Losorwith v. Country Fare Cafe, Inc., et al.
Filing
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SECOND JOINT STIPULATION for ORDER to Continue Time for Defendants to Respond to Complaint; ORDER Theron Signed by Judge Oliver W. Wanger on 6/16/2011. (Defendants have up to and including 8/12/2011 to serve and file their response to the Complaint.)(Gaumnitz, R)
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JONES HELSLEY PC
265 E. River Park Circle, Suite 310
P.O. Box 28340
Fresno, California 93729
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Telephone: (559) 233-4800
Facsimile: (559) 233-9330
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Michael S. Helsley #199103
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Attorneys for:
Defendants, COUNTRY FARE CAFÉ, INC.,
JOSE VALADEZ, TERESA VALADEZ
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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KELLI LOSORWITH,
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Plaintiff,
v.
Case No. 1:11-CV-00350-OWW-GSA
SECOND JOINT STIPULATION FOR
ORDER TO CONTINUE TIME FOR
DEFENDANTS TO RESPOND TO
COMPLAINT; ORDER THEREON
COUNTRY FARE CAFÉ, INC., JOSE
VALADEZ, TERESA VALADEZ
Defendant(s).
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1.
On or about March 14, 2011, Plaintiff, KELLI LOSORWITH (“Plaintiff”)
served her Complaint on Defendants, COUNTRY FARE CAFÉ, INC., JOSE VALADEZ,
TERESA VALADEZ (“Defendants”) making the response to the Complaint due on or before
April 12, 2011.
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Thereafter, Defendants hired a Certified Access Specialist to inspect and
to prepare a CASp report on the property at issue.
Counsel for Defendants requested an
additional 60-day extension of time to respond to the Complaint and to continue the Mandatory
Scheduling Conference for 60 days to permit Defendants to make the necessary modifications to
bring the property at issue into compliance with the ADA accessibility regulations and to permit
the parties to negotiate a settlement of the case. Plaintiff’s counsel agreed to permit Defendants
to serve and file its response to the Complaint on or before June 13, 2011.
{7125/002/00268745.DOC}
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____________________________________________________________________________________________________
SECOND JOINT STIPULATION FOR ORDER TO CONTINUE TIME FOR DEFENDANTS TO RESPOND TO COMPLAINT;
ORDER THEREON
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On April 13, 2011, this Court granted the parties request to extend the
time for Defendants to respond to Plaintiff’s Complaint.
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Since the April 13, 2011, Order, Defendants have completed the CASp
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inspection and have provided to Plaintiff a copy of the CASp report. In addition, Plaintiff is in
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the process of preparing a proposed settlement to Defendants for their review.
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Plaintiff’s counsel agrees to permit Defendants to serve and file their response to the Complaint
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on or before August 12, 2011.
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As such,
Good cause exists for the extension of time to respond to the Complaint to
allow the parties time to negotiate and finalize a settlement of the case thereby avoiding the
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necessity of proceeding to trial.
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6.
THEREFORE, IT IS HEREBY STIPULATED, by and between, Plaintiff
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KELLI LOSORWITH and Defendants COUNTRY FARE CAFÉ, INC., JOSE VALADEZ,
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TERESA VALADEZ, by and through their respective counsels of record, that Defendants may
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have up to and including August 12, 2011, to serve and file their respective response to the
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Complaint.
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DATED: June 15, 2011
JONES HELSLEY PC
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By: /s/ Michael S. Helsley_________
Michael S. Helsley, Esq.,
Attorneys for Defendants,
COUNTRY FARE CAFÉ, INC.,
JOSE VALADEZ, TERESA VALADEZ
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DATED: June 15, 2011.
MOORE LAW FIRM, P.C.
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By: /s/ Tanya Levinson Moore, Esq.
Tanya Levinson Moore, Esq.
Attorneys for Plaintiff,
KELLI LOSORWITH
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{7125/002/00268745.DOC}
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____________________________________________________________________________________________________
SECOND JOINT STIPULATION FOR ORDER TO CONTINUE TIME FOR DEFENDANTS TO RESPOND TO COMPLAINT;
ORDER THEREON
ORDER
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Good cause appearing, IT IS HEREBY ORDERED that Defendants have up to
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and including August 12, 2011 to serve and file their response to the Complaint.
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IT IS SO ORDERED.
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Dated:
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June 16, 2011
/s/ Oliver W. Wanger
UNITED STATES DISTRICT JUDGE
DEAC_Sig nature-END:
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{7125/002/00268745.DOC}
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____________________________________________________________________________________________________
SECOND JOINT STIPULATION FOR ORDER TO CONTINUE TIME FOR DEFENDANTS TO RESPOND TO COMPLAINT;
ORDER THEREON
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