIMAS O’CAMPO,

CASE NO. 2:15-cv-01849-TLN-CMK

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REQUEST FOR CONTINUANCE FOR
DISPOSITIVE MOTION HEARING

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Plaintiff,
vs.

16 GOLDEN BEAR RESTAURANT GROUP,
INC. dba ARBY’S; JOSEPH POLATI,

17 TRUSTESS of the POLATI FAMILY TRUST

The Hon. Troy L. Nunley
Trial Date:

March 12, 2018

DATED JULY 29, 2009; TRACI POLATI,

18 TRUSTEE of the POLATI FAMILY TRUST
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DATED JULY 29, 2009,
Defendants.

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TO: The Honorable Court,

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Defendants, Golden Bear Restaurant Group, Inc. dba Arby’s, Joseph Polati, Trustees of the

26 Polati Family Trust dated July 29, 2009, Traci Polati, Trustee of the Polati Family Trust Dated
27 July 29, 2009, and Plaintiff, Dimas O’Campo (collectively “the Parties”), by and through their

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4851-6010-9391.1

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REQUEST FOR CONTINUANCE FOR DISPOSITIVE MOTION HEARING

1 respective attorneys of record, hereby stipulate as follows:
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WHEREAS, the Pretrial Scheduling Order issued on February 1, 2016, indicates that “All

3 dispositive motions . . . shall be heard no later than October 5, 2017. See Docket No. 10.
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WHEREAS, due to a family medical emergency of Defense counsel, the Parties met and

5 conferred, and mutually agreed, to continue the deadline to hear dispositive motions at least thirty
6 (30) days. Given that the Court only hears civil law and motion on a limited number of days each
7 month, the Parties mutually agreed to continue the date to November 16, 2017.
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NOW THEREFORE, the Parties hereby stipulate and hereby request that the Court’s

9 Pretrial Scheduling Order (Docket No. 10) be modified to extend the deadline to hear dispositive
10 motions from October 5, 2017 to November 16, 2017.
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IT IS SO STIPULATED.

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DATED: September 14, 2017

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LEWIS BRISBOIS BISGAARD & SMITH

By:

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LLP

/s/ Shane Singh, Esq.
Shane Singh, Esq.
Attorneys for Defendants, GOLDEN BEAR
RESTAURANT GROUP, INC. dba ARBY’S,
JOSEPH POLATI, TRUSTEES of the POLATI
FAMILY TRUST DATED JULY 29, 2009;
TRACI POLATI, TRUSTEE of the POLATI
FAMILY TRUST DATED JULY 29, 2009

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DATED: September 14, 2017

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DISABLED ADVOCACY GROUP, APLC

By: /s/ Scottlyn J. Hubbard IV, Esq.
Scottlyn J. Hubbard IV
Stephanie Ross
Attorneys for Plaintiff, DIMAS O’CAMPO

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REQUEST FOR CONTINUANCE FOR DISPOSITIVE MOTION HEARING

Signature Certification

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I hereby certify that the content of this document is acceptable to Scottlyn J.

3 Hubbard, counsel for Plaintiff, Dimas O’Campo, and that I have obtained Mr.
4 Hubbard’s authorization to affix his electronic signature to this document.
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6 DATED: September 14, 2017

LEWIS BRISBOIS BISGAARD & SMITH

LLP

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By: /s/ Shane Singh
Shane Singh
Attorneys for Defendants, GOLDEN
BEAR RESTAURANT GROUP, INC. dba
ARBY’S, JOSEPH POLATI, TRUSTEES
of the POLATI FAMILY TRUST DATED
JULY 29, 2009; TRACI POLATI,
TRUSTEE of the POLATI FAMILY
TRUST DATED JULY 29, 2009

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IT IS SO ORDERED.

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19 Dated: September 20, 2017
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Troy L. Nunley
United States District Judge

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REQUEST FOR CONTINUANCE FOR DISPOSITIVE MOTION HEARING