Lopez Tax Service, Inc. et al v. The Income Tax School, Inc.

Filing 42

ORDER GRANTING 41 STIPULATION to Extend ENE Deadline. Signed by Judge Jeffrey S. White on 12/5/12. (jjoS, COURT STAFF) (Filed on 12/5/2012)

Case3:12-cv-02654-JSW Document41 Filed12/04/12 Page1 of 3

1
2
3
4
5
6
7

GAUNTLETT & ASSOCIATES
David A. Gauntlett (SBN 96399)
James A. Lowe (SBN 214383)
Andrew M. Sussman (SBN 112418)
18400 Von Karman, Suite 300
Irvine, California 92612
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiffs Lopez Tax Service, Inc.,
Carlos C. Lopez, Kristeena S. Lopez, and Latino
Tax Professionals Association, LLC

8
9
10
11
12
13
14
15
16
17

Nicholas Ranallo (SBN 275016)
Attorney at Law
371 Dogwood Way
Boulder Creek, California 95006
Telephone: [phone]
Facsimile: (831-533-5073
[e-mail]
Christopher E. Gatewood [Pro Hac Vice ]
THRESHOLD COUNSEL, PC
1905 Huguenot Road, Suite 200
Richmond, Virginia 23235
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Defendant The Income Tax School

18
UNITED STATES DISTRICT COURT

19

NORTHERN DISTRICT OF CALIFORNIA

20

SAN FRANCISCO DIVISION

21
22

LOPEZ TAX SERVICE, INC., et al.,

23

Plaintiffs,

24
vs.
25
26
27
28

THE INCOME TAX SCHOOL, INC.,
Defendant.

)
)
)
)
)
)
)
)
)
)
)
)

Case No.: CV12-02654-JSW

STIPULATION AND [PROPOSED]
ORDER TO EXTEND EARLY NEUTRAL
EVALUATION DEADLINE
[Civ. L.R. 7-12]

STIPULATION AND [PROPOSED] ORDER

Case3:12-cv-02654-JSW Document41 Filed12/04/12 Page2 of 3

1

Pursuant to Civ. L.R. 7-12, Plaintiffs LOPEZ TAX SERVICE, INC., CARLOS C. LOPEZ,

2

KRISTEENA S. LOPEZ and LATINO TAX PROFESSIONALS ASSOCIATION, LLC,

3

(collectively “Lopez”) and Defendant THE INCOME TAX SCHOOL, INC. (“ITS”) hereby stipulate

4

and agree to request an extended deadline to complete Early Neutral Evaluation in this case. This

5

stipulation is based on the following:

6
7
8

1)

Per local rules, the Court originally ordered the Parties to complete the ENE within

90 days of October 31, 2012, or January 29, 2013.
2)

In their November 27, 2012 initial conference call with William Fenwick, the

9

appointed Evaluator, the Parties and Evaluator agreed that it may be reasonable and necessary to

10

extend the ENE deadlines. The parties believe that the ENE will be more effective after each has

11

had the opportunity to conduct their respective depositions. The Lopez parties are scheduled to

12

depose individuals associated with ITS on December 10-12, 2012. ITS has likewise scheduled

13

depositions of the Lopez parties for January 7-9, 2013.

14
15
16

3)

The Parties, their counsel, and the Evaluator are available and have agreed to hold the

ENE on January 29, 2013.
4)

The parties seek to extend the ENE deadline to March 1, 2013, to allow the parties

17

sufficient time to conduct a meaningful evaluation on January 29th and to allow for a potential

18

follow-up session, if necessary.

19
20
21
22
23
24
25
26
27

Dated: December 4, 2012

GAUNTLETT & ASSOCIATES
By: /s/ Andrew M. Sussman
David A. Gauntlett
James A. Lowe
Andrew M. Sussman
Attorneys for Plaintiffs
Lopez Tax Service, Inc., Carlos C. Lopez,
Kristeena S. Lopez, and Latino Tax Professionals
Association, LLC

28
STIPULATION AND [PROPOSED] ORDER

Case3:12-cv-02654-JSW Document41 Filed12/04/12 Page3 of 3

1

Dated: December 4, 2012

Nicholas Ranallo, Attorney at Law
By: /s/ Nicholas Ranallo
Nicholas Ranallo
371 Dogwood Way
Boulder Creek, CA 95006

2
3
4

Christopher E. Gatewood [Pro Hac Vice]
THRESHOLD COUNSEL, PC
1905 Huguenot Road, Suite 200
Richmond, VA 23235
Telephone: [phone]
Facsimile: [phone]
[e-mail]

5
6
7
8

Attorneys for Defendant
The Income Tax School, Inc.

9
10
11
12

PURSUANT TO STIPULATION, IT IS SO ORDERED.

13
14
15

December 5, 2012
Dated: ____________________________

_________________________________________
UNITED STATES DISTRICT JUDGE

16
17
18
19
20
21
22
23
24
25
26
27
28
STIPULATION AND [PROPOSED] ORDER