Yanushkevich v. Aaron Brothers, Inc. et al

Filing 18

STIPULATION AND ORDER re #17 Extending Time to Respond to Plaintiff's Complaint filed by Aaron Brothers, Inc. Signed by Judge Edward M. Chen on 11/7/16. (bpfS, COURT STAFF) (Filed on 11/7/2016)

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LEON COSGROVE, LLC
John Bosco, Texas State Bar Number 24045533
8117 Preston Road, Suite 300
Dallas, TX 75225
Telephone: [phone]
Fax: [phone]
Email: [e-mail]
Admitted Pro Hac Vice
Attorney for AARON BROTHERS, INC., Defendant

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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DMITRY YANUSHKEVICH,
Plaintiff,

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vs.

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AARON BROTHERS, INC., a Delaware
corporation, d/b/a AARON BROTHERS
ART & FRAMING; ALEX DELLY, an
individual; SHARON K. DELLY, an
individual; ROBERT G. BLATMAN, an
individual; and DOES 1-20 inclusive,
Defendants.

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Case No. 16-cv-3019-EMC
JOINT STIPULATION AND
[PROPOSED] ORDER
EXTENDING TIME TO
RESPOND TO PLAINTIFF’S
COMPLAINT

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WHEREAS, in the interest of conserving party and judicial resources and exploring the
possibility of an early resolution, Plaintiff Dmitry Yanushkevich (“Plaintiff”), has provided
Defendant Aaron Brothers, Inc., Defendant Alex Delly, Defendant Sharon K. Delly, and

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Defendant Robert G. Blatman (collectively, “Defendants”) with a settlement demand,

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Defendants have responded and the parties are actively engaged in productive settlement

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discussions;

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WHEREAS, a resolution of the case would obviate Defendants’ need to respond to the
Complaint;

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{00112092. 1 }

Page 1 of 3
Joint Stipulation and Proposed Order
Case No.: 16-CV-3019-EMC

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WHEREAS, the parties have previously stipulated to extend Defendants’ deadline to
respond to the Complaint;
Pursuant to Local Rule 6-2, IT IS HEREBY STIPULATED AND AGREED to by and
between the parties, subject to the approval of the Court, that the following deadlines apply:
November 11, 2016

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Last Day for Defendants to Respond to Complaint

November 11, 2016

Last Day for Plaintiff to file “Notice of Need for

Mediation”

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No provision of this Stipulation shall be construed as a waiver of any and all claims or

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defenses available to either Plaintiff or Defendants, and any and all such claims and defenses are

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hereby expressly reserved.

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IT IS SO STIPULATED.
Dated: October 26, 2016

/s/ Irene Karbelashvili
Irene Karbelashvili, Attorney for
Plaintiff Dmitry Yanushkevich

Dated: October 26, 2016

/s/ John Bosco
John Bosco, Attorney for
Defendant Aaron Brothers, Inc.

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FILER’S ATTESTATION
Pursuant to Local Rule 5-1, I hereby attest that I, John D. Bosco, received the
concurrence of counsel for Plaintiff in the filing of this document.

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By: /s/ John Bosco
JOHN BOSCO

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{00112092. 1 }

Page 2 of 3
Joint Stipulation and Proposed Order
Case No.: 16-CV-3019-EMC

[PROPOSED] ORDER

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Based on the foregoing stipulation, IT IS SO ORDERED that the following deadlines
apply:

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November 11, 2016

Last Day for Defendants to Respond to Complaint

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November 11, 2016

Last Day for Plaintiff to file “Notice of Need for

Mediation”

UNIT
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{00112092. 1 }

FO

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__________________________________________
D
RDERE
THE HONORABLE JUDGE EDWARD M. CHEN
IS SO O DISTRICT JUDGE
IT
UNITED STATES

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A

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Page 3 of 3
Joint Stipulation and Proposed Order
Case No.: 16-CV-3019-EMC

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