Holland et al v. The Related Companies, Inc. et al

Filing 51

ORDER GRANTING AS MODIFIED 50 STIPULATION Continuing Hearings and Deadlines. Discovery due by 5/2/2016. Expert Witness List due by 5/31/2016. Jury Selection set for 10/26/2016 08:00 AM in Courtroom 5, 2nd Floor, Oakland before Hon. Jeffrey S. White. Jury Trial set for 10/31/2016 08:00 AM in Courtroom 5, 2nd Floor, Oakland before Hon. Jeffrey S. White. Motion Hearing set for 7/8/2016 09:00 AM in Courtroom 5, 2nd Floor, Oakland before Hon. Jeffrey S. White. Pretrial Conference set for 9/26/2016 02:00 PM in Courtroom 5, 2nd Floor, Oakland before Hon. Jeffrey S. White. Signed by Judge Jeffrey S. White on 1/15/16. (jjoS, COURT STAFF) (Filed on 1/15/2016)

Case 4:15-cv-03220-JSW Document 50 Filed 01/14/16 Page 1 of 5

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LYN R. AGRE (SBN 178218)
KASOWITZ, BENSON, TORRES & FRIEDMAN LLP
101 California Street, Suite 2300
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Defendants
RELATED MANAGEMENT COMPANY, L.P.
(incorrectly sued as The Related Companies, Inc.)
and THIRD AND MISSION ASSOCIATES, LLC

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

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PETER HOLLAND and KRISTEN
HOLLAND,

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101 CALIFORNIA STREET, SUITE 2300
SAN FRANCISCO, CALIFORNIA 94111

KASOWITZ, BENSON, TORRES & FRIEDMAN LLP

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Plaintiffs,
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v.
THE RELATED COMPANIES, INC.;
THIRD AND MISSION ASSOCIATES,
LLC; DOES 1 through 10, inclusive

Case No. 4:15-CV-03220 JSW
Hon. Judge Jeffery S. White
STIPULATION AND [PROPOSED]
ORDER CONTINUING DEADLINES SET
IN OCTOBER 2, 2015 CASE
MANAGEMENT ORDER (DKT. NO. 45)
AS MODIFIED HEREIN

Defendants.

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Stipulation and [Proposed] Order Continuing Deadlines Set in October 2, 2015 Case Management Order
(dkt. 45); Case No. 4:15-CV-03220

Case 4:15-cv-03220-JSW Document 50 Filed 01/14/16 Page 2 of 5

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By and through their attorneys of record, Defendants THIRD AND MISSION

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ASSOCIATES, LLC and RELATED MANAGEMENT COMPANY, L.P. (incorrectly sued as

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The Related Companies, Inc.) (“Defendants”) and Plaintiffs PETER HOLLAND and KRISTIN

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HOLLAND (“Plaintiffs”) hereby stipulate and agree as follows:

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WHEREAS, the Court entered a scheduling order on October 2, 2015 (dkt. No. 45) setting
case deadlines pursuant to stipulation of the parties;

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WHEREAS, the Court approved the substitution of Kasowitz, Benson, Torres & Friedman

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LLP in place of Kimball, Tirey & St. John LLP as Defendants’ counsel of record on December 18,

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2015;

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WHEREAS, Defendants’ new lead counsel, Lyn Agre, represents witnesses in a matter

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pending before the Honorable Charles R. Breyer in the United States District Court for the

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Northern District of California (United States v. Federal Express Corporation, Case No. 14-CR-

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380), which is set for trial on July 13, 2016 and expected to last several months;

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WHEREAS, Defendants’ new counsel and Plaintiffs’ counsel have met and conferred, and
agree that extension of certain of the deadlines in the current scheduling order is warranted.
IT IS HEREBY STIPULATED AND AGREED, by and between the parties hereto and
their respective undersigned attorneys, as follows:
The parties respectfully jointly request that the Court continue the deadlines set forth in the
October 2, 2015 Case Management Order as follows:

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Discovery Cut-off

May 2, 2016

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Designation of experts

May 2, 2016

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Expert discovery cut-off

May 31, 2016

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Hearing of dispositive motions

July 8, 2016

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Pretrial conference

September 26, 2016

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Jury selection & trial

October 31, 2016

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Stipulation and [Proposed] Order Continuing Deadlines Set in October 2, 2015 Case Management Order
(dkt. 45); Case No. 4:15-CV-03220

Case 4:15-cv-03220-JSW Document 50 Filed 01/14/16 Page 3 of 5

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Respectfully submitted,

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DATED: January 14, 2016

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/s/ Lyn R. Agre______________________________
Lyn R. Agre
KASOWITZ, BENSON, TORRES
& FRIEDMAN LLP
Attorneys for Defendants
THIRD AND MISSION ASSOCIATES, LLC and
RELATED MANAGEMENT COMPANY, L.P.
(incorrectly sued as The Related Companies, Inc.)

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DATED: January 14, 2016

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/s/ Steven L. Derby___________________________
Steven L. Derby
THE DERBY LAW FIRM P.C.

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Attorneys for Plaintiffs
PETER HOLLAND and
KRISTEN HOLLAND

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DATED: January 14, 2016

/s/ Celia McGuinness________________________
Paul L. Rein
Celia McGuinness
Catherine Cabalo
LAW OFFICES OF PAUL L. REIN
Attorneys for Plaintiffs
PETER HOLLAND and
KRISTEN HOLLAND

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Stipulation and [Proposed] Order Continuing Deadlines Set in October 2, 2015 Case Management Order
(dkt. 45); Case No. 4:15-CV-03220

Case 4:15-cv-03220-JSW Document 50 Filed 01/14/16 Page 5 of 5

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[PROPOSED] ORDER
Pursuant to the parties’ stipulation, it is hereby ordered that the deadlines set forth in the
October 2, 2015 Case Management Conference Order are vacated and reset as follows:
Discovery Cut-off

May 2, 2016

Designation of experts

May 2, 2016

Expert discovery cut-off

May 31, 2016

Hearing of dispositive motions

July 8, 2016

Pretrial conference
Jury selection
Jury selection & trial Trial

September 26, 2016 at 2:00 p.m.
October 26, 2016 at 8:00 a.m.
October 31, 2016 at 8:00 a.m.

IT IS SO ORDERED.

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January 15, 2016
DATED: ______________________

___________________________________
Honorable Jeffery S. White

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Stipulation and [Proposed] Order Continuing Deadlines Set in October 2, 2015 Case Management Order
(dkt. 45); Case No. 4:15-CV-03220