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

Filing 65

ORDER GRANTING 64 STIPULATION TO EXTEND DEADLINES. Discovery due by 5/23/2016. Designation of Experts due by 5/23/2016. Expert Witness List due by 6/20/2016. Signed by Judge Jeffrey S. White on 4/29/16. (jjoS, COURT STAFF) (Filed on 4/29/2016) Modified on 4/29/2016 (jjoS, COURT STAFF).

Case 4:15-cv-03220-JSW Document 64 Filed 04/28/16 Page 1 of 5

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LYN R. AGRE (SBN 178218)
MARGARET A. ZIEMIANEK (SBN 233418)
GUNNAR K. MARTZ (SBN 300852)
KASOWITZ, BENSON, TORRES & FRIEDMAN LLP
101 California Street, Suite 2300
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendants
THE RELATED COMPANIES, INC.,
THIRD AND MISSION ASSOCIATES, LLC,
and RELATED MANAGEMENT COMPANY, L.P.
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

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101 CALIFORNIA STREET, SUITE 2300
SAN FRANCISCO, CALIFORNIA 94111

KASOWITZ, BENSON, TORRES & FRIEDMAN LLP

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PETER HOLLAND and KRISTEN
HOLLAND,
Plaintiffs,

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v.

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THE RELATED COMPANIES, INC.;
THIRD AND MISSION
ASSOCIATES, LLC; RELATED
MANAGEMENT COMPANY, L.P.;
DOES 1 through 10, inclusive

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Case No. 4:15-CV-03220 JSW
Hon. Judge Jeffery S. White
STIPULATION AND [PROPOSED]
ORDER CONTINUING DEADLINES SET
IN JANUARY 15, 2016 ORDER
(DKT. NO. 51)

Defendants.

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Stipulation and [Proposed] Order Continuing Deadlines Set in January 15, 2016 Order (Dkt. No. 51);

Case No. 4:15-CV-03220

Case 4:15-cv-03220-JSW Document 64 Filed 04/28/16 Page 2 of 5

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By and through their attorneys of record, Defendants THE RELATED COMPANIES,

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INC., THIRD AND MISSION ASSOCIATES, LLC, and RELATED MANAGEMENT

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COMPANY, L.P. (collectively, “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 an order on January 15, 2016, (Dkt. No. 51) setting case
deadlines pursuant to stipulation of the parties;

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WHEREAS, Defendants’ counsel and Plaintiffs’ counsel have met and conferred, and
agree that extension of certain of the deadlines in the current scheduling order is warranted.

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IT IS HEREBY STIPULATED AND AGREED, by and between the parties hereto and
their respective undersigned attorneys, as follows:

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The parties respectfully jointly request that the Court continue the deadlines set forth in the
January 15, 2016 Order as follows:

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Discovery Cut-off

May 23, 2016

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Designation of experts

May 23, 2016

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Expert discovery cut-off

June 20, 2016

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The parties propose no change to the following deadlines set forth in the January 15, 2015
Order:

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Hearing of dispositive motions

July 8, 2016

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Pretrial conference

September 26, 2016 at 2:00 p.m.

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Jury selection

October 26, 2016 at 8:00 a.m.

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Trial

October 31, 2016 at 8:00 a.m.

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IT IS SO STIPULATED.

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Stipulation and [Proposed] Order Continuing Deadlines Set in January 15, 2016 Order (Dkt. No. 51);

Case No. 4:15-CV-03220

Case 4:15-cv-03220-JSW Document 64 Filed 04/28/16 Page 3 of 5

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Respectfully submitted,

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DATED: April 28, 2016

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/s/ Lyn R. Agre______________________________
Lyn R. Agre
KASOWITZ, BENSON, TORRES
& FRIEDMAN LLP

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Attorneys for Defendants
THE RELATED COMPANIES, INC.,
THIRD AND MISSION ASSOCIATES,
LLC, and RELATED MANAGEMENT
COMPANY, L.P.

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DATED: April 28, 2016

/s/ Celia McGuinness________________________
Paul L. Rein
Celia McGuinness
Catherine Cabalo
LAW OFFICES OF PAUL L. REIN

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Steven L. Derby
THE DERBY LAW FIRM P.C.
Attorneys for Plaintiffs
PETER HOLLAND and
KRISTEN HOLLAND

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Stipulation and [Proposed] Order Continuing Deadlines Set in January 15, 2016 Order (Dkt. No. 51);

Case No. 4:15-CV-03220

Case 4:15-cv-03220-JSW Document 64 Filed 04/28/16 Page 4 of 5

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CERTIFICATION OF COMPLIANCE WITH L.R. 5-1(i)(3)

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Pursuant to Local Rule 5-1(i)(3), I hereby certify that the content of this document is

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acceptable to Celia McGuinness and Steven L. Derby, counsel for Plaintiffs, and that I have

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obtained their authorization to affix their respective electronic signatures to this document.

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DATED: April 28, 2016

/s/ Lyn R. Agre______________________________
Lyn R. Agre
KASOWITZ, BENSON, TORRES & FRIEDMAN LLP

Attorneys for Defendants
THE RELATED COMPANIES, INC.,
THIRD AND MISSION ASSOCIATES, LLC, and
RELATED MANAGEMENT COMPANY, L.P.

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Stipulation and [Proposed] Order Continuing Deadlines Set in January 15, 2016 Order (Dkt. No. 51);

Case No. 4:15-CV-03220

Case 4:15-cv-03220-JSW Document 64 Filed 04/28/16 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
January 15, 2016 Order are vacated and reset as follows:

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Discovery Cut-off

May 23, 2016

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Designation of experts

May 23, 2016

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Expert discovery cut-off

June 20, 2016

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Hearing of dispositive motions

July 8, 2016

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Pretrial conference

September 26, 2016 at 2:00 p.m.

Jury selection

October 26, 2016 at 8:00 a.m.

Trial

October 31, 2016 at 8:00 a.m.

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IT IS SO ORDERED.

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April 29, 2016
DATED: ______________________

___________________________________
Honorable Jeffery S. White

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Stipulation and [Proposed] Order Continuing Deadlines Set in January 15, 2016 Order (Dkt. No. 51);

Case No. 4:15-CV-03220