July 21, 2008
BILL POON & COMPANY, ARCHITECTS, INC., PLAINTIFF,
KHALIL BAFAIZ, AN INDIVIDUAL, NABIL W. TAOVIL, AN INDIVIDUAL, G.A.R.S. INCORPORATED, A CALIFORNIA CORPORATION, GEORGE G. PAVANA, AN INDIVIDUAL, INDERJIT CHADHA, AN INDIVIDUAL, NAEEM AKRAM, AN INDIVIDUAL, AND DOES 1 THROUGH 20, INCLUSIVE, DEFENDANTS.
KHALIL BAFAIZ, CROSS-CLAIMANT
MELISSA CHAVIS, AN INDIVIDUAL, NABIL W. TAOVIL, AN INDIVIDUAL, G.A.R.S., INCORPORATED, A CALIFORNIA CORPORATION, GEORGE PAVANA, AND INDIVIDUAL, CROSS-DEFENDANTS
STIPULATION AND (PROPOSED) ORDER TO EXTEND DEADLINE FOR COMPLETING ADR PROCESS
At the Case Management Conference on March 20, 2008, Judge Hamilton ordered that the matter be referred to ENE to be completed within 150 days, or August 18, 2008. Stuart Gasner, of the law offices of Keker & Van Nest has been appointed as the evaluator. On June 4, 2008, a teleconference was conducted by Mr. Gasner. The ENE session was agreed to be held on July 17, 2008 at Mr. Gasner's office; briefs were to be exchanged on Friday, July 11, 2008. An extension is necessary in that the defendants have not yet been able to fully comply with Requests for Production of Documents propounded upon them by Plaintiff on May 27, 2008, which Requests called for production of the specified documents for inspection and copying on July 1, 2008. Without the documents demanded, the parties cannot properly prepare their briefs nor prepare for the ENE session. Plaintiff respectfully requests that this court order an extension of the deadline for completing the ADR process until October 31, 2008. An extension until late October, 2008, is necessary because of Mr. Gasner's schedule. This matter has been discussed with Mr. Gasner. Attached hereto is an email from him with respect to his availability. In furtherance of this request, the undersigned, counsel for all the parties hereto, hereby stipulate to extend the deadline for completing the ADR process with respect to the above captioned matter until October 31, 2008.
Matthew Webb, Attorney for Defendant and Cross-Complainant KHALIL BAFAIZ, and Defendants INDERJIT CHADHA, and NAEEM AKRAM Dated: 11 July 2008 Gerald Filice, Attorney for Defendants G.A.R.S. INCORPORATED, GEORGE G. PAVANA, and NABIL W. TAOVIL Dated: 14 July 2008 Larry E. Lulofs, Attorney for Cross-Defendant MELISSA CHAVIS I attest that concurrence in the filing of the document has been obtained from each of the other signatories. Dated: 15 July 2008 Kenneth Natkin, Attorney for Plaintiff BILL POON 20 ARCHITECTS, INC.
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