Schaeffer et al v. Piccolo Properties, L.P. et al

Filing 142

STIPULATION AND ORDER re 140 STIPULATION WITH PROPOSED ORDER Extending Briefing Schedule on Plaintiff's Additional Motions for Summary Judgment against MB Enterprises, Inc. and Gregory Village Partners, L.P. filed by M.B. Enterprises, Inc. Motion Hearing set for 5/7/2015 at 2:00 PM in Courtroom 9, 19th Floor, San Francisco before Hon. Jon S. Tigar. Signed by Judge Jon S. Tigar on January 29, 2015. (wsn, COURT STAFF) (Filed on 1/29/2015)

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HORACE W GREEN, BAR NO. 115699

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BUCHMAN PROVINE BROTHERS SMITH LLP
2033 N. Main Street, Suite 720
Walnut Creek, California 94596
Telephone:
925 944 9700
Facsimile:
9259449701

[e-mail]

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Attorneys for Defendants
MB Enterprises, Inc., Massoud Ebrahimi, and
Bhagdeep S. Dhaliwal

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

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RYAN SCHAEEFER, an individual;
ANNE SCHAEFFER, an individual; and
REESE SCHAEFFER, a minor by and
through her general guardians Ryan
Schaeffer and Anne Schaeffer"

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Plaintiffs,

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STIPULATION AND [PROPOSED] ORDER
EXTENDING BRIEFING SCHEDULE ON
PLAINTIFFS' ADDITIONAL MOTIONS FOR
SUMMARY JUDGMENT AGAINST MB
ENTERPRISES, INC. AND GREGORY
VILLAGE PARTNERS, L.P.

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Case No. 3:13-CV-4358 JST

GREGORY VILLAGE PARTNERS, L.P.,
a California Partnership, et al."

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Defendants.

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1.

By Order dated December 8, 20 14 (docket # 131), the Court established a briefing

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schedule with respect to Plaintiffs' request to file additional motions for summary judgment
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against Defendants MB Enterprises', Inc. and Gregory Village Partners, L.P. Under that schedule,
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Plaintiffs were provided the ability to file their additional summary judgment motions with
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respect to liability on selected causes of action against these Defendants no later than January 30,
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2015. Defendants' opposition papers were to be filed by March 4,2015. Plaintiffs' reply papers
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were to be filed by March 18,2015. The motions were set for hearing on April 9, 2015.
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2.
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After the Court issued that Order, counsel for Defendant MB Enterprises, Inc.

received an Order from Judge Wi1li~nn B. Shubb in the Eastern District of California. By that

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STIPULATION AND [PROPOSED] ORDER EXTENDING BRIEFING SCHEDULE
Case No. 3: 13-CV-4358 JST

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Order, Judge Shubb re-calendared the commencement of a jury trial from January 13, 2015 to

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February 3,2015. MB Enterprises' counsel represents the Defendants in that jury trial, which is

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estimated to last three weeks. This trial will prevent counsel from preparing and filing opposition

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papers by March 4,2015.

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WHEREFORE, Plaintiffs, Gregory Village, and MBE stipulate to and respectfully request

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that this Court amend the existing filing deadlines for Plaintiffs' additional summary judgment

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motions against Gregory Village and MBE, related filing deadlines, and the date for hearing on

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both summary judgment motions as follows:

February 27,2015

Last day for Plaintiffs to file summary judgment motions

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April 1, 2015

Last day for Gregory Village/MBE to file oppositions

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April 15, 2015

Last day for Plaintiffs to file reply papers

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May 7, 2015

Hearing on both summary judgment motions.

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STIPULATION AND [PROPOSED] ORDER EXTENDING BRIEFING SCHEDULE
Case No. 3: 13-CV-4358 JST

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Dated: January 27,2015

BUCHMAN PROVINE BROTHERS SMITH LLP

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By:/s/Horace W. Green
Horace W Green
Attorneys for Defendants
MB Enterprises, Inc., Massoud Ebrahimi, and
Bhagdeep S. Dhaliwal

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Dated: January 27,2015

PALADIN LAW GROUP@ LLP

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By:/s/John R. Till
John R. Till
Attorneys for Plaintiffs

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Dated: January 27,2015

STANZLERLAWGROUP

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By:/s/Jeffery Curtiss
Jeffery Curtiss
Attorneys for Defendant
Gregory Village Properties, LP, VPI, Inc.

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PROPOSED ORDER

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incorporate the dates proposed above.

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STIPULATION AND [PROPOSED] ORDER EXTENDING BRIEFING SCHEDULE
Case No. 3: 13-CV-4358 JST

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By: __~__~~~~~_______
Jon S. Tigar
Honorable ORDERED
UnitedIStates SO
T IS District Court Judge

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Dated: January 29, 2015

UNIT
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existing filing deadlines and hearing date set forth in Docket Number 131 in this matter to

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PURSUANT TO STIPULATION, IT IS SO ORDERED that this Court amends the

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