Woodward et al v. Seftel et al

Filing 17

STIPULATION AND ORDER EXTENDING TIME TO RESPOND TO COMPLAINT FOR DEFENDANT DANIEL SEFTEL, LUCIENNE SEFTEL, WEI-SENG CHAN-KAI AND IVY WS CHAN-KAI re 9 . Signed by Judge Jeremy Fogel on 8/24/09. (dlm, COURT STAFF) (Filed on 8/31/2009)

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Dennis P. Howell, Esq. SBN 78806 Rebecca Connolly, Esq. SBN 145482 GRUNSKY, EBEY, FARRAR & HOWELL A Professional Corporation 240 Westgate Drive Watsonville, CA 95076 Telephone [phone] Facsimile [phone] Attorneys for Defendants DANIEL SEFTEL, LUCIENNE SEFTEL, WEI-SENG CHAN-KAI, and IVY WS CHAN-KAI UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION ZACHARY T. WOODFORD, Plaintiff, vs. DANIEL SEFTEL; LUCIENNE SEFTEL; WEI-SENG CHAN-KAI; IVY WS CHANKAI; QUEST DIAGNOSTICS, INC.; and DOES 1-10, Inclusive, Defendants. Defendants Daniel Seftel, Lucienne Seftel, Wei-Seng Chan-Kai, and Ivy Ws Chan-Kai ("Defendants") and Plaintiff Zachary T. Woodford ("Plaintiff"), by and through their undersigned attorneys, hereby state and stipulate as follows: WHEREAS the Complaint in this action was filed on June 6, 2009; and WHEREAS the Court issued is Scheduling Order for Cases Asserting Denial of Right of Access Under Americans with Disabilities Act Title II & II (42 U.S.C. §§ 12131-89) on June 9, 2009 ("Scheduling Order"); and, WHEREAS the Plaintiff filed a First Amended Complaint on July 10, 2009; and WHEREAS the Defendants were served on or about July 28, 2009 and Defendants' response
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-----No. C09-02569 PVT JF STIPULATION EXTENDING TIME TO RESPOND TO COMPLAINT FOR DEFENDANTS DANIEL SEFTEL, LUCIENNE SEFTEL, WEI-SENG CHANKAI, and IVY WS CHAN-KAI; [proposed] -------------- ORDER

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C 09-02569 PVT STIPULATION OF EXTENSION OF TIME TO FILE RESPONSIVE PLEADING

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to the First Amended Complaint is now due on August 17, 2009; and WHEREAS Plaintiff has agreed to Defendants' request for an extension of time to respond to the First Amended Complaint until September 10, 2009; and, WHEREAS the Plaintiff and Defendants stipulate that the dates set forth in the Scheduling Order need to be extended for an additional 30 days, and therefore, a Court Order is necessary under Northern District Local Rule 6-1(b). THEREFORE, the parties stipulate pursuant to Northern District Local Rule 7-12 that the date by which Defendants must file a response to the Complaint is extended until September 10, 2000 and that the last day for the parties and counsel to hold joint inspection of premises with or without meetand-confer regarding settlement currently set for September 17, 2009 is continued until October 19, 2009 and all dates set forth in the Scheduling Order based upon such inspection date are likewise extended to correspond to the October 19, 2009 date. IT IS SO STIPULATED: DATED: August 12, 2009 LAW OFFICES OF PAUL L. REIN /s/ By Paul L. Rein, Attorneys for Plaintiff

DATED:

August 12, 2009

GRUNSKY, EBEY, FARRAR & HOWELL /s/ By Rebecca Connolly, Attorneys for Defendants Daniel Seftel, Lucienne Seftel, Wei-Seng ChanKai, and Ivy Ws Chan-Kai

PURSUANT TO STIPULATION, IT IS HEREBY ORDERED that the date for filing of defendants' responsive pleadings is extended to September 10, 2009 and that the last day for the parties and counsel to hold joint inspection of premises with or without meet-and-confer regarding
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settlement currently set for September 17, 2009 is continued until October 19, 2009 and all dates set forth in the Scheduling Order based upon such inspection date are likewise extended to correspond to the October 19, 2009 date.

8/24/09 DATED: ____________________

_______________________________________ --------- --- ----------Patricia-V. -Trumbull Jeremy Fogel ------------- -----United States Magistrate -Judge-- District Judge

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C 09-02569 PVT STIPULATION OF EXTENSION OF TIME TO FILE RESPONSIVE PLEADING

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ATTESTATION PURSUANT TO GENERAL ORDER 45

I, Rebecca Connolly, attest that concurrence in the filing of this document has been obtained from the other signatory. I declare under penalty of perjury that the foregoing is true and correct. Executed this 12th day of August, 2009, at Watsonville, California.

By:

/s/ Rebecca Connolly Rebecca Connolly

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C 09-02569 PVT STIPULATION OF EXTENSION OF TIME TO FILE RESPONSIVE PLEADING