Shahan v. Golden State Bridge Inc

Filing 55

ORDER AS MODIFIED GRANTING STIPULATION TO CONTINUE DEFENDANT'S MSJ 53 . Opposition due by 1/28/2015. Reply due by 2/6/2015. Motion Hearing set for 2/25/2015 02:00 PM in Courtroom 7, 4th Floor. Signed by Judge Nathanael Cousins on 1/12/2015. (lmh, COURT STAFF) (Filed on 1/12/2015)

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John R. Hillsman (CA SBN 71220)
[e-mail]
Abraham Feinstein-Hillsman (CA SBN 241810)
[e-mail]
McGUINN, HILLSMAN & PALEFSKY
535 Pacific Avenue
San Francisco, CA 94133
tel:
[phone] fax: [phone]

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Attorneys for Plaintiff ALLEN SHAHAN

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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ALLEN SHAHAN,

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Plaintiff,

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vs.
GOLDEN STATE BRIDGE, INC.,
Defendant.
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No. CV 13 3594 NC

JOINT STIPULATED REQUEST
FOR THE CONTINUANCE OF
DEFENDANT’S MOTION FOR
SUMMARY JUDGMENT AND
[PROPOSED] ORDER THEREON
AS MODIFIED

WHEREAS:

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1.

This Claim is currently set for trial on March 9, 2015.

2.

Defendant GOLDEN STATE BRIDGE, INC.’S Motion for Summary Judgment

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herein is scheduled to be heard on February 4, 2015, and the deadline for Plaintiff to file his

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opposition thereto is Wednesday, January 14, 2015.

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2.

Plaintiff's Counsel, John R. Hillsman and Abraham Feinstein Hillsman, currently

have a conflicting Jury trial that began on December 1, 2014, and is continuing. ("Conflicting

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Matter"). The Conflicting Matter is entitled Michael Prickett and Marya Takamori- Prickett v.
Bonnier Corporation; Warren Miller Entertainment, Inc.; Bare Sports Canada, LTD; Bare Sports
USA, Corp. and Does 1 through 30 inclusive, (County of Alameda Case No RG12655617)
3. Plaintiffs’ counsel have reason to believe that the conclusion of the trial of the
Conflicting Matter will not occur prior to the above-mentioned January 14, 2015 filing deadline.
____________________________________________________________________________
Joint Stipulated Request for the Continuance Defendant’s MSJ

McGUINN, HILLSMAN
& PALEFSKY
535 Pacific Avenue
San Francisco, CA 94133
[phone]

- CV 13 3594 NC

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THEREFORE, THE PARTIES HEREBY JOINTLY STIPULATE AND REQUEST THAT:
1.

Defendants Motion for Partial Summary Judgment herein be taken off calendar for

1:00 p.m. on February 4, 2015.
2.

Defendant's Motion for Partial Summary Judgment be reset for hearing on

Wednesday, February 18, 2015, at 1:00 p.m. in Courtroom 7 of this Court, located at 280 South
1st Street, San Jose, California 95113.
3.

The date for Plaintiff to submit his opposing papers to Defendant's Motion for

Summary Judgment shall be continued from January 14, 2015, to the new date of January 28, 2015.
4.

The date for Defendant to submit its reply papers to Plaintiff’s opposition shall be

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continued from January 23, 2015 to the new date of Friday, February 6, 2015.

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Dated: January 8, 2015

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McGUINN, HILLSMAN & PALEFSKY
Attorneys for Plaintiff ALLEN SHAHAN

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By: /s/

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JOHN R. HILLSMAN
JOHN R. HILLSMAN

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Dated: January 9, 2015

COX, WOOTTON, LERNER, GRIFFIN,
HANSON & POULOS
Attorneys for Defendant
GOLDEN STATE BRIDGE, INC.

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By: /s/

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RICHARD R. WOOTTON
RICHARD R. WOOTTON

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ATTESTATION OF COUNSEL AS TO SIGNATURE
Pursuant to Civil Local Rule 5-1(i)(3 regarding signatures, John R. Hillsman
hereby attests that concurrence in the filing of this document has been obtained.

____________________________________________________________________________
Joint Stipulated Request for the Continuance Defendant’s MSJ
McGUINN, HILLSMAN
& PALEFSKY
535 Pacific Avenue
San Francisco, CA 94133
[phone]

- CV 13 3594 NC

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[PROPOSED]
ORDER

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The parties’ Joint Stipulation and Proposed Order is hereby adopted by the Court, and
the Court hereby orders that:
1.

Defendant’s Motion for Partial Summary Judgment is continued from February 4,
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2:00
2015, to the new date of Wednesday, February 18, 2015, at 1:00 p.m. in Courtroom 7 of this Court,

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located at 280 South lst Street, San Jose, California;
2.

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Plaintiff’s deadline to submit opposing papers to Defendant’s Motion for Summary

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Judgment is continued from January 14, 2015 to the new date of Wednesday, January 28, 2015;

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and,

Motion for Summary Judgment is continued from January 23 to the new date of Friday, February
6, 2015.

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January 12, 2015
Dated: __________________

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AS

.
thanael M
Judge Na

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Cousins

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______________________________________
ERED
NATHANAELSO ORD
COUSINS,
IT IS
IED
Magistrate Judge, United States District Court
MODIF

NO

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UNIT
ED

IT IS SO ORDERED.

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R NIA

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Defendant’s deadline to submit reply papers to Plaintiff’s opposition to Defendant’s

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3.

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McGUINN, HILLSMAN
& PALEFSKY
535 Pacific Avenue
San Francisco, CA 94133
[phone]

____________________________________________________________________________
Joint Stipulated Request for the Continuance Defendant’s MSJ

- CV 13 3594 NC

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