Filed: Jun. 14, 2019
Latest Update: Jun. 14, 2019
Summary: STIPULATION AND [PROPOSED] ORDER REGARDING RESPONSIVE PLEADING DEADLINE AND PRELIMINARY INJUNCTION HEARING HAYWOOD S. GILLIAM, JR. , District Judge . Plaintiff Niral Patel ("Plaintiff") and defendant Double AA Corporation ("Defendant") (collectively, the "Parties"), by and through their respective counsel of record, hereby stipulate and agree as follows: WHEREAS, Plaintiff filed his Complaint on May 14, 2019 and served it on Defendant on May 21, 2019, making Defendant's responsive pl
Summary: STIPULATION AND [PROPOSED] ORDER REGARDING RESPONSIVE PLEADING DEADLINE AND PRELIMINARY INJUNCTION HEARING HAYWOOD S. GILLIAM, JR. , District Judge . Plaintiff Niral Patel ("Plaintiff") and defendant Double AA Corporation ("Defendant") (collectively, the "Parties"), by and through their respective counsel of record, hereby stipulate and agree as follows: WHEREAS, Plaintiff filed his Complaint on May 14, 2019 and served it on Defendant on May 21, 2019, making Defendant's responsive ple..
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STIPULATION AND [PROPOSED] ORDER REGARDING RESPONSIVE PLEADING DEADLINE AND PRELIMINARY INJUNCTION HEARING
HAYWOOD S. GILLIAM, JR., District Judge.
Plaintiff Niral Patel ("Plaintiff") and defendant Double AA Corporation ("Defendant") (collectively, the "Parties"), by and through their respective counsel of record, hereby stipulate and agree as follows:
WHEREAS, Plaintiff filed his Complaint on May 14, 2019 and served it on Defendant on May 21, 2019, making Defendant's responsive pleading currently due June 11, 2019.
WHEREAS, Plaintiff filed an Application for Preliminary Injunction on May 31, 2019 and the hearing on Plaintiff's Application for Preliminary Injunction is currently set for July 8, 2019 at 9:30 am in this Court.
WHEREAS, the Parties have agreed to mediate this matter and to the following schedule for the filing of Defendant's responsive pleading and briefing and hearing for the Preliminary Injunction:
1. Defendant's responsive pleading is due on September 16, 2019;
2. The Parties request that Court set the hearing for Plaintiff's Application for Preliminary Injunction on, or after, October 1, 2019, but not the week of October 14, 2019, to allow the Parties time to mediate this matter;
3. Defendant's response to Plaintiff's Application for Preliminary Injunction will be due 30 days prior to the date set by the Court for the hearing on Plaintiff's Application for Preliminary Injunction; and
4. Plaintiff's reply for Plaintiff's Application for Preliminary Injunction will be due 15 days prior to the date set by the Court for the hearing on Plaintiff's Application for Preliminary Injunction.
WHEREAS, Defendant agrees to not take any action against Plaintiff and to maintain the status quo pending the outcome of the mediation and, if necessary, the Court's ruling on Plaintiff's Application for Preliminary Injunction.
NOW, THEREFORE, IT IS HEREBY STIPULATED between the Parties, by and through their respective attorneys of records, that the dates and deadlines listed above be set by the Court.
IT IS SO STIPULATED.
Dated: June 10, 2019 STEYER LOWENTHAL BOODROOKAS
ALVAREZ & SMITH LLP
By: /s/ Jeffrey H. Lowenthal
Jeffrey H. Lowenthal
Dana M. Andreoli
Cody T. Stroman
Attorneys for Defendant
Double AA Corporation
Dated: June 10, 2019 LAGARIAS, NAPELL & DILLON, LLP
By: /s/Peter C. Lagarias
Peter C. Lagarias
Bruce J. Napell
Attorneys for Plaintiff
Niral Patel
Attestation
Pursuant to Northern District L.R. 5-1(i)(3) regarding signatures, I hereby attest that concurrence in the filing of this document has been obtained from each of the other signatories. I declare under penalty of perjury under the laws of the United States of American that the foregoing is true and correct.
Dated: June 10, 2019 STEYER LOWENTHAL BOODROOKAS
ALVAREZ & SMITH LLP
By: /s/ Jeffrey H. Lowenthal
Jeffrey H. Lowenthal
Dana M. Andreoli
Cody T. Stroman
Attorneys for Defendant
Double AA Corporation
ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED, that the following dates and deadlines be set in regards to Defendant's responsive pleading and Plaintiff's Application for Preliminary Injunction:
1. Defendant's responsive pleading is due on September 16, 2019;
2. The hearing on Plaintiff's Application for Preliminary Injunction shall be held on October 24, 2019 at 2:00 p.m.;
3. Defendant's response to Plaintiff's Application for Preliminary Injunction is due 30 days prior to the date set by the Court for the hearing on Plaintiff's Application for Preliminary Injunction; and
4. Plaintiff's reply for Plaintiff's Application for Preliminary Injunction will is due 15 days prior to the date set by the Court for the hearing on Plaintiff's Application for Preliminary Injunction.
5. As stipulated by the parties, Defendant agrees to not take any action against Plaintiff and to maintain the status quo pending the outcome of the mediation and, if necessary, the Court's ruling on Plaintiff's Application for Preliminary Injunction.
IT IS SO ORDERED.
