Jones v. Marriot Hotel Services, Inc.

Filing 77

STIPULATION EXTENDING DISCOVERY by Hon. William Alsup granting 76 Stipulation.(whalc1, COURT STAFF) (Filed on 4/10/2013)

M ILLER L AW G ROUP

A P ROF E SSIONAL C ORPORATION
C ALIF ORNIA

1 Michele Ballard Miller (SBN 104198)
[e-mail]
2 Janine S. Simerly (SBN 102361)
[e-mail]
3 Noah Levin (SBN 263069)
[e-mail]
4 MILLER LAW GROUP
A Professional Corporation
5 111 Sutter Street, Suite 700
San Francisco, CA 94104
6 Tel. [phone]
Fax [phone]
7
Attorneys for Defendant MARRIOTT HOTEL
8 SERVICES, INC. and MARRIOTT INTERNATIONAL, INC.
9 Stephen Robert Onstot (SBN 139319)
[e-mail]
10 1601 Barton Road, #3902
Redlands, CA 92373
11 Tel: [phone]
Fax: [phone]
12
Thomas G. Jarrard, Pro Hac Vice
13
[e-mail]
WA State Bar No. 39774
14 1020 North Washington Street
Spokane, WA 99201
15 Tel: [phone]
Fax: [phone]
16
Matthew Z. Crotty, Pro Hac Vice
17
[e-mail]
WA State Bar No. 8653, ISB No. 8653
18 422 West Riverside, Suite 1100
Spokane, WA 99201-0030
19 Tel: [phone]
Fax: [phone]
20
Attorneys for Plaintiff
21 CHRISTOPHER JONES
22

UNITED STATES DISTRICT COURT

23

NORTHERN DISTRICT OF CALIFORNIA

24 CHRISTOPHER JONES,

Case No.: CV 12-0587 WHA

25

STIPULATION AND [PROPOSED] ORDER
TO EXTEND DISCOVERY UNTIL MAY 30,
2013

Plaintiff,

26 v.
27 MARRIOTT HOTEL SERVICES, INC., AND
MARRIOTT INTERNATIONAL, INC.,
28
Defendants.

STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY UNTIL MAY 30, 2013
Case No.: CV 12-0587 WHA

1

Plaintiff CHRISTOPHER JONES (“Plaintiff”) and Defendants MARRIOTT

2 HOTEL SERVICES, INC. and MARRIOTT INTERNATIONAL, INC. (“Defendants”), by and
3 through their undersigned attorneys, hereby stipulate and agree as follows:
4
5

WHEREAS, the deadline to complete discovery, including expert discovery, in

6 this matter is current set for April 30, 2013;
7
8

WHEREAS, the parties are engaged in settlement discussions in this matter

9 and have agreed to attend private mediation in mid-April 2013;
10
11

WHEREAS, the parties believe that a 30-day continuance of discovery in this

M ILLER L AW G ROUP

A P ROF E SSIONAL C ORPORATION
C ALIF ORNIA

12 matter would facilitate settlement discussions;
13
14

WHEREAS, trial in this matter is set for September 23, 2013, and a 30-day

15 discovery extension would not affect other case deadlines;
16
17

NOW, THEREFORE,

18
19

IT IS HEREBY STIPULATED AND AGREED by and between Plaintiff and

20 Defendants, by and through their respective undersigned attorneys of record, to extend all
21 discovery deadlines, including expert disclosure and discovery, to May 30, 2013. Good
22 cause exists for extending the existing discovery deadlines, as set forth above.
23 / / / /
24 / / / /
25 / / / /
26 / / / /
27 / / / /
28 / / / /
1
STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY UNTIL MAY 30, 2013
Case No.: CV 12-0587 WHA

1

IT IS SO STIPULATED.

2
3 Dated: March 20, 2013
4

MILLER LAW GROUP
A Professional Corporation

5
By:

/s/
Michele Ballard Miller
Attorneys for Defendants
MARRIOTT HOTEL SERVICES, INC. and
MARRIOTT INTERNATIONAL, INC.

By:

6

/s/
Matthew Z. Crotty
Attorneys for Plaintiff
CHRISTOPHER JONES

7
8
9
10

Dated: March 20, 2013

11

M ILLER L AW G ROUP

A P ROF E SSIONAL C ORPORATION
C ALIF ORNIA

12
13
14
ORDER

15
16
17

After full consideration of the stipulation of counsel and good cause appearing,

18 the Court HEREBY ORDERS that all discovery deadlines, including expert discovery, are
19 extended until May 30, 2013.
20
21

IT IS SO ORDERED.

22
23 Dated: April 8, 2013.
Honorable William H. Alsup

24
25
26
27
4845-6238-1587, v. 3

28
2
STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY UNTIL MAY 30, 2013
Case No.: CV 12-0587 WHA