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

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

ORDER GRANTING {{82}} STIPULATION Continuing Deadlines Set in April 29, 2016 Order (doc. no. 65). Fact Discovery due by 5/27/2016. Expert Discovery due by 7/15/2016. Motion Hearing set for 7/22/2016 09:00 AM in Courtroom 5, 2nd Floor, Oakland before Hon. Jeffrey S. White. Signed by Judge Jeffrey S. White on 5/31/16.

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Case 4:15-cv-03220-JSW Document 85 82 Filed 05/31/16 05/27/16 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 APRIL 29, 2016 ORDER 15 THE RELATED COMPANIES, INC.; (DKT. NO. 65) THIRD AND MISSION ASSOCIATES, AS MODIFIED 16 LLC; RELATED MANAGEMENT COMPANY, L.P.; DOES 1 through 10, 17 inclusive 18 Defendants. 19 20 21 22 23 24 25 26 27 28 Stipulation and [Proposed] Order Continuing Deadlines Set in April 29, 2016 Order (Dkt. No. 65); Case No. 4:15-CV-03220 Case 4:15-cv-03220-JSW Document 85 82 Filed 05/31/16 05/27/16 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 April 29, 2016 (Dkt. No. 65), setting case 6 deadlines pursuant to stipulation of the parties; 7 WHEREAS, the current schedule is as follows: 8 Fact discovery cut-off May 23, 2016 9 Designation of experts May 23, 2016 10 Expert discovery cut-off June 20, 2016 11 Hearing of dispositive motions July 8, 2016 12 Pretrial conference September 26, 2016 at 2:00 p.m. 13 Jury selection October 26, 2016 at 8:00 a.m. 14 Trial October 31, 2016 at 8:00 a.m. 15 WHEREAS, Defendants' counsel and Plaintiffs' counsel have met and conferred, and 16 agree that extension of certain of the deadlines in the current scheduling order is warranted. 17 IT IS HEREBY STIPULATED AND AGREED, by and between the parties hereto and 18 their respective undersigned attorneys, as follows: 19 The parties respectfully jointly request that the Court continue the deadlines set forth in the 20 April 29, 2016 Order as follows: 21 Fact discovery cut-off May 27, 20161 22 Designation of experts June 22, 2016 23 Expert discovery cut-off July 15, 2016 24 Hearing of dispositive motions July 22, 2016 25 26 1 27 Thereby extending the deadline to file discovery motions to June 3, 2016, pursuant to Local Rule 37-3. 28 2 Stipulation and [Proposed] Order Continuing Deadlines Set in April 29, 2016 Order (Dkt. No. 65); Case No. 4:15-CV-03220 Case 4:15-cv-03220-JSW Document 85 82 Filed 05/31/16 05/27/16 Page 3 of 5 1 The parties propose no change to the other deadlines. 2 3 IT IS SO STIPULATED. 4 Respectfully submitted, 5 6 DATED: May 27, 2016 /s/ Lyn R. Agre______________________________ 7 Lyn R. Agre 8 KASOWITZ, BENSON, TORRES & FRIEDMAN LLP 9 Attorneys for Defendants 10 THE RELATED COMPANIES, INC., THIRD AND MISSION ASSOCIATES, LLC, and 11 RELATED MANAGEMENT COMPANY, L.P. 12 13 DATED: May 27, 2016 /s/ Celia McGuinness________________________ Paul L. Rein 14 Celia McGuinness LAW OFFICES OF PAUL L. REIN 15 16 Steven L. Derby THE DERBY LAW FIRM P.C. 17 Attorneys for Plaintiffs 18 PETER HOLLAND and KRISTEN HOLLAND 19 20 21 22 23 24 25 26 27 28 3 Stipulation and [Proposed] Order Continuing Deadlines Set in April 29, 2016 Order (Dkt. No. 65); Case No. 4:15-CV-03220 Case 4:15-cv-03220-JSW Document 85 82 Filed 05/31/16 05/27/16 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: May 27, 2016 /s/ Lyn R. Agre______________________________ Lyn R. Agre 7 KASOWITZ, BENSON, TORRES & FRIEDMAN LLP 8 Attorneys for Defendants THE RELATED COMPANIES, INC., 9 THIRD AND MISSION ASSOCIATES, LLC, and RELATED MANAGEMENT COMPANY, L.P. 10 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 April 29, 2016 Order (Dkt. No. 65); Case No. 4:15-CV-03220 Case 4:15-cv-03220-JSW Document 85 82 Filed 05/31/16 05/27/16 Page 5 of 5 1 [PROPOSED] ORDER 2 Pursuant to the parties' stipulation, it is hereby ordered that the following deadlines set 3 forth in the April 29, 2016 Order are vacated and reset as follows: 4 Fact discovery cut-off May 27, 2016 5 Designation of experts June 22, 2016 6 Expert discovery cut-off July 15, 2016 7 Hearing of dispositive motions July 22, 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. The parties shall review this Court's deadlines relating to pre-trial conferences, 12 including the deadlines by which they must exchange motions in limine. The Court reserves the right to continue the pretrial conference and trial if required. 13 May 31, 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 April 29, 2016 Order (Dkt. No. 65); Case No. 4:15-CV-03220