Pick-n-Pull Auto Dismantlers v. Alco Iron & Metal Co. et al
Filing
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Order by Hon. Vince Chhabria granting 30 Stipulation to Enlarge Time for Discovery Conference and Initial Disclosures, Initial Case Management Conference, and Briefing Schedule for Motions to Dismiss.(knm, COURT STAFF) (Filed on 10/20/2014)
COBLENTZ PATCH DUFFY & BASS LLP
One Ferry Building, Suite 200, San Francisco, California 94111-4213
415.391.4800 • Fax 415.989.1663
1 JONATHAN R. BASS (State Bar No. 75779)
CHARMAINE G. YU (State Bar No. 220579)
2 ALICE WANG (State Bar No. 289631)
COBLENTZ PATCH DUFFY & BASS LLP
3 One Ferry Building, Suite 200
San Francisco, California 94111-4213
4 Telephone: 415.391.4800
Facsimile: 415.989.1663
5 Email: ef-jrb@cpdb.com,
ef-cgy@cpdb.com
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Attorneys for ALCO IRON & METAL CO.
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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PICK-N-PULL AUTO DISMANTLERS, a
12 California general partnership,
,
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Plaintiff,
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v.
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ALCO IRON & METAL CO., a California
16 corporation; CESAR ZAMORA, an
individual; RICARDO ZAMORA, an
17 individual; EMILIO ZAMORA, an individual;
and DOES 1-25,
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Defendants.
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Case No. 3:14-CV-03275 VC
STIPULATION AND [PROPOSED]
ORDER ENLARGING TIME FOR
DISCOVERY CONFERENCE AND
INITIAL DISCLOSURES, INITIAL CASE
MANAGEMENT CONFERENCE
PURSUANT TO LOCAL RULE 6-2, AND
BRIEFING SCHEDULE FOR MOTIONS
TO DISMISS THE COMPLAINT
Judge: Hon. Vince Chhabria
Trial Date:
None Set
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STIPULATION AND [PROPOSED] ORDER ENLARGING TIME
3:14-CV-03275 VC
WHEREAS Plaintiff Pick-N-Pull Auto Dismantlers ("Plaintiff") and Defendants Alco Iron
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2 & Metal Co., Cesar Zamora, Ricardo Zamora, and Emilio Zamora (together, "Defendants," and
3 collectively with Plaintiff, the "Parties") have stipulated to three prior extensions of time, whereby
4 each of the following deadlines was extended: (1) Defendants' time to answer or otherwise
COBLENTZ PATCH DUFFY & BASS LLP
One Ferry Building, Suite 200, San Francisco, California 94111-4213
415.391.4800 • Fax 415.989.1663
5 respond to the Complaint [Dkt. 14]; (2) the deadlines for the Federal Rule of Civil Procedure 26
6 discovery conference and initial disclosures, and the initial case management conference (the
7 "Rule 26 Deadlines") [Dkt. 27]; and (3) the briefing schedule for Defendants' pending Motions to
8 Dismiss Pursuant to Federal Rule of Civil Procedure 12(b)(6) ("Motions to Dismiss") [Dkt. 29];
WHEREAS the Parties participated in a mediation on October 7, 2014;
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WHEREAS the Parties have reached a negotiated resolution of this dispute;
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WHEREAS the Parties are in the process of documenting that resolution;
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WHEREAS the Parties contemplate that this case will be dismissed shortly after the
13 execution of a final settlement agreement;
WHEREAS, in light of the anticipated dismissal of this case, Plaintiff and Defendants
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15 desire to extend the Rule 26 Deadlines and the briefing schedule for the Motions to Dismiss;
IT IS HEREBY STIPULATED and agreed to, by and among the undersigned, on behalf of
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17 their respective clients, to enlarge the time regarding the Rule 26 Deadlines and the briefing
18 schedule for the Motions to Dismiss such that each deadline and event will be extended by six
19 weeks.
