Zimmerman v. Starbucks Corporation

Filing 18

ORDER Granting 17 Stipulation to Extend Time. Starbucks Corporation answer due 8/14/2017. Signed by Magistrate Judge George Foley, Jr on 8/1/17. (Copies have been distributed pursuant to the NEF - ADR)

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Case 2:17-cv-00833-GMN-GWF Document 17 Filed 07/31/17 Page 1 of 3 1 2 3 4 5 6 7 8 9 10 Whitney C. Wilcher, Esq. The Wilcher Firm Nevada State Bar No. 7212 8465 West Sahara Avenue Suite 111-236 Las Vegas, NV 89117 Email: wcw@nevadaada.com Attorney for Plaintiff Lynn V. Rivera, Nevada Bar No. 6797 BURNHAM BROWN 200 S. Virginia Street, 8th Floor Reno, Nevada 89501 Telephone: (775) 398-3065 Fax: (877) 648-5288 Email: lrivera@burnhambrown.com Attorneys for Defendant STARBUCKS CORPORATION UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 11 12 Kevin Zimmerman, an individual, 13 No. 17-cv-00833 Plaintiff, STIPULATION TO EXTEND TIME TO RESPOND TO PLAINTIFF’S COMPLAINT; [PROPOSED] ORDER 14 15 16 17 vs. Starbucks Corporation, Defendant. 18 19 20 21 22 23 24 25 26 27 28 1 STIPULATION TO EXTEND TIME TO RESPOND TO PLAINTIFF’S COMPLAINT; [PROPOSED] ORDER No. 17-cv-00833 Case 2:17-cv-00833-GMN-GWF Document 17 Filed 07/31/17 Page 2 of 3 1 Plaintiff KEVIN ZIMMERMAN (“Plaintiff”) and Defendant STARBUCKS 2 CORPORATION (“Defendant”) (collectively, the “Parties”), through their counsel of record, 3 HEREBY STIPULATE and agree that Defendant’s deadline to respond to the Complaint in the 4 instant matter is extended to August 14, 2017. 5 This action is one of seven actions currently pending in this District in which Plaintiff 6 alleges denial of access at a Starbucks store. Those actions are: 17-cv-00976, 17-cv-00833, 17- 7 cv-00596, 17-cv-00834, 17-cv-00312, 17-cv-01201, and 17-cv-01338. 8 9 In each of these seven actions, the Parties are represented by the same counsel, and have maintained a cooperative dialogue. In two of these actions, Defendant previously agreed to 10 waive service of the Complaint, placing Defendant’s responsive pleading deadline at July 17, 11 2017. The Parties then agreed to extend the responsive pleading deadline for all of the 12 remaining cases to that same date. In the interim, Plaintiff made global settlement demands to 13 Defendant, which include these seven actions as well as additional claims which have yet to be 14 filed in court. The Parties’ global settlement discussions are ongoing. 15 The Parties have now agreed to extend the responsive pleading deadline for all seven 16 pending cases to August 14. The Parties believe this extension is appropriate under the 17 circumstances, in order to permit the Parties to continue exploring a good faith, global resolution 18 prior to commencing further litigation to which the Parties and the Court would be required to 19 devote time and resources. Good cause exists for this extension, and the Parties respectfully 20 request that it be approved by the Court. 21 22 23 24 25 26 DATED: July 31, 2017 /s/ Whitney C. Wilcher, Esq. Whitney C. Wilcher, Esq. The Wilcher Firm 8465 West Sahara Avenue Suite 111-236 Las Vegas, NV 89117 702-466-1959 Email: wcw@nevadaada.com Attorney for Plaintiff 27 28 2 STIPULATION TO EXTEND TIME TO RESPOND TO PLAINTIFF’S COMPLAINT; [PROPOSED] ORDER No. 17-cv-00833 Case 2:17-cv-00833-GMN-GWF Document 17 Filed 07/31/17 Page 3 of 3 1 DATED: July 31, 2017 2 BURNHAM BROWN /s/ Lynn V. Rivera Lynn V. Rivera Attorneys for Defendant STARBUCKS CORPORATION 3 4 5 6 7 [PROPOSED] ORDER GRANTING STIPULATION Upon consideration of the Stipulation of Plaintiff KEVIN ZIMMERMAN (“Plaintiff”) 8 and Defendant STARBUCKS CORPORATION (“Defendant”) (collectively, the “Parties”), and 9 good cause appearing, the Court hereby orders as follows: Defendant’s responsive pleading is 10 due on or before August 14, 2017. 11 12 13 IT IS SO ORDERED: 14 15 ___________________________________ UNITED STATES DISTRICT JUDGE STATES MAGISTRATE JUDGE 16 August 1, DATED: _________2017 17 18 4816-9868-4235, v. 1 19 20 21 22 23 24 25 26 27 28 3 STIPULATION TO EXTEND TIME TO RESPOND TO PLAINTIFF’S COMPLAINT; [PROPOSED] ORDER No. 17-cv-00833

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