Adams v. Zelda's Restaurant et al

Filing 55

STIPULATION AND ORDER TO CONTINUE DISCOVERY AND MOTION DEADLINES.. Signed, as modified, by Judge Joseph C. Spero on 7/19/11. (klhS, COURT STAFF) (Filed on 7/20/2011)

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PAUL L. REIN, Esq. (SBN 43053)
CELIA McGUINNESS, Esq. (SBN 159420)
LAW OFFICES OF PAUL L. REIN
200 Lakeside Drive, Suite A
Oakland, CA 94612
Telephone: [phone]
Facsimile: 510/832-4787
Attorneys for Plaintiff CHRISTINA ADAMS
Jeffrey H. Baraban (State Bar # 79747)
James S. Link (State Bar #94280)
[e-mail]
Baraban & Teske
215 N. Marengo Avenue, 3rd Floor
Pasadena, CA 91101
[phone]
[phone] (fax)
MICHAEL D. BRUNO (SBN: 166805)
[e-mail]
GORDON & REES LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants John Ealy, As Trustee, Richard J. Bregante, As Trustee and Capitola
RJL, INC. dba Zelda’s Restaurant

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IN THE UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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CHRISTINA ADAMS,
Plaintiff,

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vs.

Case No.: CV 09-01275 JCS
STIPULATION TO CONTINUE
DISCOVERY AND MOTION DEADLINES;
AND ORDER (PROPOSED)

ZELDA’S RESTAURANT; CAPITOLA RJL,
INC. dba ZELDA’S RESTAURANT; JOHN
EALY; RICHARD J. BREGANTE; and DOES
1-10, inclusive,
Defendants.
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CV 09-01275 JCS--STIPULATION TO CONTINUE DISCOVERY AND MOTION DEADLINES

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WHEREAS, the parties are actively engaged in settlement negotiations under Magistrate
Judge Laurel D. Beeler;
WHEREAS, Magistrate Beeler has requested that the parties refrain from conducting
discovery and motion practice at this time;

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WHEREAS, defendant John Ealy is recovering from heart surgery;

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IT IS HEREBY STIPULATED by and among Plaintiff CHRISTINA ADAMS and

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Defendants CAPITOLA RJL, INC. dba ZELDA’S RESTAURANT; JOHN T. EALY; and

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RICHARD J. BREGANTE, through their designated counsel, the Date for the Designation of

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Experts be continued from July 22 to August 26, that the Discovery Cutoff, including expert

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discovery, be continued from July 22, 2011 to September 21, 2011, that the last day to file and

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serve dispositive motions be continued from August 19, 2011, to October 13, 2011, and the Last

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Day to Hear Motions be continued from September 23, 2011 at 9:30 a.m. to November 18, 2011 at

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9:30 a.m.

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Dated: July 15, 2011

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By: ___/s/Celia McGuinness______________
Attorneys for Plaintiff CHRISTINA ADAMS

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PAUL L. REIN, ESQ.
CELIA McGUINNESS, ESQ.
LAW OFFICES OF PAUL L. REIN

Dated: July 15, 2011

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JEFFREY H. BARABAN, ESQ.
JAMES M. LINK, ESQ.
BARABAN & TESKE

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By:____________________________
Attorneys for Defendants ZELDA’S
RESTAURANT; CAPITOLA RJL, INC. dba
ZELDA’S RESTAURANT; JOHN EALY;
and RICHARD J. BREGANTE

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Dated: July 15, 2011

MICHAEL D. BRUNO
GORDON & REES LLP
By:____/s/Michael D. Bruno___________
Attorneys for Defendants ZELDA’S
RESTAURANT; CAPITOLA RJL, INC. dba
ZELDA’S RESTAURANT; JOHN EALY;
and RICHARD J. BREGANTE

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CV 09-01275 JCS--STIPULATION TO CONTINUE DISCOVERY AND MOTION DEADLINES

[PROPOSED ORDER]

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Pursuant to the stipulation of the parties and for GOOD CAUSE SHOWN, it is hereby

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ordered that the Date for the Designation of Experts be continued from July 22 to August 26, that

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the Discovery Cutoff, including expert discovery be continued from July 22, 2011 to September

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21, 2011, that the last day to file and serve dispositive motions be continued from August 19, 2011,

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to October 13, 2011, and that the Last Day to Hear Motions be continued from September 23, 2011

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at 9:30 a.m. to November 18, 2011 at 9:30 a.m.

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Dated: July__, 2011

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HON. JOSEPH SPERO
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CV 09-01275 JCS--STIPULATION TO CONTINUE DISCOVERY AND MOTION DEADLINES