Bishay v. Icon Aircraft, Inc.

Filing 36

STIPULATION and ORDER signed by Chief District Judge Kimberly J. Mueller on 10/9/2020 EXTENDING Plaintiff's deadline to file an amended complaint to 10/15/2020. (Huang, H)

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1 2 3 4 5 SUZANNE K. BABB (Bar No. 229750) BEYERS COSTIN SIMON 200 Fourth Street, Ste. 400 Post Office Box 878 Santa Rosa, California 95402-0878 Tele: (707) 547-2000 Fax: (707) 526-2746 6 Attorneys for Plaintiff Samer Bishay 7 Hannah L. Cannom (Bar No. 245635) WALKER STEVENS CANNOM LLP 500 Molino Street, Suite 118 Los Angeles, California 90013 Tele: (213) 337-9972 Fax: (213) 403-4906 8 9 10 11 Attorneys for Defendant, ICON Aircraft, Inc. 12 13 14 UNITED STATES DISTRICT COURT 15 FOR THE EASTERN DISTRICT OF CALIFORNIA 16 SACRAMENTO DIVISION 17 18 19 20 21 22 SAMER BISHAY, Civil Action No. 2:19-cv-00178-KJM-AC Plaintiff, v. STIPULATION TO EXTEND TIME FOR PLAINTIFF TO FILE AMENDED COMPLAINT; ORDER ICON AIRCRAFT, INC., a Delaware corporation, JURY TRIAL DEMANDED Defendant. 23 24 25 26 27 28 STIPULATION TO EXTEND TIME FOR PLAINTIFF TO FILE AMENDED COMPLAINT 1 2 3 4 5 6 7 8 Plaintiff Samer Bishay (“Plaintiff”) and Defendant, ICON Aircraft, Inc. (“ICON”), by and through their attorneys of record in this case, stipulate and agree as follows: WHEREAS, on February 12, 2020, ICON filed a motion to dismiss Plaintiff’s Second Amended Complaint; WHEREAS, on September 14, 2020, the Court entered an order granting ICON’s motion, with leave for Plaintiff to amend his complaint within 21 days of the Order. WHEREAS, Plaintiff’s counsel resides in Sonoma County, California, which has been the site of devastating firestorms. The attendant evacuations, destroyed infrastructure, and lack of access to 9 files and reliable telephone and internet connections has prevented Plaintiff’s counsel from being able 10 to address the Court’s Order with her client within the Court’s timeframe; 11 12 13 14 15 16 WHEREAS, Plaintiff’s counsel requested and Defendant’s counsel has agreed to a ten day extension of time for Plaintiff to file his amended complaint, should he elect to do so; IT IS HEREBY STIPULATED by and between the parties hereto through their respective attorneys that the last day for Plaintiff to file an amended complaint is extended to October 15, 2020. IT IS SO STIPULATED. 17 Respectfully submitted, 18 19 BEYERS COSTIN SIMON 20 Dated: October 5, 2020 21 22 /s/ Suzanne K. Babb By: _______________________ SUZANNE K. BABB Attorneys for Plaintiff 23 24 25 26 27 28 WALKER STEVENS CANNOM LLP Dated: October 5, 2020 /s/ Hannah L. Cannom By: ____________________________ HANNAH L. CANNOM Attorneys for Defendant 1 2 ORDER The Court, having duly considered the parties’ stipulation set forth above, and good cause 3 appearing, orders as follows: 4 5 Plaintiff’s deadline to file an amended complaint is extended to October 15, 2020. 6 IT IS SO ORDERED. 7 Dated: October 9, 2020. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2

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