Bolbol et al v. Feld Entertainment, Inc et al

Filing 22

STIPULATION AND ORDER TO EXTEND TIME FOR PLAINTIFFS TO FILE OPPOSITION TO DEFENDANTS' MOTION TO DISMISS re 21 Stipulation filed by Deniz Bolbol. Signed by Judge Paul S. Grewal on January 4, 2012. (psglc1, COURT STAFF) (Filed on 1/4/2012)

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G. WHITNEY LEIGH (SBN 153457)
MATT SPRINGMAN (SBN 252508)
GONZALEZ & LEIGH, LLP
744 Montgomery Street, Fifth Floor
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff
DENIZ BOLBOL
JOSEPH P. CUVIELLO
P.O. Box 2834
Redwood City, CA 94064
Telephone: [phone]
Plaintiff In Pro Se

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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DENIZ BOLBOL, and JOSEPH
CUVIELLO, INDIVIDUALLY,

Case No. 5:11-cv-05539 PSG

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STIPULATION AND [PROPOSED]
ORDER TO EXTEND TIME FOR
PLAINTIFFS TO FILE OPPOSITION
TO DEFENDANTS’ MOTION TO
DISMISS

Plaintiffs,
v.
FELD ENTERTAINMENT INC., (dba
RINGLING BROS. and BARNUM &
BAILEY CIRCUS), RINGLING BROS.
CIRCUS GENERAL MANAGER JAMES
DENNIS, RINGLING BROS. CIRCUS
OPERATIONS MANAGER MATTHEW
GILLET and DOES 1 through 10,

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Defendants.
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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME FOR PLAINTIFFS TO FILE
OPPOSITION TO MOTION TO DISMISS

Case No. 5:11-cv-05539 PSG

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Under Civil L.R. 6-2, the parties may file a stipulation, conforming to Civil L.R. 7-12,

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requesting an order changing time that would affect the date of an event or deadline already fixed

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by Court order. The stipulated request must be accompanied by a declaration that:

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(1)

Sets forth with particularity, the reasons for the requested enlargement of time;

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(2)

Discloses all previous time modifications in the case, whether by stipulation or

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Court order; and

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(3)

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Describes the effect the requested time modification would have on the schedule

for the case.
The Hearing in this matter is scheduled for February 14, 2012. Plaintiffs’ Opposition to
Defendants’ Motion to Dismiss would ordinarily be due on January, 4 2012.
Counsel for Ms. Bolbol respectfully requests that the deadline for Plaintiffs’ Opposition

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to Defendants’ Motion to Dismiss be extended to January 18, 2012, that Defendant, Feld

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Entertainment, Inc., be provided with two weeks to file its Reply by February 1, 2012, and that

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the Hearing on February 14, 2012, be rescheduled for March 6, 2012 at 10:00 a.m., in order to

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provide the Court with adequate time to review the pleadings. Plaintiffs make this request

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because Defendant’s Motion to Dismiss was filed on December 21, 2011, and the period during

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which Plaintiffs have to file their Opposition by January 4, 2012, falls over the December

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holidays and the New Year. Counsel for Ms. Bolbol is short-staffed during this period in

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observance of the December holidays and the New Year, and as a result, filing the Opposition by

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January 4, 2012 would be onerous, burdensome, and prejudicial to Plaintiffs, and an extension

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for the deadline for Plaintiffs’ Opposition and Defendants’ Reply, and an accompanying

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rescheduling of the Hearing, would not prejudice, burden, and/or harm Defendants or the Court.

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In addition, Ms. Bolbol’s counsel is due in court on January 4, 2012, on other matters.

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There have been no previous time modifications either by stipulation or Court order in
this case.
In addition to the extension of time for the Opposition from January 4, 2012 to January
18, 2012, and a rescheduling of the Hearing from February 14, 2012 to March 6, 2012, the
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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME FOR PLAINTIFFS’ TO FILE
OPPOSITION TO DEFENDANTS’ MOTION TO DISMISS

Case No. 5:11-cv-05539 PSG

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requested time modifications would change the date on which Defendant would file a Reply

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from January 11, 2012 to February 1, 2012.

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Based on the foregoing, Plaintiffs and Defendant, Feld Entertainment, Inc., stipulate as
follows:

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Plaintiffs will file their Opposition by 11:59 p.m., Wednesday, January 18, 2012,

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Defendant will file its Reply by 11:59 p.m., Wednesday, February 1, 2012, and Plaintiffs

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respectfully request that the Hearing set for Tuesday, February 14, 2012 at 10:00 a.m. be

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rescheduled for Tuesday, March 6, 2012 at 10:00 a.m.

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IT IS SO STIPULATED.
Dated: January 3, 2012

GONZALEZ & LEIGH, LLP

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By: /s/ G. Whitney Leigh___________
G. Whitney Leigh
Attorney for Plaintiff
DENIZ BOLBOL

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Dated: January 3, 2012

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By:__/s/ Joseph P. Cuviello______________
JOSEPH P. CUVIELLO
In Pro Se

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Dated: January 3, 2012

McMANIS FAULKNER

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By: _/s/ Marwa Elzankaly________________
Marwa Elzankaly
Attorney for Defendant
FELD ENTERTAINMENT, INC., (dba
Ringling Bros. and Barnum & Bailey
Circus)

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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME FOR PLAINTIFFS’ TO FILE
OPPOSITION TO DEFENDANTS’ MOTION TO DISMISS

Case No. 5:11-cv-05539 PSG

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PURSUANT TO THE STIPULATION, IT IS SO ORDERED.

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Dated: _______________________
1/4/2012

_________________________________________
Magistrate Judge Paul S. Grewal
UNITED STATES DISTRICT JUDGE
MAGISTRATE

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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME FOR PLAINTIFFS’ TO FILE
OPPOSITION TO DEFENDANTS’ MOTION TO DISMISS

Case No. 5:11-cv-05539 PSG