Ramirez v. Apena Corp et al

Filing 14

STIPULATION AND ORDER re 13 STIPULATION WITH PROPOSED ORDER to Continue Joint Site Inspection filed by Irma Ramirez Signed by Judge Edward M. Chen on 11/25/15. (bpf, COURT STAFF) (Filed on 11/25/2015)

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THOMAS E. FRANKOVICH (State Bar No. 074414)
THOMAS E. FRANKOVICH,
A Professional Law Corporation
1832- A Capitol Street
Vallejo, CA 94590
Telephone: [phone]
Facsimile:
[phone]
Attorney for Plaintiff
IRMA RAMIREZ

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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)
)
Plaintiff,
)
)
v.
)
)
APENA CORP, a California Corporation )
dba PLAZA TEQUILA TAQUERIA;
)
DEMETRIOS GIANNIS, Trustee and
)
ROSE GIANNIS, Trustee of the Giannis
)
Family Trust,
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Defendants..
)
___________________________________ )
IRMA RAMIREZ,

CASE NO. 15-cv-03808-EMC
STIPULATION RE CONTINUING
DEADLINE FOR THE PARTIES TO
CONDUCT THE JOINT SITE
INSPECTION, [PROPOSED] ORDER
THEREON

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Plaintiff and Defendants by and through their respective attorney of record, respectfully
request and stipulate, as follows:
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Whereas, defendants have been served with the summons and complaint and

have answered plaintiff’s complaint;
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Whereas, pursuant to General Order 56, ¶3,4, the parties are to have the Joint

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Site Inspection at the Plaza Tequila Taqueria, located at/near 19315 Highway 12, Sonoma,

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California, no later than December 3, 2015 . However, due to scheduling conflicts and the holidays,

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the parties are unable to conduct the General Order 56 Joint Site Inspection by the December 3rd

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deadline.

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3.

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Therefore, in light of the above, the parties have agreed to reschedule and

conduct the joint site inspection on December 10, 2015.
STIPULATION RE CONTINUING DEADLINE FOR THE PARTIES TO CONDUCT THE JOINT SITE
INSPECTION and [PROPOSED] ORDER THEREON

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IT IS SO STIPULATED.

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This stipulation may be executed in counterparts and have the same force and effect as

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though all signatures are on the same and/or consecutive pages. Photocopies and facsimile shall

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have the same force and effect as originals.

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Respectfully submitted,

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7 Dated: November 24, 2015
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THOMAS E. FRANKOVICH, Esq.
A PROFESSIONAL LAW CORPORATION
By: /s/ Thomas E. Frankovich
Thomas E. Frankovich
Attorney for Plaintiff IRMA RAMIREZ

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By: /s/ Marvin Pederson
Marvin Pederson
Attorney for Defendant Apena Corp.

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ATTORNEY AT LAW

Dated: November 24, 2015

DICKENSON, PEATMAN & FOGARTY, P.C.

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By: /s/Joy Durand
Joy Durand
Attorney for Defendants Demetrios Giannis and
Rose Giannis

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December 10

inspection of the premises be continued up to and including ________________________, 2015.

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S

O
IT IS S

ORD

R NIA

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Honorable Edward M. Chen
United States District Judge
ERED

hen

NO

.C
STIPULATION RE CONTINUING DEADLINE FOR THE PARTIES TO CONDUCT THE JOINT SITE
ward M
udge Ed
J
INSPECTION and [PROPOSED] ORDER THEREON

RT

FO

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Dated: _______________, 2015

RT
U
O

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S DISTRICT
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C
_______________________________
TA

November 25

UNIT
ED

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H

ER

LI

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IT IS SO ORDERED, that the last day for the parties and counsel to conduct the joint site

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PROPOSED ORDER

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