Marroquin v. Ashron Construction & Restoration, Inc et al

Filing 35

STIPULATION AND ORDER re 34 to Continue Fact Discovery Cutoff. Fact Discovery Cutoff is 3/14/2014. Signed by Magistrate Judge Howard R. Lloyd on 2/5/2014. (hrllc1, COURT STAFF) (Filed on 2/5/2014)

1
2
3
4

*E-Filed: February 5, 2014*
Dawna J. Cilluffo [231219]
Chelsea K. Dunton [288742]
DC Law, Dawna J. Cilluffo, A Professional Corporation
2005 De La Cruz Boulevard, Suite 215
Santa Clara, California 95050
Tel: [phone]
Fax: [phone]

5
6
7

Attorneys for Defendants,
Ashron Construction & Restoration, Inc.,
Ezra Cohen, and U.S. Specialty Insurance Company

8
9

IN THE UNITED STATES DISTRICT COURT

10

FOR THE NORTHERN DISTRICT OF CALIFORNIA

11

SAN JOSE DIVISION

12
13
14
15
16
17
18

CESAR GONZALEZ MARROQUIN and
VINCENT DE LA TORRE,

)
)
)
Plaintiffs,
)
)
v.
)
)
ASHRON CONSTRUCTION &
)
RESTORATION, INC.: EZRA COHEN; and )
U.S. SPECIALTY INSURANCE COMPANY, )
)
Defendants.
)
)

19
20

Case No.: C13-00421 HRL
STIPULATION AND [PROPOSED]
ORDER TO CONTINUE FACT
DISCOVERY CUTOFF

RECITALS
CESAR GONZALEZ MARROQUIN, VINCENT DE LA TORRE, ASHRON

21

CONSTRUCTION & RESTORATION, INC., EZRA COHEN, and U.S. SPECIALTY

22

INSURANCE COMPANY, (collectively referred to herein as the “Parties”) hereby stipulate,

23

through counsel, as follows:

24
25
26
27
28

Whereas, the Parties participated in a half day mediation session with Claire Cormier,
Esq. as planned on January 9, 2014.
Whereas, the Parties wish to schedule an additional mediation session with Ms. Cormier
in late February, 2014.
Whereas, fact discovery cutoff in this matter is currently February 5, 2014;
1
STIPULATION AND [PROPOSED] ORDER TO CONTINUE FACT DISCOVERY CUTOFF

1

Whereas the final Pretrial Conference is set for April 17, 2014.

2

Whereas, in order to allow time for the Parties to gather additional information and

3

documents to ensure a successful second session of mediation, and in order for said mediation

4

session to be completed prior to the fact discovery cutoff, and to allow the Parties to complete

5

necessary discovery and trial preparations should the additional mediation session fail to resolve

6

this matter, the Parties hereby stipulate as follows:
STIPULATION

7
1.

8

time after the second mediation session to complete any additional discovery as

9

necessary.

10

SO STIPULATED.

11
12

To continue the fact discovery cutoff until March 14, 2014, to allow adequate

Dated: January 31, 2014

DC LAW

13
14

By:

/s/ Chelsea K. Dunton
DAWNA J. CILLUFFO
CHELSEA K. DUNTON
Attorneys for Defendants, Ashron Construction &
Restoration, Inc., Ezra Cohen, and U.S. Specialty
Insurance Company

15
16
17
18

Dated: January 31, 2014

JUSTICE AT WORK LAW GROUP

19
By:

/s/ Tomas Margain
TOMAS MARGAIN
PHUNG TRUONG
Attorneys for Plaintiffs, Cesar Gonzalez Marroquin
and Vincent De La Torre

20
21
22
23

///

24

///

25

///

26

///

27

///

28

///

2
STIPULATION AND [PROPOSED] ORDER TO CONTINUE FACT DISCOVERY CUTOFF

ORDER

1
2
3
4
5
6

Based upon the Stipulation of the Parties, and good cause appearing therefore, IT IS
HEREBY ORDERED THAT:
1. The current fact discovery cutoff date of February 5, 2014 is hereby continued to
March 14
___________________, 2014;
IT IS SO ORDERED.

7
8

February 5, 2014
Dated: ______________________

9
10

___________________________________________
HOWARD R. LLOYD
United States Magistrate Judge

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

3
STIPULATION AND [PROPOSED] ORDER TO CONTINUE FACT DISCOVERY CUTOFF