Storz Management Company et al v. Carey et al

Filing 134

STIPULATION and ORDER signed by Magistrate Judge Deborah Barnes on 4/20/2020 MODIFYING its 3/12/2020 Order (ECF Document No. 130 ) to allow Plaintiffs until 6/17/2020 to produce Mr. Pierini for his continued deposition as SMC's PMK. (Becknal, R)

1 LEWIS BRISBOIS BISGAARD & SMITH LLP
CHRISTOPHER J. BAKES, SB# 99266
2 ANDREW D. BLUTH, SB# 232387
CAITLIN E. HIGGINS, SB# 298782
3 2020 West El Camino Avenue, Suite 700
Sacramento, California 95833
4 Tel: [phone]
Fax: [phone]
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Attorneys for Plaintiffs/Counterdefendants STORZ MANAGEMENT
6 COMPANY, a California corporation, and STORZ REALTY, INC.
7 weintraub tobin chediak coleman grodin law corporation
CHARLES L. POST, SB#. 160443
8 JAMES KACHMAR, SB#. 216781
400 Capitol Mall, 11th Floor
9 Sacramento, California 95814
Telephone: [phone]
10 Facsimile:
916/446.1611
11 Attorneys for Defendants/Counterclaimants
ANDREW CAREY and MARK WEINER
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

15 STORZ MANAGEMENT COMPANY, a
California Corporation, and STORZ
16 REALTY, INC.,
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Plaintiffs,

No. 2:18-cv-00068 TLN DB
STIPULATION AND ORDER RE:
MODIFICATION OF ORDER DATED
MARCH 12, 2020 (DCKT. NO. 130)

vs.

19 ANDREW CAREY, an individual, and
MARK WEINER, an individual,
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Defendants.
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And related cross-claim.

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Plaintiffs/Counterdefendants Storz Management Company and Storz Realty, Inc.

25 (“Plaintiffs”), together with Defendants/Counterclaimants Andrew Carey and Mark Weiner
26 (“Defendants”) (Plaintiffs and Defendants referred to collectively as the “Parties”) hereby stipulate
27 to and request a modification to the Court’s March 12, 2020 Order as follows:

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BRISBOI
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BISGAAR

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WHEREAS, on or about February 14, 2020, the Court issued an Order (Dckt. # 125)
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4825-0666-2074.1

STIPULATION AND ORDER RE: JOINT REQUEST FOR ADDITIONAL TIME TO SCHEUDLE
CONTINUED DEPOSITION OF JIM PIERINI

1 granting Defendants’ Motion to Compel Continued Deposition of James Pierini as Storz
2 Management Company’s (“SMC”) Person Most Knowledgeable (Dckt. # 116) and ordering
3 Plaintiffs to produce witness James Pierini for a continued deposition as SMC’s PMK by no later
4 than March 13, 2010; and
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WHEREAS, on or about March 12, 2020, the Court issued an Order (Dckt. # 130)

6 modifying its February 14 Order to allow until April 17 for the Parties to complete the deposition
7 of Mr. Pierini, given the scheduling difficulties created by current public health concerns; and
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WHEREAS, due to continued social distancing, travel, and other restrictions necessitated

9 by the current public health environment, the Parties agree that the deposition needs to be
10 continued to a later date; and
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WHEREAS, the Parties jointly request that the Court modify its March 12, 2020 Order

12 (Dckt. # 130) to allow additional time for the continued deposition of Mr. Pierini as SMC’s PMK
13 to take place.
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NOW, THEREFORE, the Parties jointly request:

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1. That the Court modify its March 12, 2020 Order (ECF Document No. 130) to allow

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Plaintiffs until June 17, 2020 to produce Mr. Pierini for his continued deposition as

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SMC’s PMK.

18 IT IS SO STIPULATED AND AGREED.
19 Respectfully submitted,
20 DATED: April 17, 2020

LEWIS BRISBOIS BISGAARD & SMITH

LLP

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By:

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/s/ Christopher J. Bakes
Christopher J. Bakes
Attorneys for Plaintiffs/Counterdefendants
STORZ MANAGEMENT COMPANY, a
California corporation, and STORZ REALTY,
INC.

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BISGAAR

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4825-0666-2074.1

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STIPULATION AND ORDER RE: JOINT REQUEST FOR ADDITIONAL TIME TO SCHEUDLE
CONTINUED DEPOSITION OF JIM PIERINI

1 DATED: April 17, 2020

WEINTRAUB TOBIN CHEDIAK COLEMAN
GRODIN

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By: /s/ James Kachmar (as authorized on 4/17/2020)
James Kachmar
Attorneys for Defendants / Counterclaimants
ANDREW CAREY and MARK WEINER

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ORDER
Pursuant to the parties’ stipulation, IT IS SO ORDERED.

10 DATED: April 20, 2020

/s/ DEBORAH BARNES
UNITED STATES MAGISTRATE JUDGE

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4825-0666-2074.1

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STIPULATION AND ORDER RE: JOINT REQUEST FOR ADDITIONAL TIME TO SCHEUDLE
CONTINUED DEPOSITION OF JIM PIERINI