Pimentel et al v. Bonsall et al

Filing 20

STIPULATION AND ORDER re 19 RE AMENDMENT OF COMPLAINT AND DISCOVERY WITH CERTIFICATE OF SERVICE filed by Robert Bonsall, etc. Motion to dismiss Hearing reset from 8/30/2018 to 9/6/2018 01:30 PM in San Francisco, Courtroom 05, 17th Floor before Judge Edward M. Chen. Case Management Statement due by 8/30/2018. Further Case Management Conference reset ffrom 8/30/2018 to 9/6/2018 01:30 PM in San Francisco, Courtroom 05, 17th Floor before Judge Edward M. Chen. Signed by Judge Edward M. Chen on 6/12/18. (bpfS, COURT STAFF) (Filed on 6/12/2018)

1 LINDA M. MORONEY (SBN: 172668)
[e-mail]
2 RYAN B. POLK (SBN: 230769)
[e-mail]
3 KEVIN LIU (SBN: 295287)
[e-mail]
4 GORDON REES SCULLY MANSUKHANI,
LLP
5 275 Battery Street, Suite 2000
San Francisco, CA 94111
Telephone: (415)
6 Telephone: [phone]
Facsimile: [phone]
Facsimile: [phone]
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Attorneys for Defendants
8 ROBERT BONSALL AND
BEESON, TAYER, & BODINE APC
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KENNETH C. ABSALOM
[e-mail]
10 [e-mail]
LAW OFFICE OF KENNETH C. ABSALOM
11 340 Pine Street, Suite 503
San Francisco, CA 94104
Telephone: (415)
12 Telephone: [phone]
Facsimile: [phone]
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Attorneys for Plaintiffs
14 ROLANDO PIMENTEL AND
ZACHARIAS SALAS
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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OLANDO
ROLANDO PIMENTEL, et al.,

CASE NO. 3:18-cv-01958-EMC

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Plaintiffs,

Related to Case No. 18-cv-00411-EMC

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v.
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OBERT
ROBERT BONSALL, et al.,

STIPULATION AND [PROPOSED]
ORDER RE AMENDMENT OF
COMPLAINT AND DISCOVERY (MODIFIED)

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Defendants.
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Date:
Time:
Courtroom:
Judge:

August 30, 2018
1:30 p.m.
5, 17th Floor
Hon. Edward M. Chen

Complaint Filed:
Trial Date:

February 2, 2018
Not set

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STIPULATION AND [PROPOSED] ORDER; Case No. 3:18-cv-01958-EMC

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Plaintiffs Rolando Pimentel and Zacharias Salas (“Plaintiffs”) and Defendants Robert
("Plaintiffs")

Bodine APC ("Defendants") (collectively, "the Parties")
2 Bonsall and Beeson, Tayer, & Bodine APC (“Defendants”) (collectively, “the Parties”) having met
3 and conferred subsequent to the Case Management Conference held on May 31, 2018, hereby
stipulation.
4 submit the following stipulation. The parties agree:
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1.
1.

Plaintiffs will not be amending the Complaint as against Defendants Robert Bonsall

6 and Beeson, Tayer, & Bodine APC at this time, but reserve the right to do so after the pending
7 motion to dismiss is resolved.
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2.
2.

Pursuant to this Court's
May 31, 2018
Pursuant to this Court’s Civil Minutes of the May 31, 2018 Case Management

9 Conference, counsel for the parties met and conferred on June 8, 2018 regarding the scope of
10 discovery to be conducted between now and August 30, 2018, and have no disputes to report.
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June
Dated: June 11, 2018

GORDON REES SCULLY MANSUKHANI, LLP

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By:

/s/ Ryan B. Polk
Linda M. Moroney
Ryan B. Polk
Kevin Liu
Attorneys for Defendants
ROBERT BONSALL AND
BEESON, TAYER, & BODINE APC

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Dated: June 11,
Dated: June 11, 2018

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Law Office of Kenneth C. Absalom
Absalom___________________
By: _/s/ Kenneth C. Absalom
/s/
Kenneth C. Absalom
Counsel for Plaintiffs' Pimental and Salas
Plaintiffs Pimental

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ATTESTATION
In accordance with Civ. L.R. 5.1(i)(3), I attest that concurrence in the filing of this
document has been obtained from the other Signatories, which shall serve in lieu of their signatures
on the document.

