Filed: Oct. 20, 2014
Latest Update: Oct. 20, 2014
Summary: STIPULATION AND [PROPOSED] ORDER ENLARGING TIME FOR DISCOVERY CONFERENCE AND INITIAL DISCLOSURES, INITIAL CASE MANAGEMENT CONFERENCE PURSUANT TO LOCAL RULE 6-2, AND BRIEFING SCHEDULE FOR MOTIONS TO DISMISS THE COMPLAINT VINCE CHHABRIA, District Judge. WHEREAS Plaintiff Pick-N-Pull Auto Dismantlers ("Plaintiff") and Defendants Alco Iron & Metal Co., Cesar Zamora, Ricardo Zamora, and Emilio Zamora (together, "Defendants," and collectively with Plaintiff, the "Parties") have stipulated to t
Summary: STIPULATION AND [PROPOSED] ORDER ENLARGING TIME FOR DISCOVERY CONFERENCE AND INITIAL DISCLOSURES, INITIAL CASE MANAGEMENT CONFERENCE PURSUANT TO LOCAL RULE 6-2, AND BRIEFING SCHEDULE FOR MOTIONS TO DISMISS THE COMPLAINT VINCE CHHABRIA, District Judge. WHEREAS Plaintiff Pick-N-Pull Auto Dismantlers ("Plaintiff") and Defendants Alco Iron & Metal Co., Cesar Zamora, Ricardo Zamora, and Emilio Zamora (together, "Defendants," and collectively with Plaintiff, the "Parties") have stipulated to th..
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STIPULATION AND [PROPOSED] ORDER ENLARGING TIME FOR DISCOVERY CONFERENCE AND INITIAL DISCLOSURES, INITIAL CASE MANAGEMENT CONFERENCE PURSUANT TO LOCAL RULE 6-2, AND BRIEFING SCHEDULE FOR MOTIONS TO DISMISS THE COMPLAINT
VINCE CHHABRIA, District Judge.
WHEREAS Plaintiff Pick-N-Pull Auto Dismantlers ("Plaintiff") and Defendants Alco Iron & Metal Co., Cesar Zamora, Ricardo Zamora, and Emilio Zamora (together, "Defendants," and collectively with Plaintiff, the "Parties") have stipulated to three prior extensions of time, whereby each of the following deadlines was extended: (1) Defendants' time to answer or otherwise respond to the Complaint [Dkt. 14]; (2) the deadlines for the Federal Rule of Civil Procedure 26 discovery conference and initial disclosures, and the initial case management conference (the "Rule 26 Deadlines") [Dkt. 27]; and (3) the briefing schedule for Defendants' pending Motions to Dismiss Pursuant to Federal Rule of Civil Procedure 12(b)(6) ("Motions to Dismiss") [Dkt. 29];
WHEREAS the Parties participated in a mediation on October 7, 2014;
WHEREAS the Parties have reached a negotiated resolution of this dispute;
WHEREAS the Parties are in the process of documenting that resolution;
WHEREAS the Parties contemplate that this case will be dismissed shortly after the execution of a final settlement agreement;
WHEREAS, in light of the anticipated dismissal of this case, Plaintiff and Defendants desire to extend the Rule 26 Deadlines and the briefing schedule for the Motions to Dismiss;
IT IS HEREBY STIPULATED and agreed to, by and among the undersigned, on behalf of their respective clients, to enlarge the time regarding the Rule 26 Deadlines and the briefing schedule for the Motions to Dismiss such that each deadline and event will be extended by six weeks.
The stipulated dates are as follows:
December 2, 2014 Last Day to:
(1) Meet and confer re: initial disclosures, early
settlement, ADS process selection, and discovery
plan;
(2) File ADR Certification signed by Parties and Counsel
(3) File either Stipulation to ADR Process or Notice
Need for ADR Phone Conference
December 8, 2014 Last day to file response brief to the Motions to Dismiss.
December 18, 2014 Last day to file reply briefs in support of the Motions to
Dismiss.
December 23, 2014 Last day to file Rule 26(f) Report, complete initial
disclosures or state objection in Rule 26(f) Report and file
Case Management Statement per Court's standing order re:
Contents of Joint Case Management Statement
December 30, 2014 Initial Case Management Conference in Courtroom 4, 17th
Floor at 10:00 a.m.
January 8, 2014 Hearing on Motions to Dismiss. Note that this date has been
extended by seven weeks, as a six week extension would
cause the hearing to be scheduled for January 1, 2015.]
IT IS SO STIPULATED AND AGREED.
FILER'S ATTESTATION PURSUANT TO CIVIL LOCAL RULE 5-1(i)(3)
I, Charmaine G. Yu, attest that concurrence in the filing of this STIPULATION AND [PROPOSED] ORDER ENLARGING TIME FOR DISCOVERY CONFERENCE AND INITIAL DISCLOSURES, AND INITIAL CASE MANAGEMENT CONFERENCE PURSUANT TO LOCAL RULE 6-2 has been obtained from each of the other signatories.
Executed this 15th of October, 2014, at San Francisco, California.
[PROPOSED] ORDER
PURSUANT TO THE STIPULATION, IT IS SO ORDERED.
