Delgado v. Dharm-Jit Holding Company, LLC et al
Filing
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STIPULATION AND ORDER re 14 Stipulation, filed by Dharm-Jit Holding Company, LLC, Standard Food Service, LLC. Signed by Judge Paul S. Grewal on September 16, 2011. (psglc2, COURT STAFF) (Filed on 9/19/2011)
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Prepared by:
Jamerson C. Allen (State Bar No. 132866)
Cara Ching-Senaha (State Bar No. 209467)
JACKSON LEWIS LLP
199 Fremont Street, 10th Floor
San Francisco, California 94105
Telephone: (415) 394-9400
Facsimile: (415) 394-9401
E-mail: allenj@jacksonlewis.com
E-mail: ching-senahac@jacksonlewis.com
Attorneys for Defendants DHARM-JIT
HOLDING COMPANY, LLC and
STANDARD FOOD SERVICE, LLC dba
DENNY’S
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Tanya E. Moore (SBN 206683)
K. Randolph Moore (SBN 106993)
MOORE LAW FIRM, P.C.
332 North Second Street
San Jose, CA 95112
Tel. (408) 298-2000
Fax. (408) 298-6046
Attorneys for Plaintiff DANIEL DELGADO
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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DANIEL DELGADO,
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Case No. CV 11-2037
Plaintiff,
SECOND JOINT STIPULATION OF
TIME EXTENDING TIME FOR
DATES STATED IN SCHEDULING
ORDER FILED APRIL 25, 2011;
[PROPOSED] ORDER
v.
DHARM-JIT HOLDING COMPANY, LLC;
STANDARD FOOD SERVICE, LLC dba
DENNY’S,
Complaint Filed: 4/25/2011
Trial Date:
Defendants.
None set
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SECOND JOINT STIPULATION
Case No. CV 11 - 2037
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Plaintiff DANIEL DELGADO and Defendants DHARM-JIT HOLDING COMPANY,
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LLC and STANDARD FOOD SERVICE, LLC dba DENNY’S (collectively “Defendants”)
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hereby jointly stipulate, through their attorneys of record, to an extension of time of the deadline
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by which the Parties must hold a joint site inspection of the premises, and all ensuing or
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dependent dates, as set forth in the “Scheduling Order for Cases Asserting Denial of Right of
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Access Under Americans With Disabilities Act Title II & III (42 U.S.C. 12131-89)” (“Scheduling
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Order”), filed April 25, 2011. With this stipulated extension, the deadline for the site inspection
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shall be extended from September 19 to October 31, 2011; the deadline for completion of initial
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disclosures shall be extended from September 12 to October 23, 2011; the last date by which the
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Parties shall meet and confer to discuss settlement shall be extended from October 3 to October
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31, 2011; etc.
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The Parties’ stipulation is based on the following:
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(1) All Parties though their counsel have jointly agreed to extend the date for the joint site
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inspection, the date for initial disclosures, the date for meet and confer discussions,
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and all other dependent or ensuing dates set forth in the Scheduling Order, based on
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the mutual unavailability and other scheduling commitments of counsel for the Parties
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and their experts; and
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(2) The Parties have scheduled a joint site inspection on October 12, 2011, at 10:00 a.m.;
and
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(3) In light of the foregoing and the Parties’ stipulation above, the Parties agree good
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cause exists to extend these dates in the Scheduling Order, subject to the mutual
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availability of counsel and their experts.
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IT IS SO STIPULATED.
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Dated: September 13, 2011
MOORE LAW FIRM, P.C.
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/s/ Tanya E. Moore
Tanya E. Moore
Attorneys for Plaintiff
DANIEL DELGADO
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SECOND JOINT STIPULATION
Case No. CV 11 - 2037
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Dated: September 13, 2011
JACKSON LEWIS LLP
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/s/ Cara Ching-Senaha
Jamerson C. Allen
Cara Ching-Senaha
Attorneys for Defendants
DHARM-JIT HOLDING COMPANY, LLC and
STANDARD FOOD SERVICE, LLC dba DENNY’S
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ORDER
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Having considered the Parties’ Stipulation and the grounds stated therein, and for good
cause shown, the Court hereby extends the dates set forth in the Scheduling Order, as follows:
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The deadline for the site inspection shall now be October 31, 2011;
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The deadline for completion of initial disclosures shall now be October 23, 2011; and
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The last date by which the Parties shall meet and confer to discuss settlement shall be
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October 31, 2011.
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IT IS SO ORDERED.
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Date:
, 2011
Paul S. Grewal
United States Magistrate Judge
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4814-4630-1962, v. 1
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SECOND JOINT STIPULATION
Case No. CV 11 - 2037
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