Filed: May 08, 2019
Latest Update: May 08, 2019
Summary: STIPULATION TO MODIFY SCHEDULING ORDER [DKT. NO. 37]; [PROPOSED] ORDER THEREON JENNIFER L. THURSTON , Magistrate Judge . RECITALS 1. WHEREAS, on December 13, 2018, this Court issued its Scheduling Order [Dkt. No. 37] setting the deadline to amend pleadings as May 17, 2019; 2. WHEREAS, the Plaintiff is evaluating the need to file a motion to amend her Second Amended Complaint but feels the need to depose particular witnesses before determining whether filing a Third Amended Complaint
Summary: STIPULATION TO MODIFY SCHEDULING ORDER [DKT. NO. 37]; [PROPOSED] ORDER THEREON JENNIFER L. THURSTON , Magistrate Judge . RECITALS 1. WHEREAS, on December 13, 2018, this Court issued its Scheduling Order [Dkt. No. 37] setting the deadline to amend pleadings as May 17, 2019; 2. WHEREAS, the Plaintiff is evaluating the need to file a motion to amend her Second Amended Complaint but feels the need to depose particular witnesses before determining whether filing a Third Amended Complaint ..
More
STIPULATION TO MODIFY SCHEDULING ORDER [DKT. NO. 37]; [PROPOSED] ORDER THEREON
JENNIFER L. THURSTON, Magistrate Judge.
RECITALS
1. WHEREAS, on December 13, 2018, this Court issued its Scheduling Order [Dkt. No. 37] setting the deadline to amend pleadings as May 17, 2019;
2. WHEREAS, the Plaintiff is evaluating the need to file a motion to amend her Second Amended Complaint but feels the need to depose particular witnesses before determining whether filing a Third Amended Complaint is warranted;
3. WHEREAS, Defense Counsel is unavailable to attend depositions in this matter during the entire month of April and first week of May as: (1) they have four major oppositions to motions, including motions for summary judgment, due on May 6, 2019, in the United States District Court, Southern District of New York, case of Twelve Sixty LLC, et al. v. Extreme Music Library Limited, et al., Case No. 1:17-CV-01479-PAC, the preparation of which is extensive and involves complex issues including motions to exclude key witnesses; and (2) they begin a one to two week trial on April 29, 2019, in the case of Valderrama, et al. v. Beautologie Cosmetic Surgery Inc., et al., Kern County Superior Court Case No. BCV-17-101520.
4. WHEREAS, due to Defense Counsel's unavailability as set forth above, Defendants have agreed to allow Plaintiff additional time to determine whether or not she wants to seek leave to file a Third Amended Complaint so that she may take depositions she feels are necessary to do complete such analysis;
5. WHEREAS, the Parties hereto agree that the deadline to amend pleadings be extended to June 17, 2019.
6. WHEREAS, the requested extension will not affect the trial date of September 14, 2020, or any of the dates related thereto.
STIPULATION
IT IS HEREBY STIPULATED by and between the Parties hereto through their respect attorneys of record that the deadline to amend pleadings be extended to June 17, 2019.
Dated: May 7, 2019. LAW OFFICE OF ALFRED R. HERNANDEZ
/s/Alfred R. Hernandez
By:________________________________
Alfred R. Hernandez,
Attorneys for Plaintiff
Dated: May 7, 2019. MARDEROSIAN & COHEN
/s/Michael G. Marderosian
By:________________________________
Michael G. Marderosian,
Attorneys for Defendants
above-named.
ORDER
Based upon the stipulation of the parties, the Court ORDERS:
1. The scheduling order is amended to extend the deadline by which stipulations to amend or motions to amend the pleadings to June 17, 2019.
IT IS SO ORDERED.
