Delgado v. Dharm-Jit Holding Company, LLC et al

Filing 15

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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1 2 3 4 5 6 7 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 8 9 10 11 12 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 13 UNITED STATES DISTRICT COURT 14 NORTHERN DISTRICT OF CALIFORNIA 15 16 DANIEL DELGADO, 17 18 19 20 21 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 22 23 24 25 26 27 28 1 SECOND JOINT STIPULATION Case No. CV 11 - 2037 1 Plaintiff DANIEL DELGADO and Defendants DHARM-JIT HOLDING COMPANY, 2 LLC and STANDARD FOOD SERVICE, LLC dba DENNY’S (collectively “Defendants”) 3 hereby jointly stipulate, through their attorneys of record, to an extension of time of the deadline 4 by which the Parties must hold a joint site inspection of the premises, and all ensuing or 5 dependent dates, as set forth in the “Scheduling Order for Cases Asserting Denial of Right of 6 Access Under Americans With Disabilities Act Title II & III (42 U.S.C. 12131-89)” (“Scheduling 7 Order”), filed April 25, 2011. With this stipulated extension, the deadline for the site inspection 8 shall be extended from September 19 to October 31, 2011; the deadline for completion of initial 9 disclosures shall be extended from September 12 to October 23, 2011; the last date by which the 10 Parties shall meet and confer to discuss settlement shall be extended from October 3 to October 11 31, 2011; etc. 12 The Parties’ stipulation is based on the following: 13 (1) All Parties though their counsel have jointly agreed to extend the date for the joint site 14 inspection, the date for initial disclosures, the date for meet and confer discussions, 15 and all other dependent or ensuing dates set forth in the Scheduling Order, based on 16 the mutual unavailability and other scheduling commitments of counsel for the Parties 17 and their experts; and 18 19 (2) The Parties have scheduled a joint site inspection on October 12, 2011, at 10:00 a.m.; and 20 (3) In light of the foregoing and the Parties’ stipulation above, the Parties agree good 21 cause exists to extend these dates in the Scheduling Order, subject to the mutual 22 availability of counsel and their experts. 23 IT IS SO STIPULATED. 24 Dated: September 13, 2011 MOORE LAW FIRM, P.C. 25 /s/ Tanya E. Moore Tanya E. Moore Attorneys for Plaintiff DANIEL DELGADO 26 27 28 2 SECOND JOINT STIPULATION Case No. CV 11 - 2037 1 Dated: September 13, 2011 JACKSON LEWIS LLP 2 /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 3 4 5 6 ORDER 7 8 9 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: 10 The deadline for the site inspection shall now be October 31, 2011; 11 The deadline for completion of initial disclosures shall now be October 23, 2011; and 12 The last date by which the Parties shall meet and confer to discuss settlement shall be 13 October 31, 2011. 14 IT IS SO ORDERED. 15 16 Date: , 2011 Paul S. Grewal United States Magistrate Judge 17 18 19 20 21 4814-4630-1962, v. 1 22 23 24 25 26 27 28 3 SECOND JOINT STIPULATION Case No. CV 11 - 2037

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