Sawatsky v. Carl's Jr. Restaurants, LLC et al

Filing 17

ORDER APPROVING 16 STIPULATION AND REQUEST BY THE PARTIES FOR AN ORDER MODIFYING GENERAL ORDER 56 TO EXTEND THE DEADLINE FOR THE PARTIES' JOINT SITE INSPECTION. Signed by Judge Beth Labson Freeman on 9/25/2015. (blflc1S, COURT STAFF) (Filed on 9/25/2015)

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LAW OFFICE OF IRENE KARBELASHVILI
Irene Karbelashvili, State Bar Number 232223
Irakli Karbelashvili, State Bar Number 302971
12 South First Street, Suite 413
San Jose, CA 95113
Telephone: [phone]
Fax: [phone]

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Attorneys for JULYA SAWATSKY, Plaintiff

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA

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JULYA SAWATSKY,
Plaintiff,

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vs.

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CARL’S JR. RESTAURANTS LLC, a
Delaware limited liability company, d/b/a
CARL’S JR.; HERMAN FOFADO, an
individual, d/b/a CARL’S JR.; MIGUEL
JARA, an individual, a/k/a MIGUEL E.
JARA, JR.; and DOES 1-10, inclusive,
Defendants.

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Case No. 5:15-CV-2621 BLF
Civil Rights
STIPULATION AND REQUEST
BY THE PARTIES FOR AN
ORDER MODIFYING GENERAL
ORDER 56 TO EXTEND THE
DEADLINE FOR THE PARTIES’
JOINT SITE INSPECTION; AND
[PROPOSED] ORDER THEREON

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IT IS HEREBY STIPULATED by and between Plaintiff JULYA SAWATSKY

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(“Plaintiff”) and Defendant CARL’S JR. RESTAURANTS, LLC (“Defendant”) that the deadline

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for a joint inspection be continued to, but no later than, November 15, 2015.

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Pursuant to General Order 56, Plaintiff served Defendant within the required 63 day
time period. Defendant filed its answer on July 13, 2015. To accommodate the parties and
their respective counsel’s schedules, the parties request leave to extend the deadline for the
joint inspection to no later than November 15, 2015 and all subsequent deadlines of General
Order 56 to be modified accordingly.

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Case No. 5:15-CV-2621 BLF

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The parties are hopeful that the joint inspection will assist them in resolving the issue
of injunctive relief.

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Date: September 22, 2015

By /s/ James R. Hawley
James R. Hawley, Attorney for Defendant
CARL’S JR. RESTAURANTS LLC

Dated: September 18, 2015

By /s/ Irene Karbelashvili
Irene Karbelashvili, Attorney for Plaintiff
RICHARD C. HENNING

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FILER’S ATTESTATION

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Pursuant to Local Rule 5-1, I hereby attest that on September 22, 2015, I, Irene
Karbelashvili, received the concurrence of James R. Hawley, Esq. in the filing of this document

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By:

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/s/ Irene Karbelashvili
IRENE KARBELASHVILI

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Case No. 5:15-CV-2621 BLF

[PROPOSED] ORDER

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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED:
That the deadline for conducting the joint inspection under General Order 56 is modified

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so that the deadline is extended to no later than November 15, 2015 and all subsequent deadlines

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of General Order 56 to be modified accordingly.

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IT IS SO ORDERED
Dated: September ___, 2015

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______________________________
Hon. Beth Labson Freeman
United States District Judge

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Case No. 5:15-CV-2621 BLF