Jill Cakebread et al v. Berkeley Millwork and Furniture Co., Inc.

Filing 46

STIPULATION AND ORDER Extending Deposition and Dispositive Motion Filing Deadlines. Jury Selection set for 5/1/2017 at 09:00 AM in Courtroom 3, 17th Floor, San Francisco before Hon. Richard Seeborg. Jury Trial set for 5/1/2017 at 09:00 AM in Cou rtroom 3, 17th Floor, San Francisco before Hon. Richard Seeborg. Pretrial Conference set for 4/20/2017 at 10:00 AM in Courtroom 3, 17th Floor, San Francisco before Hon. Richard Seeborg. Signed by Judge Richard Seeborg on 10/24/16 (cl, COURT STAFF) (Filed on 10/24/2016) Modified on 10/24/2016 (cl, COURT STAFF).

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Clara J. Shin (No. 214809)
Ethan Forrest (No. 286109)
COVINGTON & BURLING LLP
One Front Street, 35th Floor
San Francisco, California 94111-5356
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
Attorneys for Plaintiffs and Counter-Defendants
JILL CAKEBREAD and STEVE CAKEBREAD

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Melvin D. Honowitz (No. 57341)
Eric C. Shaw (No. 104889)
LAW OFFICE OF MELVIN D. HONOWITZ & ASSOCIATES
One Embarcadero Center, Ste. 500
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
Attorneys for Defendant
BERKELEY MILLWORK
AND FURNITURE CO. INC.

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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JILL CAKEBREAD and STEVE CAKEBREAD,

Civil Case No.: 16-cv-00083-RS

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Plaintiffs,
v.
BERKELEY MILLWORK AND FURNITURE
CO., INC.,

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Defendant.

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and related counterclaims.

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STIPULATED REQUEST FOR ORDER
EXTENDING DEPOSITION AND DISPOSITIVE
MOTION FILING DEADLINES AND [PROPOSED]
ORDER
Civil Case No.: 16-cv-00083-RS

STIPULATED REQUEST FOR ORDER
EXTENDING DEPOSITION AND
DISPOSITIVE MOTION FILING
DEADLINES AND [PROPOSED] ORDER

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Pursuant to Local Rule 6-2, IT IS HEREBY STIPULATED by and between Jill and Steve

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Cakebread and Berkeley Millwork & Furniture Co., Inc., through their respective counsel, that, if the

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Court approves, the current deadlines for completion of depositions and filing of dispositive pretrial

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motions, and the dates of the final pretrial conference and beginning of trial, be extended as set forth

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below. The stipulation is based on the following:

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1.

The parties have a pending discovery dispute and motion for sanctions before

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Judge Donna M. Ryu set for hearing on October 27, 2016. ECF No. 42. Relatedly, the Court postponed

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consideration of the Cakebreads’ Motion for Summary Judgment on Berkeley Millwork’s counterclaims

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until the discovery dispute is resolved. ECF No. 38.

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2.

Given these pending motions, the parties cannot complete depositions and file other

dispositive pretrial motions by the current deadlines of November 7 and November 17, respectively.

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3.

The parties propose and stipulate to a revised schedule as to these dates:

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•

On or before December 16, 2016, the parties must complete all depositions.

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•

On or before December 30, 2016, the parties must file and serve all dispositive pretrial

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motions.

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•

20, 2017
The final pretrial conference will be held on April 21, 2017.

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•

Trial will begin on May 1, 2017.

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4.

The parties have not previously modified any deadlines in this case.

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5.

The parties respectfully ask that the Court grant their request.

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6.

Counsel for each party declares under penalty of perjury that the foregoing is true and

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correct.

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STIPULATED REQUEST FOR ORDER
EXTENDING DEPOSITION AND DISPOSITIVE
MOTION FILING DEADLINES AND [PROPOSED]
ORDER
Civil Case No.: 16-cv-00083-RS

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*

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Per Local Rule 5-1(i)(3), the filer of this document hereby attests that the concurrence to the
filing of this document has been obtained from the other signatory.

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DATED: October 24, 2016

COVINGTON & BURLING LLP

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By:

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/s/Ethan Forrest
Clara J. Shin
Ethan Forrest
Attorneys for Plaintiffs and
Counter-Defendants
JILL CAKEBREAD and
STEVE CAKEBREAD

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DATED: October 24, 2016

LAW OFFICE OF MELVIN D. HONOWITZ
& ASSOCIATES

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By:

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/s/Eric C. Shaw
Melvin D. Honowitz
Eric C. Shaw
Attorneys for Defendant and CounterClaimant BERKELEY MILLWORK
AND FURNITURE CO., INC.

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ORDER [PROPOSED]

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Pursuant to stipulation, IT IS SO ORDERED.
DATED: ______________________
10/24/16

__________________________________
HONORABLE RICHARD G. SEEBORG
UNITED STATES DISTRICT JUDGE

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STIPULATED REQUEST FOR ORDER
EXTENDING DEPOSITION AND DISPOSITIVE
MOTION FILING DEADLINES AND [PROPOSED]
ORDER
Civil Case No.: 16-cv-00083-RS

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