Holland et al v. The Related Companies, Inc. et al

Northern District of California, cand-4:2015-cv-03220

ORDER GRANTING {{64}} STIPULATION TO EXTEND DEADLINES. Discovery due by 5/23/2016. Designation of Experts due by 5/23/2016. Expert Witness List due by 6/20/2016. Signed by Judge Jeffrey S. White on 4/29/16. Modified on 4/29/2016

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Case 4:15-cv-03220-JSW Document 65 64 Filed 04/29/16 04/28/16 Page 1 of 5 1 LYN R. AGRE (SBN 178218) MARGARET A. ZIEMIANEK (SBN 233418) 2 GUNNAR K. MARTZ (SBN 300852) KASOWITZ, BENSON, TORRES & FRIEDMAN LLP 3 101 California Street, Suite 2300 San Francisco, California 94111 4 Telephone: (415) 655-4308 Facsimile: (415) 398-5030 5 lagre@kasowitz.com mziemianek@kasowitz.com 6 gmartz@kasowitz.com 7 Attorneys for Defendants THE RELATED COMPANIES, INC., 8 THIRD AND MISSION ASSOCIATES, LLC, and RELATED MANAGEMENT COMPANY, L.P. 9 KASOWITZ, BENSON, TORRES & FRIEDMAN LLP 10 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA 11 PETER HOLLAND and KRISTEN Case No. 4:15-CV-03220 JSW SAN FRANCISCO, CALIFORNIA 94111 101 CALIFORNIA STREET, SUITE 2300 12 HOLLAND, Hon. Judge Jeffery S. White 13 Plaintiffs, STIPULATION AND [PROPOSED] 14 v. ORDER CONTINUING DEADLINES SET IN JANUARY 15, 2016 ORDER 15 THE RELATED COMPANIES, INC.; (DKT. NO. 51) THIRD AND MISSION 16 ASSOCIATES, LLC; RELATED MANAGEMENT COMPANY, L.P.; 17 DOES 1 through 10, inclusive 18 Defendants. 19 20 21 22 23 24 25 26 27 28 Stipulation and [Proposed] Order Continuing Deadlines Set in January 15, 2016 Order (Dkt. No. 51); Case No. 4:15-CV-03220 Case 4:15-cv-03220-JSW Document 65 64 Filed 04/29/16 04/28/16 Page 2 of 5 1 By and through their attorneys of record, Defendants THE RELATED COMPANIES, 2 INC., THIRD AND MISSION ASSOCIATES, LLC, and RELATED MANAGEMENT 3 COMPANY, L.P. (collectively, "Defendants") and Plaintiffs PETER HOLLAND and KRISTIN 4 HOLLAND ("Plaintiffs") hereby stipulate and agree as follows: 5 WHEREAS, the Court entered an order on January 15, 2016, (Dkt. No. 51) setting case 6 deadlines pursuant to stipulation of the parties; 7 WHEREAS, Defendants' counsel and Plaintiffs' counsel have met and conferred, and 8 agree that extension of certain of the deadlines in the current scheduling order is warranted. 9 IT IS HEREBY STIPULATED AND AGREED, by and between the parties hereto and 10 their respective undersigned attorneys, as follows: 11 The parties respectfully jointly request that the Court continue the deadlines set forth in the 12 January 15, 2016 Order as follows: 13 Discovery Cut-off May 23, 2016 14 Designation of experts May 23, 2016 15 Expert discovery cut-off June 20, 2016 16 17 The parties propose no change to the following deadlines set forth in the January 15, 2015 18 Order: 19 Hearing of dispositive motions July 8, 2016 20 Pretrial conference September 26, 2016 at 2:00 p.m. 21 Jury selection October 26, 2016 at 8:00 a.m. 22 Trial October 31, 2016 at 8:00 a.m. 23 IT IS SO STIPULATED. 24 25 26 27 28 2 Stipulation and [Proposed] Order Continuing Deadlines Set in January 15, 2016 Order (Dkt. No. 51); Case No. 4:15-CV-03220 Case 4:15-cv-03220-JSW Document 65 64 Filed 04/29/16 04/28/16 Page 3 of 5 1 Respectfully submitted, 2 3 DATED: April 28, 2016 /s/ Lyn R. Agre______________________________ 4 Lyn R. Agre 5 KASOWITZ, BENSON, TORRES & FRIEDMAN LLP 6 Attorneys for Defendants 7 THE RELATED COMPANIES, INC., 8 THIRD AND MISSION ASSOCIATES, LLC, and RELATED MANAGEMENT 9 COMPANY, L.P. 10 11 DATED: April 28, 2016 /s/ Celia McGuinness________________________ Paul L. Rein 12 Celia McGuinness 13 Catherine Cabalo LAW OFFICES OF PAUL L. REIN 14 Steven L. Derby 15 THE DERBY LAW FIRM P.C. 16 Attorneys for Plaintiffs 17 PETER HOLLAND and KRISTEN HOLLAND 18 19 20 21 22 23 24 25 26 27 28 3 Stipulation and [Proposed] Order Continuing Deadlines Set in January 15, 2016 Order (Dkt. No. 51); Case No. 4:15-CV-03220 Case 4:15-cv-03220-JSW Document 65 64 Filed 04/29/16 04/28/16 Page 4 of 5 1 CERTIFICATION OF COMPLIANCE WITH L.R. 5-1(i)(3) 2 Pursuant to Local Rule 5-1(i)(3), I hereby certify that the content of this document is 3 acceptable to Celia McGuinness and Steven L. Derby, counsel for Plaintiffs, and that I have 4 obtained their authorization to affix their respective electronic signatures to this document. 5 6 DATED: April 28, 2016 /s/ Lyn R. Agre______________________________ Lyn R. Agre 7 KASOWITZ, BENSON, TORRES & FRIEDMAN LLP 8 Attorneys for Defendants 9 THE RELATED COMPANIES, INC., THIRD AND MISSION ASSOCIATES, LLC, and 10 RELATED MANAGEMENT COMPANY, L.P. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4 Stipulation and [Proposed] Order Continuing Deadlines Set in January 15, 2016 Order (Dkt. No. 51); Case No. 4:15-CV-03220 Case 4:15-cv-03220-JSW Document 65 64 Filed 04/29/16 04/28/16 Page 5 of 5 1 [PROPOSED] ORDER 2 Pursuant to the parties' stipulation, it is hereby ordered that the deadlines set forth in the 3 January 15, 2016 Order are vacated and reset as follows: 4 Discovery Cut-off May 23, 2016 5 Designation of experts May 23, 2016 6 Expert discovery cut-off June 20, 2016 7 Hearing of dispositive motions July 8, 2016 8 Pretrial conference September 26, 2016 at 2:00 p.m. 9 Jury selection October 26, 2016 at 8:00 a.m. 10 Trial October 31, 2016 at 8:00 a.m. 11 IT IS SO ORDERED. 12 13 April 29, 2016 DATED: ______________________ ___________________________________ 14 Honorable Jeffery S. White 15 16 17 18 19 20 21 22 23 24 25 26 27 28 5 Stipulation and [Proposed] Order Continuing Deadlines Set in January 15, 2016 Order (Dkt. No. 51); Case No. 4:15-CV-03220