Zimmerman v. Starbucks Corporation

Filing 11

ORDER Granting 10 Stipulation to Extend Time. Starbucks Corporation answer due 7/31/2017. Signed by Magistrate Judge George Foley, Jr on 7/11/17. (Copies have been distributed pursuant to the NEF - ADR)

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Whitney C. Wilcher, Esq.
The Wilcher Firm
Nevada State Bar No. 7212
8465 West Sahara Avenue Suite 111-236
Las Vegas, NV 89117
Email: [e-mail]
Attorney for Plaintiff
Lynn V. Rivera, Nevada Bar No. 6797
BURNHAM BROWN
200 S. Virginia Street, 8th Floor
Reno, Nevada 89501
Telephone:
[phone]
Fax:
[phone]
Email: [e-mail]
Attorneys for Defendant
STARBUCKS CORPORATION
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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No. 17-cv-01338 -GMN-GWF

Kevin Zimmerman, an individual,

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Plaintiff,

STIPULATION TO EXTEND TIME TO
RESPOND TO PLAINTIFF’S
COMPLAINT; [PROPOSED] ORDER

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vs.
Starbucks Corporation,
Defendant.

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STIPULATION TO EXTEND TIME TO RESPOND TO PLAINTIFF’S COMPLAINT;
[PROPOSED] ORDER

No. 17-cv-01338

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Plaintiff KEVIN ZIMMERMAN (“Plaintiff”) and Defendant STARBUCKS

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CORPORATION (“Defendant”) (collectively, the “Parties”), through their counsel of record,

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HEREBY STIPULATE and agree that Defendant’s deadline to respond to the Complaint in the

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instant matter is extended to July 31, 2017.

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This action is one of seven actions currently pending in this District in which Plaintiff

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alleges denial of access at a Starbucks store. Those actions are: 17-cv-00976, 17-cv-00833, 17-

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cv-00596, 17-cv-00834, 17-cv-00312, 17-cv-01201, and 17-cv-01338.

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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

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waive service of the Complaint, placing Defendant’s responsive pleading deadline at July 17,

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2017. The Parties then agreed to extend the responsive pleading deadline for all of the

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remaining cases to that same date. In the interim, Plaintiff made global settlement demands to

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Defendant, which include these seven actions as well as additional claims which have yet to be

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filed in court. The Parties’ global settlement discussions are ongoing.

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The Parties have now agreed to extend the responsive pleading deadline for all seven

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pending cases to July 31. The Parties believe this extension is appropriate under the

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circumstances, in order to permit the Parties to continue exploring a good faith, global resolution

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prior to commencing further litigation to which the Parties and the Court would be required to

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devote time and resources. Good cause exists for this extension, and the Parties respectfully

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request that it be approved by the Court.

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DATED: July 7, 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: [e-mail]
Attorney for Plaintiff

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STIPULATION TO EXTEND TIME TO RESPOND TO PLAINTIFF’S COMPLAINT;
[PROPOSED] ORDER

No. 17-cv-01338

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DATED: July 7, 2017

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BURNHAM BROWN
/s/ Lynn V. Rivera
Lynn V. Rivera
Attorneys for Defendant
STARBUCKS CORPORATION

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[PROPOSED] ORDER GRANTING STIPULATION
Upon consideration of the Stipulation of Plaintiff KEVIN ZIMMERMAN (“Plaintiff”)

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and Defendant STARBUCKS CORPORATION (“Defendant”) (collectively, the “Parties”), and

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good cause appearing, the Court hereby orders as follows: Defendant’s responsive pleading is

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due on or before July 31, 2017.

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IT IS SO ORDERED:

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_______________________________________
UNITED STATES DISTRICT JUDGE
UNITED STATES MAGISTRATE JUDGE
DATED: _______________________
DATED: July 11, 2017

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4821-3895-5083, v. 1

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STIPULATION TO EXTEND TIME TO RESPOND TO PLAINTIFF’S COMPLAINT;
[PROPOSED] ORDER

No. 17-cv-01338