Paulick v. Starwood Hotels & Resorts Worldwide, Inc. et al

Filing 61

STIPULATION AND ORDER for Enlargement of Time to Conduct Case Management Conference. Further Case Management Conference set for 11/4/2011 01:30 PM in Courtroom G, 15th Floor, San Francisco. Signed by Judge Joseph C. Spero on 09/08/2011. (tmi, COURT STAFF) (Filed on 9/8/2011)

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SIDNEY J. COHEN, ESQ., State Bar No. 39023
SIDNEY J. COHEN PROFESSIONAL CORPORATION
2 427 Grand Avenue
Oakland, CA 94610
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Attorneys for Plaintiff
MICHAEL PAULICK
UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA
MICHAEL PAULICK
V.

Plaintiff,

STARWOOD HOTELS &
RESORTS WORLDWIDE, INC.;
INTRAWEST NAPA
DEVELOPMENT COMPANY,
LLC;INTRAWEST NAPA
RIVERBEND HOSPITALITY
MANAGEMENT, LLC;
VY VERASA COMMERCIAL
COMPANY, LLC and DOES 1-25,
Inclusive,
Defendants.
/

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CASE NO. C 10-01919 JCS
Civil Rights

Stipulation, Declaration and [Proposed ]Order
For Enlargement Of Time To Conduct Case
Management Conference

STIPULATION, DECLARATION,
AND [PROPOSED] ORDER FOR
ENLARGEMENT OF TIME TO
CONDUCT CASE MANAGEMENT
CONFERENCE
(Local Rule 6-2)

STIPULATION

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Plaintiff , by and through his attorney, and Defendants, by and through

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their attorneys, stipulate to an extension of time from October 21, 2011 to

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November 4, 2011 for the parties’ second Case Management Conference.

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The parties further stipulate that this Stipulation may be signed in

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counterparts and that facsimile or electronically transmitted signatures shall be as

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valid and binding as original signatures.

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It is so stipulated.
Date: 9/6/11

SIDNEY J. COHEN
PROFESSIONAL CORPORATION

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/s/ Sidney J. Cohen

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Sidney J. Cohen
Attorney for Plaintiff Richard Skaff

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Date:

GREENBERG TRAURIG
/s/ Gregory F. Hurley

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Gregory F. Hurley or Michael J. Chilleen
Attorneys for Defendants Intrawest Napa
Development Company, LLC and
Intrawest Napa Riverbend Hospitality
Management, LLC

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Date:

COLLETTE, ERICKSON, FARMER &
O’NEILL, LLP

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/s/ Rod Divelbiss
___________________________
Rod Divelbiss
Attorney for Defendant VY Verasa
Commercial Company, LLC

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DECLARATION OF SIDNEY J. COHEN

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I, Sidney J. Cohen, declare:
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I am counsel for Plaintiff in this action. I am an attorney in good

standing and licensed to practice in the courts of California, in the United States
Stipulation, Declaration and [Proposed ]Order
For Enlargement Of Time To Conduct Case
Management Conference

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District Courts for the Northern, Eastern, and Central Districts, in the United

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States Court of Appeals for the Ninth Circuit, and in the United States Supreme

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Court. If called upon to testify, I would testify as follows:

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2.

Pursuant to court Order, the parties in this case are scheduled for a

second Case Management Conference on October 21, 2011

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3.

I will be out of the San Francisco Area on October 21, 2011 and will

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be unable to appear at the presently scheduled Case Management Conference in

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person or by telephone. In addition, because of the August 11, 2011 substitution

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into the case of Greenberg Traurig in place of Lieberbach, Mohun, Carney &

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Reed for defendants Intrawest Napa Development Company, LLC and Intrawest

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Napa Riverbend Hospitality Management, LLC (Docket item 55), the honorable

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Elizabeth Laporte rescheduled the August 19, 2011 Settlement Conference in the

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case to November 2, 2011 (Docket item 58), which is a date subsequent to the

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presently scheduled October 21, 2011 Case Management Conference. In this

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regard, holding the Case Management Conference on November 4, which is after

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the November 2 Settlement Conference, likely will be more informative and

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productive for the parties and the court.

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4.

An extension of the Case Management Conference date from

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October 21, 2011 to November 4, 2011will not effect any other deadlines in the

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case.

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I declare under penalty of perjury that the foregoing is true and correct.

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Executed this 6th day of September, 2011 at Oakland, California.

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/s/ Sidney J. Cohen

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Sidney J. Cohen

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//

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//

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Stipulation, Declaration and [Proposed ]Order
For Enlargement Of Time To Conduct Case
Management Conference

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ORDER

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Having considered the parties’ Stipulation and the supporting
Declaration, and for good cause shown, the court reschedules the Case

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Management Conference in the case from October 21, 2011 to November

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4, 2011, with an updated Case Management Statement due no later than

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10/28/2011
__________________.
UNIT
ED
NO

RT

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sep

Judge Jo

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Stipulation, Declaration and [Proposed ]Order
For Enlargement Of Time To Conduct Case
Management Conference

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A

H

ER

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FO

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R NIA

_____________________________
Joseph C. Spero
United States Magistrate Judge
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Date: 9/8/2011

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IT IS SO ORDERED.

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