Filed: Aug. 26, 2019
Latest Update: Aug. 26, 2019
Summary: JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE PLAINTIFF/CROSS-DEFENDANTS' MOTION TO COMPEL JOHN MARSHALL'S COMPLIANCE WITH DEPOSITION SUBPOENA AND REQUESTS FOR PRODUCTION CAROLYN K. DELANEY , Magistrate Judge . IT IS HEREBY STIPULATED AND AGREED, between Plaintiff/Cross-Defendant PEO Experts CA, Inc., dba Bixby Zane Insurance Services ("Plaintiff"); Defendants/Cross-Complainants Michael Craig Engstrom; Christopher Ignazio Longo; Ryan Wakefield; Jennifer Engstrom; Michael Engstrom
Summary: JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE PLAINTIFF/CROSS-DEFENDANTS' MOTION TO COMPEL JOHN MARSHALL'S COMPLIANCE WITH DEPOSITION SUBPOENA AND REQUESTS FOR PRODUCTION CAROLYN K. DELANEY , Magistrate Judge . IT IS HEREBY STIPULATED AND AGREED, between Plaintiff/Cross-Defendant PEO Experts CA, Inc., dba Bixby Zane Insurance Services ("Plaintiff"); Defendants/Cross-Complainants Michael Craig Engstrom; Christopher Ignazio Longo; Ryan Wakefield; Jennifer Engstrom; Michael Engstrom,..
More
JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE PLAINTIFF/CROSS-DEFENDANTS' MOTION TO COMPEL JOHN MARSHALL'S COMPLIANCE WITH DEPOSITION SUBPOENA AND REQUESTS FOR PRODUCTION
CAROLYN K. DELANEY, Magistrate Judge.
IT IS HEREBY STIPULATED AND AGREED, between Plaintiff/Cross-Defendant PEO Experts CA, Inc., dba Bixby Zane Insurance Services ("Plaintiff"); Defendants/Cross-Complainants Michael Craig Engstrom; Christopher Ignazio Longo; Ryan Wakefield; Jennifer Engstrom; Michael Engstrom, Inc.; B&C LOC, Inc.; PEO Advisors of CA, Inc.; and Freedom Risk Insurance Services, and third party John Marshall, by and through their counsel of record, to continue Plaintiff's Motion to Compel John Marshall's Compliance with Deposition Subpoena and Requests for Production.
WHEREAS, on August 7, 2019, Plaintiff filed a Notice of Motion and Motion to Compel John Marshall's Compliance with Subpoena for Deposition and Production of Documents (ECF No. 124);
WHEREAS, on August 19, 2019, Plaintiff's counsel was informed by counsel for John Marshall, Suzanne M. Alves, that Ms. Alves is unavailable to comply with the Court's joint statement deadline and appear for the hearing currently scheduled for August 28, 2019, due to a family emergency that will impact her schedule over the next week;
WHEREAS, the parties have agreed to continue the hearing on this matter by two weeks, from August 28, to September 11, 2019; and
WHEREAS, good cause exists for granting this request to continue the hearing past the current discovery deadline of August 30, 2019, because the parties have met and conferred in good faith to resolve the issues raised with regard to Mr. Marshall's subpoenaed deposition and requests for production of documents, and but for Ms. Alves' family emergency, the parties and Mr. Marshall would have been prepared for the hearing as currently scheduled.
NOW THEREFORE, the Parties respectfully request that the Court continue the hearing for Plaintiff's Motion and Motion to Compel John Marshall's Compliance with Subpoena for Deposition and Production of Documents to September 11, 2019.
IT IS SO STIPULATED.
Dated: August 21, 2019 FISHER & PHILLIPS LLP
By: /s/ Natalie B. Fujikawa
Alden J. Parker
William R.H. Mosher
Natalie B. Fujikawa
Attorneys for Plaintiff and Cross-Defendants
PEO Experts CA, Inc., dba Bixby Zane Insurance
Services; Bixby Zane, Inc.; Jason Crawford; Brad
Worley; Workforce Business Services, Inc., Workforce
Business Services CA, LLC; and Robert Kelly
Dated: August 21, 2019 PARKER LAW GROUP
By: /s/ Myles G. Taylor
Port J. Parker
Myles G. Taylor
Attorneys for Defendants and Cross-Complainants
Michael C. Engstrom, Christopher I. Longo, Jennifer
Engstrom, Michael Engstrom, Inc., B&C LOC, Inc.,
and PEO Advisors of CA, Inc.
Dated: August 21, 2019 SMITH, MCDOWELL & POWELL, A Law Corp.
By: /s/C. Jason Smith
C. Jason Smith
Attorneys for Defendants and Cross-Complainants
Ryan Wakefield and Freedom Risk Insurance Services
Dated: August 21, 2019 ALVES RADCLIFFE LLP
By: /s/ Suzanne M. Alves
Suzanne M. Alves
Attorneys for John Marshall
PURSUANT TO STIPULATION, IT IS SO ORDERED.
