Ramirez et al v. West Side Plaza et al

Northern District of California, cand-4:2014-cv-02675

STIPULATION AND ORDER re {{14}} STIPULATION WITH PROPOSED ORDER to Extend the Mediation Deadline filed by HKV Associates LLC, Irma Ramirez, Daren Heatherly. Deadline to complete mediation continued to 3/1/16. Signed by Magistrate Judge Kandis A. Westmore on 1/14/16.

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1 THOMAS E. FRANKOVICH (State Bar No. 074414) THOMAS E. FRANKOVICH, 2 A PROFESSIONAL LAW CORPORATION 1832-A Capitol Street 3 Vallejo, CA 94590 Telephone: (415) 444-5800 4 Facsimile: (415) 674-9900 5 Attorney for Plaintiffs IRMA RAMIREZ; and 6 DAREN HEATHERLY 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 IRMA RAMIREZ; and) CASE NO. 4:14-cv-02675-KAW 11 DAREN HEATHERLY,)) 12 Plaintiffs,) STIPULATION and [PROPOSED] ORDER) TO EXTEND MEDIATION DEADLINE 13 v.) 14) WEST SIDE PLAZA, et al.,) 15) Defendants.) 16 __________________________________) 17 18 Plaintiffs IRMA RAMIREZ; and DAREN HEATHERLY and defendant HKV 19 Associates LLC, a California Limited Liability Company, by and through their respective attorney of record stipulate to extend the deadline to complete mediation for the following 20 reasons: 21 1. Whereas, all defendants have been served with the summons and complaint, and 22 defendants have answered plaintiffs' complaint; and 23 2. Whereas, the Court ordered that mediation be completed no later than 90 days 24 after the Notice of Need for Mediation is filed; and 25 3. Whereas, General Order (56) Site Inspection was not conducted in the above- 26 mentioned case, because the parties have fully resolved the injunctive claims and have an 27 executed Equitable Agreement in place; and 28 4. Whereas, plaintiffs filed a notice of need for mediation on September 15, 2015. STIPULATION and [PROPOSED] ORDER TO EXTEND MEDIATION DEADLINE 1 5. Whereas, as mediation has now been set for February 23, 2016, which is past the 2 courted ordered mediation deadline it is necessary to extend the time to conclude a mediation; 3 6. Therefore, the parties respectfully request that jurisdiction for the mediation 4 currently scheduled for February 23, 2016 at 10:00 a.m. be granted to February 23, 2016, and/or 5 to a date that is convenient to the Court. 6 IT IS SO STIPULATED. 7 This stipulation may be executed in counterparts and have the same force and effect as 8 though all signatures are on the same and/or consecutive pages. Photocopies and facsimile 9 shall have the same force and effect as originals. 10 Respectfully submitted, 11 Dated: January 13, 2016 THOMAS E. FRANKOVICH, 12 A PROFESSIONAL LAW CORPORATION 13 14 By: /s/ Thomas E. Frankovich Thomas E. Frankovich 15 Attorney for Plaintiffs 16 Dated: January 13, 2016 LAW OFFICES OF PHILIP H. KELLY 17 18 By: /s/ Philip H. Kelly Philip H. Kelly 19 Attorney for Defendant HKV Associates, LLC 20 21 22 23 24 25 26 27 28 STIPULATION and [PROPOSED] ORDER TO EXTEND MEDIATION DEADLINE 2 1 [PROPOSED] ORDER 2 IT IS SO ORDERED that the last day for the parties to complete mediation is continued to ________________, 3/1 2016. 3 4 Dated: _______________, 1/14 2016 ___________________________________ Honorable Kandis A. Westmore 5 United States Magistrate Judge 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STIPULATION and [PROPOSED] ORDER TO EXTEND MEDIATION DEADLINE 3