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

Filing 85

ORDER GRANTING 82 STIPULATION Continuing Deadlines Set in April 29, 2016 Order (doc. no. 65). Fact Discovery due by 5/27/2016. Expert Discovery due by 7/15/2016. Motion Hearing set for 7/22/2016 09:00 AM in Courtroom 5, 2nd Floor, Oakland before Hon. Jeffrey S. White. Signed by Judge Jeffrey S. White on 5/31/16. (jjoS, COURT STAFF) (Filed on 5/31/2016)

Case 4:15-cv-03220-JSW Document 82 Filed 05/27/16 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.

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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,

Case No. 4:15-CV-03220 JSW
Hon. Judge Jeffery S. White

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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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STIPULATION AND [PROPOSED]
ORDER CONTINUING DEADLINES SET
IN APRIL 29, 2016 ORDER
(DKT. NO. 65)
AS MODIFIED

Defendants.

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Stipulation and [Proposed] Order Continuing Deadlines Set in April 29, 2016 Order (Dkt. No. 65);

Case No. 4:15-CV-03220

Case 4:15-cv-03220-JSW Document 82 Filed 05/27/16 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 April 29, 2016 (Dkt. No. 65), setting case
deadlines pursuant to stipulation of the parties;

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WHEREAS, the current schedule is as follows:

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Fact 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.

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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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WHEREAS, Defendants’ counsel and Plaintiffs’ counsel have met and conferred, and

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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
April 29, 2016 Order as follows:

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Fact discovery cut-off

May 27, 20161

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Designation of experts

June 22, 2016

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Expert discovery cut-off

July 15, 2016

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Hearing of dispositive motions

July 22, 2016

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Thereby extending the deadline to file discovery motions to June 3, 2016, pursuant to Local Rule
37-3.

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Stipulation and [Proposed] Order Continuing Deadlines Set in April 29, 2016 Order (Dkt. No. 65);

Case No. 4:15-CV-03220

Case 4:15-cv-03220-JSW Document 82 Filed 05/27/16 Page 3 of 5

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The parties propose no change to the other deadlines.

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IT IS SO STIPULATED.

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Respectfully submitted,

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DATED: May 27, 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: May 27, 2016

/s/ Celia McGuinness________________________
Paul L. Rein
Celia McGuinness
LAW OFFICES OF PAUL L. REIN
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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Stipulation and [Proposed] Order Continuing Deadlines Set in April 29, 2016 Order (Dkt. No. 65);

Case No. 4:15-CV-03220

Case 4:15-cv-03220-JSW Document 82 Filed 05/27/16 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: May 27, 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 April 29, 2016 Order (Dkt. No. 65);

Case No. 4:15-CV-03220

Case 4:15-cv-03220-JSW Document 82 Filed 05/27/16 Page 5 of 5

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[PROPOSED] ORDER
Pursuant to the parties’ stipulation, it is hereby ordered that the following deadlines set
forth in the April 29, 2016 Order are vacated and reset as follows:

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Fact discovery cut-off

May 27, 2016

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Designation of experts

June 22, 2016

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Expert discovery cut-off

July 15, 2016

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Hearing of dispositive motions

July 22, 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. The parties shall review this Court's deadlines relating to pre-trial conferences,
including the deadlines by which they must exchange motions in limine. The Court reserves the right to
continue the pretrial conference and trial if required.
May 31, 2016
DATED: ______________________
___________________________________
Honorable Jeffery S. White

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Stipulation and [Proposed] Order Continuing Deadlines Set in April 29, 2016 Order (Dkt. No. 65);

Case No. 4:15-CV-03220