Mogaddedi v. Marriott International, Inc.

Filing 37

JOINT STIPULATION AND ORDER RE: 36 : IT IS HEREBY ORDERED that the following dates are continued: (1) the Non-Expert Discovery Completion Date, from 8/29/2016 to 10/10/2016; and (2) the last hearing date for dispositive motions, from 10/13/2016 to 12/1/2016. Signed by Judge Laurel Beeler on 8/10/2016. (afmS, COURT STAFF) (Filed on 8/11/2016)

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MAYALL HURLEY
A Professional Corporation
2453 Grand Canal Boulevard
Stockton, California 95207
Telephone [phone]
Facsimile [phone]
NICHOLAS J. SCARDIGLI
CA State Bar No. 249947
VLADIMIR J. KOZINA
CA State Bar No. 284645

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Attorneys for Plaintiff AZIZ MOGADDEDI
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Leila Narvid, Bar No. 229402
[e-mail]
Jonathan W. Black, Bar No. 280421
[e-mail]
PAYNE & FEARS LLP
Attorneys at Law
One Post Street, Suite 1000
San Francisco, California 94104
Telephone: [phone]
Facsimile: [phone]

Attorneys for Defendant
MARRIOTT HOTEL SERVICES, INC.

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UNITED STATE DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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AZIZ MOGADDEDI,

Case No.: 3:15-cv-02563-LB

Plaintiff,

JOINT STIPULATION AND REQUEST
TO CONTINUE (1) NON-EXPERT
DISCOVERY COMPLETION DATE
AND (2) LAST HEARING DATE FOR
DISPOSITIVE MOTIONS; [PROPOSED]
ORDER

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v.
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MARRIOTT INTERNATIONAL, INC.;
and DOES 1-100, inclusive,

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Defendants.

The Hon. Laurel Beeler

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Joint Stipulation and Request to Continue Non-Expert Discovery Completion Date and Last Date for Dispositive
Motions; [Proposed] Order
Page 1 of 4

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The parties to the above-entitled action hereby respectfully submit this Joint Stipulation and

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Request to Continue (1) the Non-Expert Discovery Completion Date, from August 29, 2016, to

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October 10, 2016; and (2) the last hearing date for dispositive motions, from October 13, 2016, to

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December 1, 2016. The parties had refrained from conducting extensive discovery in anticipation

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of a recent, ultimately unsuccessful, settlement conference on June 17, 2016, and are currently in

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the process of meeting and conferring regarding discovery responses.

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JOINT STIPULATION AND REQUEST TO CONTINUE

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WHEREAS, the parties had refrained from conducting extensive discovery in anticipation
of a court-sponsored mediation on November 24, 2016, and a settlement conference on June 17,
2016;
WHEREAS, the parties are currently in the process of meeting and conferring regarding
discovery responses;
WHEREAS, Plaintiff is waiting for the conclusion of the meet and confer process before
setting depositions;
WHEREAS, the parties have recently agreed upon a mutual convenient date for the
deposition of Plaintiff, August 25, 2016;
WHEREAS, parties request that the Court continue (1) the Non-Expert Discovery

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Completion Date, from August 29, 2016, to October 10, 2016; and (2) the last hearing date for

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dispositive motions, from October 13, 2016, to December 1, 2016. This stipulation does not alter

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the date of any other event or deadline already fixed by Court order.

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DATED: August 10, 2016

MAYALL HURLEY P.C.

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By

/s/ Nicholas J. Scardigli
NICHOLAS J. SCARDIGLI
VLADIMIR J. KOZINA
Attorneys for Plaintiff
AZIZ MOGADDEDI

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Joint Stipulation and Request to Continue Non-Expert Discovery Completion Date and Last Date for Dispositive
Motions; [Proposed] Order
Page 2 of 4

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DATED: August 10, 2016

PAYNE & FEARS LLP

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By

/s/ Leila Narvid
LEILA NARVID
Attorneys for Defendant
MARRIOTT INTERNATIONAL, INC.

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Joint Stipulation and Request to Continue Non-Expert Discovery Completion Date and Last Date for Dispositive
Motions; [Proposed] Order
Page 3 of 4

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[PROPOSED] ORDER
Pursuant to the Joint Stipulation by the parties, and GOOD CAUSE APPEARING
THEREFORE,

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IT IS HEREBY ORDERED that (1) the Non-Expert Discovery Completion Date, from

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August 29, 2016, to October 10, 2016; and (2) the last hearing date for dispositive motions, from

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October 13, 2016, to December 1, 2016.

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DATED: August __, 2016

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_____________________________________
Hon. Laurel Beeler
U.S. Magistrate Judge

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Joint Stipulation and Request to Continue Non-Expert Discovery Completion Date and Last Date for Dispositive
Motions; [Proposed] Order
Page 4 of 4