Superior Consulting Services, Inc. v. Steeves-Kiss

Filing 33

STIPULATION AND ORDER re 32 MOTION to Continue and for Extension of Time filed by Superior Consulting Services, Inc. Case Management Statement due by 3/29/2018. Initial Case Management Conference reset for 4/5/2018 09:30 AM in S an Francisco, Courtroom 05, 17th Floor. Responses due by 2/1/2018. Replies due by 2/15/2018. Motion Hearing set for 3/1/2018 01:30 PM in San Francisco, Courtroom 05, 17th Floor before Judge Edward M. Chen. Signed by Judge Edward M. Chen on 1/25/18. (bpf, COURT STAFF) (Filed on 1/25/2018)

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Coleman W. Watson, Esq.
[e-mail]
Attorney for Plaintiff, Superior Consulting Services, Inc.
California Bar No.: 266015
Watson LLP
189 S. Orange Avenue, Ste. 810
Orlando, FL 32801
Tel: [phone]
Fax: [phone]

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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SUPERIOR CONSULTING SERVICES,
INC., D/B/A YOUR FUTURE HEALTH
AND D/B/A YFH,

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Plaintiff,

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vs.
JENNIFER L. STEEVES-KISS,

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Defendant.

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Case No.: 3:17-cv-06059-EMC
STIPULATION AND [PROPOSED
ORDER] TO EXTEND BRIEFING
SCHEDULE FOR MOTION FOR
SANCTIONS, TO CONTINUE
MOTION TO DISMISS HEARING,
AND CONTINUE CASE
MANAGEMENT CONFERENCE

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Plaintiff, SUPERIOR CONSULTING SERVICES, INC., D/B/A YOUR FUTURE

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HEALTH AND D/B/A YFH (“Superior”) and Defendant, JENNIFER L. STEEVES-KISS,

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pursuant to Local Rule 6-2, by and through their respective counsel, hereby stipulate as follows:

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1.

Whereas, Superior filed the complaint in this action on October 23, 2017, Doc. 1,

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STIPULATION TO EXTEND BRIEFING SCHEDULE FOR MOTION FOR SANCTIONS, TO CONTINUE
MOTION TO DISMISS HEARING, AND CONTINUE CASE MANAGEMENT DEADLINES

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and an amended complaint on November 29, 2017, Doc. 16.

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Whereas, Defendant moved to dismiss the amended complaint on December 14,

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2017. Doc. 18. The motion to dismiss is currently set for hearing on January 26, 2018 at 9:00
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a.m.. Docs. 18, 28, 30.
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Whereas, Defendant filed a motion for sanctions on January 11, 2018. Doc. 24.

The responsive deadline to the motion is January 25, 2018.

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4.

Whereas, on January 12, 2018, the court entered an order setting a hearing on the

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motion for sanctions on March 1, 2018, as well as re-setting the initial case management
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conference for the same date. Doc. 25.
5.

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Whereas, on January 22, 2018, Superior’s lead counsel had a death in his

immediate family and has obligations to attend to for funeral arrangements and other affairs.

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6.

Whereas, on January 23, 2018, in light of this unexpected event, the parties

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stipulated and agreed to, modify the briefing schedule under Defendant’s Motion for Sanctions
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as follows: (i) Plaintiff’s responsive deadline currently scheduled for January 25, 2018 is

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extended to February 1, 2018; and, (ii) Defendant’s reply deadline is extended to February 15,

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2018.

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7.

Whereas, the parties stipulated and agreed to, continue the hearing on Defendant’s

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Motion to Dismiss Plaintiff’s amended Complaint from January 26, 2018 to March 1, 2018.
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8.

Whereas, the parties stipulated and agreed to, continue the Case Management

Conference scheduled on March 1, 2018 to April 2, 2018.
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Accordingly, the parties have stipulated and agreed to, seek the Court’s approval

for the revised briefing schedule on Defendant’s Motion for Sanctions based on the dates listed

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STIPULATION TO EXTEND BRIEFING SCHEDULE FOR MOTION FOR SANCTIONS, TO CONTINUE
MOTION TO DISMISS HEARING, AND CONTINUE CASE MANAGEMENT DEADLINES

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above, a continuance on Defendant’s Motion to Dismiss Hearing to March 1, 2018, and a

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continuance of the Case Management Conference to April 2, 2018.

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DATED on January 24, 2018
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/s/ Coleman Watson
Coleman W. Watson, Esq.
California Bar No. 266015
New York Bar No. 4850004
Florida Bar. No. 0087288
Georgia Bar No. 317133

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Email: [e-mail]
[e-mail]
WATSON LLP
189 S. Orange Avenue, Ste. 810
Orlando, FL 32801
Tel: [phone]
Fax: [phone]
Attorneys for Plaintiff,
SUPERIOR CONSULTING SERVICES,
INC.

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/s/ Dawn Valentine
ROBERT A. WEIKERT (SBN 121146)
[e-mail]
DAWN N. VALENTINE (SBN 206486)
[e-mail]
NIXON PEABODY LLP
One Embarcadero Center, 18th Floor
San Francisco, CA 94111-3600
Tel: [phone]
Fax: [phone]

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Attorneys for Defendant,
JENNIFER L. STEEVES-KISS

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STIPULATION TO EXTEND BRIEFING SCHEDULE FOR MOTION FOR SANCTIONS, TO CONTINUE
MOTION TO DISMISS HEARING, AND CONTINUE CASE MANAGEMENT DEADLINES

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ORDER

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Pursuant to the foregoing Stipulation, IT IS ORDERED that the briefing schedule on

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Defendant’s Motion for Sanctions is hereby extended such that Plaintiff’s responsive deadline is

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extended from January 25, 2018 to February 1, 2018, and Defendant’s reply deadline is extended

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to February 18, 2018. IT IS FURTHER ORDERED that the hearing on Defendant’s Motion to
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ER

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THE HONORABLE JUDGE EDWARD M. CHEN
Chen
ard M.
UNITED STATESeDISTRICT JUDGE
dg Edw
Ju

NO

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ERED
O ORD D
IT IS S
DIFIE
_________________________________________
AS MO
R NIA

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Dated: January ____, 2018.

S DISTRICT
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IT IS ORDERED.

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hereby continued, to March 1, 2018. IT IS FURTHER ORDERED that the Case Management
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Conference currently scheduled for March 1, 2018, be and hereby continued to, April 2, 2018.

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Dismiss Plaintiff’s Amended Complaint currently set for January 26, 2018 at 9:00 a.m., be and

UNIT
ED

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STIPULATION TO EXTEND BRIEFING SCHEDULE FOR MOTION FOR SANCTIONS, TO CONTINUE
MOTION TO DISMISS HEARING, AND CONTINUE CASE MANAGEMENT DEADLINES