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The stipulated dates are as follows:
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December 2, 2014
Last Day to:
(1)
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(2)
(3)
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Meet and confer re: initial disclosures, early
settlement, ADS process selection, and discovery
plan;
File ADR Certification signed by Parties and Counsel
File either Stipulation to ADR Process or Notice
Need for ADR Phone Conference
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December 8, 2014
Last day to file response brief to the Motions to Dismiss.
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December 18, 2014
Last day to file reply briefs in support of the Motions to
Dismiss.
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15729.001 2965494v1
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STIPULATION AND [PROPOSED] ORDER ENLARGING TIME
3:14-CV-03275 VC
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December 23, 2014
Last day to file Rule 26(f) Report, complete initial
disclosures or state objection in Rule 26(f) Report and file
Case Management Statement per Court's standing order re:
Contents of Joint Case Management Statement
December 30, 2014
Initial Case Management Conference in Courtroom 4, 17th
Floor at 10:00 a.m.
January 8, 2014
Hearing on Motions to Dismiss. Note that this date has been
extended by seven weeks, as a six week extension would
cause the hearing to be scheduled for January 1, 2015.]
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COBLENTZ PATCH DUFFY & BASS LLP
One Ferry Building, Suite 200, San Francisco, California 94111-4213
415.391.4800 • Fax 415.989.1663
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IT IS SO STIPULATED AND AGREED.
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11 DATED: October 15, 2014
COBLENTZ PATCH DUFFY & BASS LLP
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By: /s/Charmaine G. Yu
Charmaine G. Yu
Attorneys for Attorneys for ALCO IRON &
METAL CO.
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16 DATED: October 15, 2014
BERLINER COHEN
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By: /s/Sara Pollock
Sara Pollock
Attorneys for PICK-N-PULL AUTO
DISMANTLERS
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DATED: October 15, 2014
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THE LAW OFFICES OF ERIK BABCOCK
By: /s/ Erik Babcock
Erik Babcock
Attorneys for EMILIO ZAMORA
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25 DATED: October 15, 2014
THE LAW OFFICES OF PAUL M. WELLENKAMP
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By: /s/Paul M. Wellenkamp
Paul M. Wellenkamp
Attorneys for CESAR ZAMORA
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STIPULATION AND [PROPOSED] ORDER ENLARGING TIME
3:14-CV-03275 VC
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DATED: October 15, 2014
BONJOUR, THORMAN, BARAY & BILLINGSLEY
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By: /s/Michael Thorman
Michael Thorman
Attorneys for RICARDO ZAMORA
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COBLENTZ PATCH DUFFY & BASS LLP
One Ferry Building, Suite 200, San Francisco, California 94111-4213
415.391.4800 • Fax 415.989.1663
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15729.001 2965494v1
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STIPULATION AND [PROPOSED] ORDER ENLARGING TIME
3:14-CV-03275 VC
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FILER'S ATTESTATION PURSUANT TO CIVIL LOCAL RULE 5-1(i)(3)
I, Charmaine G. Yu, attest that concurrence in the filing of this STIPULATION AND
3 [PROPOSED] ORDER ENLARGING TIME FOR DISCOVERY CONFERENCE AND
4 INITIAL DISCLOSURES, AND INITIAL CASE MANAGEMENT CONFERENCE
COBLENTZ PATCH DUFFY & BASS LLP
One Ferry Building, Suite 200, San Francisco, California 94111-4213
415.391.4800 • Fax 415.989.1663
5 PURSUANT TO LOCAL RULE 6-2 has been obtained from each of the other signatories.
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Executed this 15th of October, 2014, at San Francisco, California.
/s/Charmaine G. Yu
Charmaine G. Yu
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STIPULATION AND [PROPOSED] ORDER ENLARGING TIME
3:14-CV-03275 VC
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[PROPOSED] ORDER
PURSUANT TO THE STIPULATION, IT IS SO ORDERED.
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October 20
4 DATED: _______, 2014
Hon. Vince Chhabria
United States District Court Judge
COBLENTZ PATCH DUFFY & BASS LLP
One Ferry Building, Suite 200, San Francisco, California 94111-4213
415.391.4800 • Fax 415.989.1663
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STIPULATION AND [PROPOSED] ORDER ENLARGING TIME
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