Elida Calderon et al v. Victor Juan Untiveros et al

Filing 29

STIPULATION AND ORDER re 28 STIPULATION WITH PROPOSED ORDER Joint Application and Stipulation to Extend Deadline to Amend Pleadings filed by 4th & Elm, LLC, Elizabel Hernandez, Elida Calderon, Fair Housing of Marin Amended Pleadings due by 4/29/2016. Signed by Magistrate Judge Kandis A. Westmore on 4/5/16. (sisS, COURT STAFF) (Filed on 4/5/2016)

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1 2 3 4 5 6 7 8 9 10 BRANCART & BRANCART Christopher Brancart (CBN 128475) cbrancart@brancart.com Liza Cristol-Deman (CBN 190516) lcristoldeman@brancart.com Post Office Box 686 Pescadero, CA 94060 Tel: (650) 879-0141 Fax: (650) 879-1103 FAIR HOUSING OF MARIN Casey Epp (CBN 284139) Casey@fairhousingmarin.com 1314 Lincoln Avenue, Suite A San Rafael, CA 94901 Tel: (415) 457-5025 Fax: (415) 457-6382 Attorneys for Plaintiffs 11 UNITED STATES DISTRICT COURT 12 NORTHERN DISTRICT OF CALIFORNIA 13 14 15 16 17 18 19 20 ELIZABEL HERNANDEZ, ELIDA ) CALDERON, and FAIR HOUSING OF ) MARIN, a Not-for-Profit Corporation, ) ) Plaintiffs, ) ) vs. ) ) VICTOR JUAN UNTIVEROS and 4TH ) & ELM, LLC, ) ) Defendants. ) ) Case No. 15-cv-04523-KAW JOINT APPLICATION AND STIPULATION TO EXTEND DEADLINE TO AMEND UNTIL AFTER MEDIATION; [PROPOSED] ORDER 21 Pursuant to Local Rules 6-2 and 7-12, plaintiffs and defendant 4th and Elm LLC, by and 22 through their counsel of record, hereby apply for and stipulate to a brief extension of the 23 deadline to amend the pleadings in this case through April 29, 2016. The current deadline is 24 March 31, 2016, as set forth in the Court’s minute order dated January 12, 2016 (ECF 24). This 25 is the first request of any party for an extension of time. No other dates or deadlines will be 26 affected by this brief extension. 27 There is good cause to grant this brief extension of time. 28 JOINT APPLICATION AND STIPULATION TO EXTEND DEADLINE TO AMEND UNTIL AFTER MEDIATION; [PROPOSED] ORDER - Case No. 15-cv-04523-KAW 1 1 First, it is based on the stipulation of counsel. 2 Second, the parties seek this extension because they are currently preparing for a 3 mediation session through the Court’s ADR Department. That mediation is scheduled to take 4 place on April 14, 2016. 5 Third, if the parties are unable to reach a resolution at the mediation, plaintiffs intend to 6 act diligently to amend the complaint to name the new owners of the subject property as 7 defendants in the case. The proposed deadline is 15 days following the mediation. 8 Fourth, this litigation is still in the early stages of discovery, and no other dates or 9 deadlines will be affected by this extension. The Court has not scheduled a trial date. Other than 10 the further CMC, scheduled for April 26, 2016, the only date set by the Court thus far is the last 11 day to amend. 12 // 13 // 14 // 15 // 16 // 17 // 18 // 19 // 20 // 21 // 22 // 23 // 24 // 25 // 26 // 27 // 28 JOINT APPLICATION AND STIPULATION TO EXTEND DEADLINE TO AMEND UNTIL AFTER MEDIATION; [PROPOSED] ORDER - Case No. 15-cv-04523-KAW 2 1 2 For all of the foregoing reasons, the parties request that the court issue the order below granting an extension of time to amend the pleadings through April 29, 2016. 3 So stipulated. 4 I, Liza Cristol-Deman, hereby attest that all signatories whose names appear below have 5 consented to the filing of this document. 6 Respectfully submitted, 7 BRANCART & BRANCART 8 Dated: March 30, 2016 9 /s/ Liza Cristol-Deman Liza Cristol-Deman Attorney for All Plaintiffs 10 11 FAIR HOUSING OF MARIN 12 Dated: March 30, 2016 /s/ Casey Epp Casey Epp Attorneys for All Plaintiffs 13 14 15 16 STRATMAN, PATTERSON & HUNTER Dated: March 30, 2016 17 /s/ P. Richard Colombatto P. Richard Colombatto Attorneys for Defendant 4th & Elm, LLC 18 19 20 [PROPOSED ORDER 21 22 PURSUANT TO STIPULATION, IT IS SO ORDERED. 23 24 4/5/16 Dated: ______________________. 25 26 27 Hon. Kandis A. Westmore U.S. Magistrate Judge 28 JOINT APPLICATION AND STIPULATION TO EXTEND DEADLINE TO AMEND UNTIL AFTER MEDIATION; [PROPOSED] ORDER - Case No. 15-cv-04523-KAW 3

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