Wong et al v. Tomaszewski et al

Filing 14

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr. on 3/17/18 ORDERING that The deadline to file a Joint Rule 26(f)(2) Report, currently due on 3/9/18, is CONTINUED to 4/6/2018 and Initial Disclosures shall be served 45 days thereafter. (Mena-Sanchez, L)

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A Professional Corporation
San Jose

Ropers Majesk i Kohn & Ben tley

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LITA M. VERRIER (SBN 181183)
J. MARK THACKER (SBN 157182)
ROPERS, MAJESKI, KOHN & BENTLEY
50 West San Fernando Street, Suite 1400
San Jose, CA 95113
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
Attorneys for Defendants CHRISTOPHER
TOMASZEWSKI and MIKE MERRI
OGNIAN GAVRILOV (SBN 258583)
MICHAEL COLEMAN (SBN 295462)
ELIEZER M. COHEN (302248)
GAVRILOV & BROOKS
2315 Capitol Avenue
Sacramento, CA 95816
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Plaintiffs LEONARD WONG,
SCOTT ZAWADA, MATTHEW ROSE,
MATTHEW LEE and ROBERT WATSON

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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LEONARD WONG, an individual; SCOTT
ZAWADA, an individual; MATTHEW
ROSE, an individual; MATTHEW LEE, an
individual; and ROBERT WATSON, an
individual,
Plaintiffs,

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v.

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CHRISTOPHER TOMASZEWSKI, an
individual; MIKE MERRI, an individual; and
DOES 1 through 25, inclusive,

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CASE NO. 2:18-cv-00039-MCE-AC
STIPULATION REQUESTING
EXTENSION TO FILE F.R.C.P. RULE
26(f)(2) REPORT; ORDER THEREON
Courtroom 7
Hon. Morrison G. England, Jr.
Complaint Filed:
Trial Date:

November 27, 2017
Not Set

Defendants.

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4838-9135-7279.1

STIPULATION REQUESTING EXTENSION TO
FILE F.R.C.P. RULE 26(f)(2) REPORT
CASE NO. 2:18-CV-00039-MCE-AC

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IT IS HEREBY STIPULATED BY AND BETWEEN ALL PARTIES AS
FOLLOWS:
Plaintiffs LEONARD WONG, SCOTT ZAWADA, MATTHEW ROSE, MATTHEW
LEE, and ROBERT WATSON (“Plaintiffs”), and Defendants CHRISTOPHER

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TOMASZEWSKI and MIKE MERRI (“Defendants”) (collectively, the “Parties”), by and through

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their respective counsel of record, hereby respectfully apply to this Court for an Order continuing

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the date for the Parties to submit their Rule 26(f) Joint Report from March 9, 2018, to April 9,

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2018, and exchange Initial Disclosures pursuant to Federal Rule of Civil Procedure (“FRCP”)

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26(a)(1) 45 days after submission of said Joint Report.

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A Professional Corporation
San Jose

Ropers Majeski Kohn & Bentley

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WHEREAS, on January 16, 2018, Defendants filed a motion to dismiss all claims in this
action pursuant to FRCP Rule 12(b)(6) (“Motion to Dismiss”);
WHEREAS, on January 30, 2018, the Court cancelled the originally scheduled March 8,
2018, date for hearing on said motion via minute order; and

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WHEREAS, the Parties have agreed that postponing the Joint Report and Initial

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Disclosures till a date after this Court rules on the pending Motion to Dismiss would allow the

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Parties to avoid potentially unnecessary litigation costs.

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NOW THEREFORE, IT IS HEREBY STIPULATED, between the Parties, subject to this

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Court’s approval, that: the date for the Parties to file its Rule 26(f) Joint Report be postponed until

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April 9, 2018, and the time to serve Initial Disclosures pursuant to FRCP Rule 26(a)(1), be

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continued until forty-five (45) days following the submission of said Joint Report.

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Dated: March 9, 2018

GAVRILOV & BROOKS

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By: /s/ Eliezer M. Cohen (as authorized on 3/9/18)
OGNIAN GAVRILOV
MICHAEL COLEMEN
ELIEZER M. COHEN
Attorneys for Plaintiffs
LEONARD WONG, SCOTT ZAWADA,
MATTHEW ROSE, MATTHEW LEE
and ROBERT WATSON

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4838-9135-7279.1

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STIPULATION REQUESTING EXTENSION TO
FILE F.R.C.P. RULE 26(f)(2) REPORT
CASE NO. 2:18-CV-00039-MCE-AC

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Dated: March 9, 2018

ROPERS, MAJESKI, KOHN & BENTLEY

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By: /s/ Lita M. Verrier
LITA M. VERRIER
J. MARK THACKER
Attorneys for Defendants
CHRISTOPHER TOMASZEWSKI and
MIKE MERRI

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A Professional Corporation
San Jose

Ropers Majeski Kohn & Bentley

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ORDER
Pursuant to the parties’ stipulation, the Court makes the following order:
The deadline to file a Joint Rule 26(f)(2) Report, currently due on March 9, 2018, is
continued to April 6, 2018, and Initial Disclosures shall be served 45 days thereafter.
IT IS SO ORDERED.
Dated: March 17, 2018

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4838-9135-7279.1

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STIPULATION REQUESTING EXTENSION TO
FILE F.R.C.P. RULE 26(f)(2) REPORT
CASE NO. 2:18-CV-00039-MCE-AC