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

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

ORDER GRANTING AS MODIFIED {{50}} STIPULATION Continuing Hearings and Deadlines. Discovery due by 5/2/2016. Expert Witness List due by 5/31/2016. Jury Selection set for 10/26/2016 08:00 AM in Courtroom 5, 2nd Floor, Oakland before Hon. Jeffrey S. White. Jury Trial set for 10/31/2016 08:00 AM in Courtroom 5, 2nd Floor, Oakland before Hon. Jeffrey S. White. Motion Hearing set for 7/8/2016 09:00 AM in Courtroom 5, 2nd Floor, Oakland before Hon. Jeffrey S. White. Pretrial Conference set for 9/26/2016 02:00 PM in Courtroom 5, 2nd Floor, Oakland before Hon. Jeffrey S. White. Signed by Judge Jeffrey S. White on 1/15/16.

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Case 4:15-cv-03220-JSW Document 51 50 Filed 01/15/16 01/14/16 Page 1 of 4 5 1 LYN R. AGRE (SBN 178218) KASOWITZ, BENSON, TORRES & FRIEDMAN LLP 2 101 California Street, Suite 2300 San Francisco, California 94111 3 Telephone: (415) 655-4308 Facsimile: (415) 398-5030 4 lagre@kasowitz.com 5 Attorneys for Defendants RELATED MANAGEMENT COMPANY, L.P. 6 (incorrectly sued as The Related Companies, Inc.) and THIRD AND MISSION ASSOCIATES, LLC 7 8 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA 9 KASOWITZ, BENSON, TORRES & FRIEDMAN LLP 10 PETER HOLLAND and KRISTEN Case No. 4:15-CV-03220 JSW HOLLAND, 11 Hon. Judge Jeffery S. White Plaintiffs, SAN FRANCISCO, CALIFORNIA 94111 STIPULATION AND [PROPOSED] 101 CALIFORNIA STREET, SUITE 2300 12 ORDER CONTINUING DEADLINES SET v. IN OCTOBER 2, 2015 CASE 13 MANAGEMENT ORDER (DKT. NO. 45) 14 THE RELATED COMPANIES, INC.; AS MODIFIED HEREIN THIRD AND MISSION ASSOCIATES, 15 LLC; DOES 1 through 10, inclusive Defendants. 16 17 18 19 20 21 22 23 24 25 26 27 28 1 Stipulation and [Proposed] Order Continuing Deadlines Set in October 2, 2015 Case Management Order (dkt. 45); Case No. 4:15-CV-03220 Case 4:15-cv-03220-JSW Document 51 50 Filed 01/15/16 01/14/16 Page 2 of 4 5 1 By and through their attorneys of record, Defendants THIRD AND MISSION 2 ASSOCIATES, LLC and RELATED MANAGEMENT COMPANY, L.P. (incorrectly sued as 3 The Related Companies, Inc.) ("Defendants") and Plaintiffs PETER HOLLAND and KRISTIN 4 HOLLAND ("Plaintiffs") hereby stipulate and agree as follows: 5 WHEREAS, the Court entered a scheduling order on October 2, 2015 (dkt. No. 45) setting 6 case deadlines pursuant to stipulation of the parties; 7 WHEREAS, the Court approved the substitution of Kasowitz, Benson, Torres & Friedman 8 LLP in place of Kimball, Tirey & St. John LLP as Defendants' counsel of record on December 18, 9 2015; 10 WHEREAS, Defendants' new lead counsel, Lyn Agre, represents witnesses in a matter 11 pending before the Honorable Charles R. Breyer in the United States District Court for the 12 Northern District of California (United States v. Federal Express Corporation, Case No. 14-CR- 13 380), which is set for trial on July 13, 2016 and expected to last several months; 14 WHEREAS, Defendants' new counsel and Plaintiffs' counsel have met and conferred, and 15 agree that extension of certain of the deadlines in the current scheduling order is warranted. 16 IT IS HEREBY STIPULATED AND AGREED, by and between the parties hereto and 17 their respective undersigned attorneys, as follows: 18 The parties respectfully jointly request that the Court continue the deadlines set forth in the 19 October 2, 2015 Case Management Order as follows: 20 Discovery Cut-off May 2, 2016 21 Designation of experts May 2, 2016 22 Expert discovery cut-off May 31, 2016 23 Hearing of dispositive motions July 8, 2016 24 Pretrial conference September 26, 2016 25 Jury selection & trial October 31, 2016 26 27 28 2 Stipulation and [Proposed] Order Continuing Deadlines Set in October 2, 2015 Case Management Order (dkt. 45); Case No. 4:15-CV-03220 Case 4:15-cv-03220-JSW Document 51 50 Filed 01/15/16 01/14/16 Page 3 of 4 5 1 2 Respectfully submitted, 3 4 DATED: January 14, 2016 /s/ Lyn R. Agre______________________________ 5 Lyn R. Agre KASOWITZ, BENSON, TORRES 6 & FRIEDMAN LLP 7 Attorneys for Defendants THIRD AND MISSION ASSOCIATES, LLC and 8 RELATED MANAGEMENT COMPANY, L.P. 9 (incorrectly sued as The Related Companies, Inc.) 10 11 12 DATED: January 14, 2016 /s/ Steven L. Derby___________________________ 13 Steven L. Derby THE DERBY LAW FIRM P.C. 14 Attorneys for Plaintiffs 15 PETER HOLLAND and KRISTEN HOLLAND 16 17 DATED: January 14, 2016 /s/ Celia McGuinness________________________ 18 Paul L. Rein Celia McGuinness 19 Catherine Cabalo LAW OFFICES OF PAUL L. REIN 20 21 Attorneys for Plaintiffs PETER HOLLAND and 22 KRISTEN HOLLAND 23 24 25 26 27 28 3 Stipulation and [Proposed] Order Continuing Deadlines Set in October 2, 2015 Case Management Order (dkt. 45); Case No. 4:15-CV-03220 Case 4:15-cv-03220-JSW Document 51 50 Filed 01/15/16 01/14/16 Page 4 5 of 4 5 1 [PROPOSED] ORDER 2 Pursuant to the parties' stipulation, it is hereby ordered that the deadlines set forth in the 3 October 2, 2015 Case Management Conference Order are vacated and reset as follows: 4 Discovery Cut-off May 2, 2016 5 Designation of experts May 2, 2016 6 Expert discovery cut-off May 31, 2016 7 Hearing of dispositive motions July 8, 2016 8 Pretrial conference September 26, 2016 at 2:00 p.m. Jury selection October 26, 2016 at 8:00 a.m. 9 Jury selection & trial Trial October 31, 2016 at 8:00 a.m. 10 IT IS SO ORDERED. 11 12 January 15, 2016 DATED: ______________________ ___________________________________ 13 Honorable Jeffery S. White 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 5 Stipulation and [Proposed] Order Continuing Deadlines Set in October 2, 2015 Case Management Order (dkt. 45); Case No. 4:15-CV-03220