Ramirez v. Old Mexico Restaurant East Side, Inc. et al

Filing 11

ORDER GRANTING re 8 Stipulation To Extend Time Within Which to Respond to Complaint filed by Fernando A. Lopez, Sr., Old Mexico Restaurant East Side, Inc. Signed by Chief Magistrate Judge Joseph C. Spero on 10/8/15. (klhS, COURT STAFF) (Filed on 10/8/2015)

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ABBEY, WEITZENBERG, WARREN & EMERY
MITCHELL B. GREENBERG, Esq., State Bar 114878
100 Stony Point Road, Suite 200
Post Office Box 1566
Santa Rosa, CA 95402-1566
Telephone: [phone]
Facsimile: 707-542-2589
E-Mail: [e-mail]
Attorneys for Defendants
OLD MEXICO RESTAURANT EAST SIDE, INC., a California Corp. dba OLD
MEXICO RESTAURANT; and FERNANDO A. LOPEZ, SR., Successor Trustee
of the Lopez Family Trust, dated August 28, 1986

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ABBEY, WEITZENBERG, WARREN & EMERY, P.C.
100 Stony Point Road, Suite 200, P.O. Box 1566, Santa Rosa, CA 95402-1566
Telephone: [phone] Facsimile [phone]

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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IRMA RAMIREZ,
Plaintiffs,

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Case No.: CV-15 3700 JCS

v.
OLD MEXICO RESTAURANT EAST
SIDE, INC., a California Corp., dba OLD
MEXICO RESTAURANT; and
FERNANDO A. LOPEZ, Sr., Successor
Trustee of the Lopez Family Trust, dated
August 28, 1986,

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STIPULATION TO EXTEND
TIME WITHIN WHICH TO
RESPOND TO COMPLAINT
(LOCAL RULE 6-1)
The Honorable Joseph C. Spero

Defendants.

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Plaintiff IRMA RAMIREZ, on the one hand, and defendants OLD MEXICO

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RESTAURANT EAST SIDE, INC., a California Corp. dba OLD MEXICO

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RESTAURANT; and FERNANDO A. LOPEZ, SR., Successor Trustee of the

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Lopez Family Trust, dated august 28, 1986, on the other hand, through their

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respective counsel of record, hereby stipulate in accordance with Local Rule 6-1(a)

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to the following:

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1.

In compliance with General Order 56, the parties to this action will be

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scheduling their joint inspection of the premises within the timeframe set forth in

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this Court’s Scheduling Order (Docket #3), and will thereafter begin the process of

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meeting and conferring to discuss settlement of the claims in this action.
-1STIPULATION TO EXTEND TIME WITHIN WHICH TO RESPOND TO COMPLAINT (LOCAL RULE 6-1)

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2.

The CASp inspector retained by Defendants is currently out of town

and unavailable to meet with the parties at this time.

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3.

Defendants’ counsel will be out of the office from October 5-9.

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4.

Accordingly, Plaintiffs and Defendants stipulate that Defendants, and

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each of them, shall have to and including October 30, 2015 in which to file an

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answer or to otherwise respond to the Complaint in this action.

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IT IS SO STIPULATED:
Dated: October 7, 2015

ABBEY, WEITZENBERG, WARREN & EMERY

ABBEY, WEITZENBERG, WARREN & EMERY, P.C.
100 Stony Point Road, Suite 200, P.O. Box 1566, Santa Rosa, CA 95402-1566
Telephone: [phone] Facsimile [phone]

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By:

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/s/ Mitchell B. Greenberg
MITCHELL B. GREENBERG
Attorneys for Defendants
OLD MEXICO RESTAURANT EAST SIDE,
INC., and FERNANDO A. LOPEZ, SR.,
Successor Trustee of the Lopez Family Trust,
dated August 28, 1986

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Dated: October 7, 2015

THOMAS E. FRANKOVICH, ESQ.

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By:

/s/ Thomas E. Frankovich
THOMAS E. FRANKOVICH
Attorney for Plaintiff
IRMA RAMIREZ

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-2STIPULATION TO EXTEND TIME WITHIN WHICH TO RESPOND TO COMPLAINT (LOCAL RULE 6-1)

ATTESTATION OF CONCURRENCE

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I, Mitchell B. Greenberg, as the ECF user and filer of this document, attest

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that, pursuant to the United States District Court, Northern District Civil Local Rule

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5.1(i)(3), concurrence in the filing of this document has been obtained from the

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above signatories.

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Dated: October 7, 2015

ABBEY, WEITZENBERG, WARREN & EMERY

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By:

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pero

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Judge Jo

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DERED

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UNIT
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Dated: 10/8/15

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NO

ABBEY, WEITZENBERG, WARREN & EMERY, P.C.
100 Stony Point Road, Suite 200, P.O. Box 1566, Santa Rosa, CA 95402-1566
Telephone: [phone] Facsimile [phone]

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/s/ Mitchell B. Greenberg
MITCHELL B. GREENBERG
Attorneys for Defendants
OLD MEXICO RESTAURANT EAST SIDE,
INC., and FERNANDO A. LOPEZ, SR.,
Successor Trustee of the Lopez Family Trust,
dated August 28, 1986

N

F
D IS T IC T O
R

C

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-3STIPULATION TO EXTEND TIME WITHIN WHICH TO RESPOND TO COMPLAINT (LOCAL RULE 6-1)

CERTIFICATE OF SERVICE

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I, Mitchell B. Greenberg, attorney of record for Defendants OLD MEXICO

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RESTAURANT EAST SIDE, INC., and FERNANDO A. LOPEZ, SR., Successor

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Trustee of the Lopez Family Trust, dated August 28, 1986, I electronically filed the

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STIPULATION TO EXTEND TIME WITHIN WHICH TO RESPOND TO

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COMPLAINT (LOCAL RULE 6-1) with the Clerk of the Court using the

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electronic case filing system, which will send notifications of this filing to all

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parties registered with the Court’s electronic case filing system.

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ABBEY, WEITZENBERG, WARREN & EMERY, P.C.
100 Stony Point Road, Suite 200, P.O. Box 1566, Santa Rosa, CA 95402-1566
Telephone: [phone] Facsimile [phone]

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Dated: October 7, 2015

ABBEY, WEITZENBERG, WARREN & EMERY

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By:

/s/ Mitchell B. Greenberg
MITCHELL B. GREENBERG
Attorneys for Defendants
OLD MEXICO RESTAURANT EAST SIDE,
INC., and FERNANDO A. LOPEZ, SR.,
Successor Trustee of the Lopez Family Trust,
dated August 28, 1986

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-4STIPULATION TO EXTEND TIME WITHIN WHICH TO RESPOND TO COMPLAINT (LOCAL RULE 6-1)