Lakes v. Bath & Body Works, LLC

Filing 187

ORDER signed by Senior Judge Morrison C. England, Jr. on 10/6/2020 ORDERING 178 that the Hearing on the Motion to Conduct Limited Discovery is CONTINUED to 11/12/2020 at 02:00 PM in Courtroom 7 (MCE) before Senior Judge Morrison C. England Jr. All filing dates are to be calculated pursuant to that continued date. (Reader, L)

1 JEFFREY M. VUCINICH, ESQ. BAR#: 67906
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[e-mail]
ELIZABETH D. RHODES, ESQ. BAR#: 218480
[e-mail]
CLAPP, MORONEY, VUCINICH, BEEMAN and SCHELEY
A PROFESSIONAL CORPORATION
1111 Bayhill Drive, Suite 300
San Bruno, CA 94066
[phone] [phone] FAX

7 Attorneys for Defendant
8 BATH & BODY WORKS, LLC
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UNITED STATE DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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12 CRYSTAL LAKES, an individual,
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Plaintiff,

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vs.

16 BATH & BODY WORKS, LLC, a

Delaware limited liability company,
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Defendants.

Case No. 2:16-cv-02989-MCE-AC
JOINT MOTION FOR
ADMINISTRATIVE RELIEF TO
EXTEND TIME FOR HEARING AND
OPPOSITION TO PLAINTIFF’S
MOTION FOR LEAVE TO CONDUCT
LIMITED DISCOVERY [ECF NO.
178]; ORDER THEREON
[Civil L. R. 7-11]

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Complaint filed: 10/04/2014

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Trial date: N/A

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Plaintiff CRYSTAL LAKES’ PLAINTIFF’S MOTION FOR LEAVE TO

23 CONDUCT LIMITED DISCOVERY [ECF No. 178] is currently pending for hearing on
24 October 15, 2020, so that opposition is due no later than October 1, 2020. As of
25 September 22, 2020, moving defendant BATH & BODY WORKS has substituted in new
26 counsel, Jeffrey M. Vucinich and Elizabeth D. Rhodes, to take over the defense of this
27 matter.[ECF No. 179] Mr. Vucinich and Ms. Rhodes have conferred with plaintiff’s
28 counsel Daniel L. Stanner, Esq., and Mr. Stanner has graciously agreed to allow a 30 day
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JOINT MOTION FOR ADMINISTRATIVE RELIEF TO EXTEND TIME FOR HEARING AND
OPPOSITION TO PLAINTIFF’S MOTION FOR LEAVE TO CONDUCT LIMITED DISCOVERY [ECF NO.
178] PURSUANT TO STIPULATION; STIPULATION; ORDER THEREON

1 continuance if this Court will permit the extension. Good cause exists to co ntinue the
2 hearing as new counsel has had no time to review the contents of the motion that is
3 pending, and time is needed to review the voluminous file in this matter. The signing of
4 this motion sets forth the parties’ agreement and stipulation to this 3 0-day continuance.
5 Administrative relief is therefore respectfully requested, in the form of a continuance of the
6 motion date from October 15, 2020, to a date 30 days forward, within this Court’s
7 discretion, or on November 12, 2020.
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Respectfully submitted,

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10 Dated: September 25, 2020
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CLAPP, MORONEY, VUCINICH,
BEEMAN and SCHELEY

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By: /s/ Jeffrey M. Vucinich
JEFFREY M. VUCINICH, ESQ.
ELIZABETH D. RHODES, ESQ.
Attorneys for Defendant
BATH & BODY WORKS, LLC

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TABET DIVITO & ROTHSTEIN, LLC

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By: /s/ Daniel L. Stanner
DANIEL L. STANNER, ESQ.
Attorneys for Plaintiff, CRYSTAL
LAKES

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JOINT MOTION FOR ADMINISTRATIVE RELIEF TO EXTEND TIME FOR HEARING AND
OPPOSITION TO PLAINTIFF’S MOTION FOR LEAVE TO CONDUCT LIMITED DISCOVERY [ECF NO.
178] PURSUANT TO STIPULATION; STIPULATION; ORDER THEREON

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ORDER
In accordance with the foregoing stipulated motion, and good cause appearing, IT

3 IS HEREBY ORDERED THAT the hearing on plaintiff’s Motion for Leave to Conduct
4 Limited Discovery [ECF No. 178] is continued to November 12, 2020, at 2:00 p.m.., in
5 Courtroom 7. All filing dates are to be calculated pursuant to that continued date.
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IT IS SO ORDERED.

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8 Dated: October 6, 2020
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JOINT MOTION FOR ADMINISTRATIVE RELIEF TO EXTEND TIME FOR HEARING AND
OPPOSITION TO PLAINTIFF’S MOTION FOR LEAVE TO CONDUCT LIMITED DISCOVERY [ECF NO.
178] PURSUANT TO STIPULATION; STIPULATION; ORDER THEREON