Shaw v. Con-Lee Restaurants, Inc et al

Filing 6

ORDER GRANTING 5 Stipulation to Extend Time To Respond To Initial Complaint filed by Con-Lee Restaurants, Inc. Response due 8/15/2013. Signed by Judge Edward J. Davila on 7/29/2013. (ecg, COURT STAFF) (Filed on 7/29/2013)

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Attorneys for Defendant
CON-LEE RESTAURANTS, INC. (Erroneously sued herein
as CON-LEE RESTAURANTS, INC., aka CON MAC
RESTAURANTS, INC. dba MCDONALD'S
RESTAURANTS aka MCDONALD'S #620)

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Cathy L. Arias, State Bar No. 141989
Brendan M. Brownfield, State Bar No. 266114
BURNHAM BROWN
A Professional Law Corporation
P.O. Box 119
Oakland, California 94604
--1901 Harrison Street, 14th Floor
Oakland, California 94612
Telephone:
[phone]
Facsimile:
[phone]
E-mail: [e-mail]
[e-mail]

rd J . D a

vila

R NIA

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Attorney for Plaintiff
CECIL SHAW

FO

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Tanya E. Moore, State Bar No. 206683
MOORE LAW FIRM, P.C.
332 North Second Street
San Jose, California 95112
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]

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D IS T IC T O
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7/29/2013

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
CECIL SHAW,
Plaintiff,
v.
CON-LEE RESTAURANTS, INC., aka CON
MAC RESTAURANTS, INC. dba
MCDONALD’S RESTAURANTS aka
MCDONALD’S #620; HENRY S. NIGRO,
Trustee of the NIGRO FAMILY TRUST
DATED February 28, 2013; LUCINDA R.
HENDERSON-NIGRO, Trustee of the
NIGRO FAMILY TRUST DATED February
28, 2013; ANDREA M. TOM, Co-Trustee of
the Andrea M. Tom Living Trust dated June
14, 2004; T. RAYMOND TOM, Co-Trustee
of The Andrea M. Tom Living Trust dated
June 14, 2004; ROSE TOM, Co-Trustee of
The Andrea M. Tom Living Trust dated June

No. 13-cv-02633 EJD
STIPULATION TO EXTEND TIME TO
RESPOND TO INITIAL COMPLAINT
(Local Rule 6-1)
Complaint Served: July 11, 2013
Current Response Date: August 1, 2013
New Response Date: August 15, 2013
Complaint Filed: June 7, 2013

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STIPULATION TO EXTEND TIME TO RESPOND TO INITIAL COMPLAINT

No. 13-cv-02633 PSG

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14, 2004; ALAN L. T. JOE, Trustee of the
ALAN L. T. JOE and VIRGINIA KIT-YEE
JOE REVOCABLE TRUST, dated October
4, 1994; VIRGINIA KIT-YEE JOE, Trustee
of the ALAN L. T. JOE and VIRGINIA KITYEE JOE REVOCABLE TRUST; FRANCIS
LEE and ANITA LEE, Husband and Wife as
Community Property; FORREST J.
CIOPPPA LIVING TRUST U/A dated March
31, 1987; YUNG FENG, Trustee of the
FENG FAMILY TRUST dated August 3,
1984; RONY Y. FENG, Trustee of the
FENG FAMILY TRUST dated August 3,
1984; TIMMY KIN CHUNG YUNG, CoTrustee of the “YUNG FAMILY 1992
TRUST” dated August 4, 1992; ALICE ARLAI YUNG in Trust, Co-Trustee of the
“YUNG FAMILY 1992 TRUST” dated
August 4, 1992,
Defendants.

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Plaintiff CECIL SHAW (“Plaintiff”) and Defendant CON-LEE RESTAURANTS, INC.

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(Erroneously sued herein as CON-LEE RESTAURANTS, INC., aka CON MAC

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RESTAURANTS, INC. dba MCDONALD'S RESTAURANTS aka MCDONALD'S #620)

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(“Defendant”), through their counsel of record, HEREBY STIPULATE and agree that

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Defendant’s time to answer or otherwise plead and respond to Plaintiff’s complaint shall be

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extended to August 15, 2013.

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Defendant’s answer or responsive pleading is presently due on August 1, 2013, and the

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parties have agreed upon an extension to August 15, 2013. No hearings, conferences, or other

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deadlines have yet been set by the Court.

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Good cause exists to extend Defendant’s time to answer or otherwise respond to

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Plaintiff’s complaint. The parties are in agreement that this extension is appropriate in order to

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afford Defendant the opportunity to investigate the allegations of the complaint and potentially

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permit the parties to commence early settlement negotiations. This stipulation represents the

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parties’ first agreement to extend Defendant’s response deadline.

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STIPULATION TO EXTEND TIME TO RESPOND TO INITIAL COMPLAINT

No. 13-cv-02633 PSG

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Plaintiff’s counsel has authorized the filing of this stipulation with her electronic

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signature.

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DATED: July 26, 2013

MOORE LAW FIRM, P.C.

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/s/ Tanya E. Moore
TANYA E. MOORE
Attorneys for Plaintiff
CECIL SHAW

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DATED: July 26, 2013

BURNHAM BROWN

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/s/ Brendan M. Brownfield
BRENDAN M. BROWNFIELD
Attorneys for Defendant CON-LEE
RESTAURANTS, INC. (Erroneously sued herein
as CON-LEE RESTAURANTS, INC., aka CON
MAC RESTAURANTS, INC. dba MCDONALD'S
RESTAURANTS aka MCDONALD'S #620)

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4823-3290-2165, v. 1

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STIPULATION TO EXTEND TIME TO RESPOND TO INITIAL COMPLAINT

No. 13-cv-02633 PSG