Lovett v. Omni Hotels & Resorts et al

Filing 118

STIPULATION AND ORDER to reset the hearing date and plaintiff's time to respond to defendant Omni's motion for summary judgment. Motion Hearing previously set for 12/17/2015 Continued to 1/21/2016 at 01:30 PM in Courtroom 3, 17th Floor, San Francisco before Hon. Richard Seeborg. Signed by Judge Richard Seeborg on 11/18/15. (cl, COURT STAFF) (Filed on 11/18/2015)

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LAW OFFICES OF

WALKUP, MELODIA, KELLY & SCHOENBERGER
A PROFESSIONAL CORPORATION

650 CALIFORNIA STREET, 26TH FLOOR
SAN FRANCISCO, CALIFORNIA 94108-2615
[phone]

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MICHAEL A. KELLY (State Bar #71460)
[e-mail]
DORIS CHENG (State Bar #197731)
[e-mail]
JUSTIN CHOU (State Bar #279137)
[e-mail]
ATTORNEYS FOR PLAINTIFF

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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JENNIFER K. LOVETT,

Case No. C 14-02844 RS

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Plaintiff,

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v.

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OMNI HOTELS MANAGEMENT
CORPORATION, and DOES ONE through
ONE HUNDRED,

STIPULATION AND PROPOSED ORDER
TO RESET THE HEARING DATE AND
PLAINTIFF’S TIME TO RESPOND TO
DEFENDANT OMNI’S MOTION FOR
SUMMARY JUDGMENT

Defendants.

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Pursuant to Civil Local Rule 6-2, plaintiff Jennifer K. Lovett ("Plaintiff") and defendant
Omni Hotels Management Corporation ("Defendant") stipulate as follows:

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WHEREAS, Defendant Omni filed its Motion for Summary Judgment on July 2, 2015

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with a requested hearing date of September 10 [Dkt. no. 59]. On July 10, the Court granted

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Plaintiff's Motion to Continue and set the hearing date to October 15 [Dkt. no. 68]. The Court

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continued, sua sponte, the hearing date, on July 17 to October 22 [Dkt. no. 71] and on September

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2 to November 5 [Dkt. no. 86]. On October 5, the court granted the parties' Stipulated Motion to

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Specially Set or, in the Alternative, to Continue the Hearing Date and rescheduled the hearing to

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December 17 [Dkt. no. 102];

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STIPULATION AND PROPOSED ORDER TO RESET THE HEARING DATE AND PLAINTIFF’S TIME TO RESPOND TO
DEFENDANT OMNI’S MOTION FOR SUMMARY JUDGMENT - CASE NO. C 14-02844 RS

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WHEREAS, on October 8, 2015, the Court granted Plaintiff's Motion for Leave to Amend

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the First Amended Complaint; denied, without prejudice, Defendant's Motion for Summary

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Judgment; and permitted Defendant to refile its Motion for Summary Judgment addressing

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Plaintiff's new claims in time for a hearing on December 17 [Dkt. no. 103];

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WHEREAS, Defendant filed its Motion for Summary Judgment on November 12 with a
hearing date of December 17 [Dkt. no.108];
WHEREAS, Plaintiff’s opposition to Defendant’s Motion for Summary Judgment is due

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on November 27, 2015;

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WHEREAS, Plaintiff’s counsel is commencing trial in another matter, Yuan v. City and

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County of San Francisco, San Francisco Superior Court Case No. CGC-13-536533 before

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Honorable Angela Bradstreet, and pre-trial motions shall be argued on November 19, 2015 and

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jury selection to commence on November 23 or 24, 2015;

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WHEREAS, Plaintiff’s counsel anticipates being in trial until shortly before Christmas;

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WHEREAS, the parties have now met and conferred on mutually convenient dates for the

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hearing and Plaintiff’s last date to oppose Defendant Omni’s Motion for Summary Judgment;

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IT IS THEREFORE STIPULATED as follows:

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Defendant Omni’s Motion for Summary Judgment shall be heard on January 21,

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Plaintiff shall file her Opposition to the Motion for Summary Judgment no later

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2016;

than January 7, 2016.

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LAW OFFICES OF

WALKUP, MELODIA, KELLY
& SCHOENBERGER
A PROFESSIONAL CORPORATION

650 CALIFORNIA STREET
26TH FLOOR
SAN FRANCISCO, CA 94108
[phone]

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STIPULATION AND PROPOSED ORDER TO RESET THE HEARING DATE AND PLAINTIFF’S TIME TO RESPOND TO
DEFENDANT OMNI’S MOTION FOR SUMMARY JUDGMENT - CASE NO. C 14-02844 RS

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DATED: November 17, 2015

WALKUP, MELODIA, KELLY, & SCHOENBERGER

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By:

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/s/ Doris Cheng
Doris Cheng
Attorney for Plaintiff JENNIFER LOVETT

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DATED: November 17, 2015

LEWIS BRISBOIS BISGAARD & SMITH

LLP

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By:

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/s/ Thomas A. Rector
Thomas A. Rector
Attorneys for Defendant OMNI HOTELS
MANAGEMENT CORPORATION

IT IS SO ORDERED.

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11/18/15
DATED: ___________
RICHARD SEEBORG
United States District Judge

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LAW OFFICES OF

WALKUP, MELODIA, KELLY
& SCHOENBERGER
A PROFESSIONAL CORPORATION

650 CALIFORNIA STREET
26TH FLOOR
SAN FRANCISCO, CA 94108
[phone]

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STIPULATION AND PROPOSED ORDER TO RESET THE HEARING DATE AND PLAINTIFF’S TIME TO RESPOND TO
DEFENDANT OMNI’S MOTION FOR SUMMARY JUDGMENT - CASE NO. C 14-02844 RS