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June
Dated: June 11, 2018
By:

/s/ Kevin Liu
Kevin Liu

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STIPULATION AND [PROPOSED] ORDER; Case No. 3:18-cv-01958-EMC

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IT IS SO ORDERED.

Motion to dismiss and CMC reset from 8/30/18 to 9/6/18
at 1:30 p.m. Joint CMC statement due 8/30/18.

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10

S

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FO

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Judge E

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7

D
RDERE
S SO O IED
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6

United States District Judge

A

5

S DISTRICT
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TA
HONORABLE EDWARD M. CHEN

RT
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O

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6/12

DATED: ______________, 2018
,

UNIT
ED

3

N

D IS T IC T
R

OF

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STIPULATION AND [PROPOSED] ORDER; Case No. 3:18-cv-01958-EMC

C

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CERTIFICATE OF SERVICE
I am a resident of the State of California, over the age of eighteen years, and not a party to

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My business
Gordon Rees Scully Mansukhani,
the within action. My business address is: Gordon Rees Scully Mansukhani, LLP, 275 Battery

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Street, Suite 2000, San Francisco, CA 94111. On the date below, II served the within documents:
On the date below, served the within
2000, San Francisco, CA

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STIPULATION AND [PROPOSED] ORDER RE AMENDMENT OF COMPLAINT AND
DISCOVERY

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u


BY ELECTRONIC MAIL: I hereby certify that on ___________2018, a copy of the
2018,
foregoing documents were filed electronically. Notice of this filing will be sent by
filed electronically.
operation of the Court's electronic filing system to all parties indicated on the
operation of the Court’s electronic filing system to all parties indicated on the
electronic filing receipt. All other parties will be served by regular U.S. Mail. Parties
filing receipt.
served by regular U.S. Mail.
may access this filing through the Court's electronic filing system.
may access this filing through the Court’s electronic filing system.

u


BY OVERNIGHT MAIL. I deposited said document(s) by placing a true copy
thereof enclosed in a sealed envelope, at a station designated for collection and
processing of envelopes and packages for overnight delivery by and overnight
delivery services company as part of the ordinary business practices of Gordon Rees
Scully Mansukhani, LLP, described below, addressed as set forth below.

u


BY U.S. MAIL: I placed the document(s) listed above in a sealed envelope with
postage thereon fully prepaid, in United States mail in the State of California
addressed as set forth below.

x
u


BY ELECTRONIC FILING. I hereby certify that on June 11, 2018, a copy of the
foregoing documents were filed electronically. Notice of this filing will be sent by
filed electronically.
operation of the Court's electronic filing system to all parties indicated on the
operation of the Court’s electronic filing system to all parties indicated on the
All other parties will be
electronic filing receipt. All other parties will be served by regular U.S. Mail.
Parties may access this filing through the Court’s electronic filing system.
access this filing through the Court's electronic filing system.

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Attorneys for Plaintiff:

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Kenneth C. Absalom
Law Office of Kenneth C. Absalom
340 Pine Street, Suite 503
San Francisco, CA 94104
Phone: [phone]
[phone]
Fax: [phone]
Email: [e-mail]
[e-mail]

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I am readily familiar with the firm’s practice of collection and processing correspondence
I am readily familiar with the firm's practice of collection and processing correspondence
Under that practice it would be deposited with the
for mailing. Under that practice it would be deposited with the U.S. Postal Service on that same
day with postage thereon fully prepaid in the ordinary course of business. I am aware that on
prepaid in the ordinary course of business.
motion of the party served, service is presumed invalid if postal cancellation date or postage meter
date is more than one day after the date of deposit for mailing in affidavit.

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STIPULATION AND [PROPOSED] ORDER; Case No. 3:18-cv-01958-EMC

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I declare under penalty of perjury under the laws of the United States of America that I am
employed in the office of a member of the Bar of this Court at whose direction the service was
made.
Executed on June 11, 2018, at San Francisco, California.

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/s/
By: Is/ Mary Grogan

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STIPULATION AND [PROPOSED] ORDER; Case No. 3:18-cv-01958-EMC