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Jane Doe v. Giuseppe Penzato

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION


May 2, 2011

JANE DOE,
PLAINTIFF,
v.
GIUSEPPE PENZATO, AN INDIVIDUAL; AND
KESIA PENZATO, AN INDIVIDUAL,
DEFENDANTS.

The opinion of the court was delivered by: The Honorable Maria-Elena James United States Magistrate Judge

MATTHEW R. REED, State Bar No. 196305 CAROLINE E. WILSON, State Bar No. 241031 JENNIFER M. MARTINEZ, State Bar No. 262081 MICHAEL D. K. NGUYEN, State Bar No. 264813 TRACY D. RUBIN, State Bar No. 267420 WILSON SONSINI GOODRICH & ROSATI Professional Corporation 650 Page Mill Road Palo Alto, CA 94304-1050 Telephone: (650) 493-9300 Facsimile: (650) 493-6811 Email: mreed@wsgr.com CINDY LIOU, State Bar No. 252161 8 ASIAN PACIFIC ISLANDER LEGAL OUTREACH 1121 Mission Street San Francisco, California 94103 Telephone: (415) 567-6255 10 Facsimile: (415) 567-6248 Email: cliou@apilegaloutreach.org Attorneys for Plaintiff JANE DOE MIA S. BLACKLER, State Bar. No. 188112 BUCHALTER NEMER A Professional Corporation 333 Market Street, 25th Floor San Francisco, CA 94105-2126 Telephone: (415) 227-0900 Facsimile: (415) 227-0770 Email: mblackler@buchalter.com Attorneys for Defendants 18 GIUSEPPE PENZATO and KESIA PENZATO

STIPULATED REQUEST AND [PROPOSED] ORDER TO ENLARGE TIME FOR THE PARTIES TO FILE, SERVE, AND NOTICE DISPOSITIVE MOTIONS AND TO CONTINUE THE DEADLINE FOR HEARING DISPOSITIVE MOTIONS

STIPULATED REQUEST AND [PROPOSED] ORDER 3:10-CV-05154-MEJ TO ENLARGE TIME FOR THE PARTIES TO FILE DISPOSITIVE MOTIONS AND TO CONTINUE THE DEADLINE FOR HEARING DISPOSITIVE MOTIONS

Pursuant to Civil Local Rules 6-1(b), 6-2, and 7-2 Plaintiff Jane Doe*fn1 ("Plaintiff") and Defendants Giuseppe Penzato and Kesia Penzato ("Defendants"), by and through their respective 3 counsel of record, hereby submit this stipulated request to enlarge time for the parties to file, 4 serve, and notice any dispositive motions and to continue the deadline for hearing dispositive 5 motions:

WHEREAS Plaintiff filed her Complaint on November 12, 2010;

WHEREAS the parties previously stipulated that Defendants would have until March 29, 2011 to answer or respond to Plaintiff's Complaint;

WHEREAS the parties previously stipulated and this Court ordered that Plaintiff would have until April 29, 2011 to file any motions responsive to Defendants' Answer previously due 11 on April 22, 2011;

WHEREAS by Order dated April 14, 2011 this Court set December 1, 2011 and January 5, 2012, respectively, as the deadlines for the parties' dispositive motions, and this Court's 14 hearing on those motions; 15

WHEREAS Plaintiff's counsel has a previously scheduled arbitration hearing in December 2011 that conflicts with these deadlines; 17

WHEREAS extending these deadlines by six weeks will alter the dates regarding the parties' dispositive motions, but will not alter the date of any other event or deadline already 19 fixed by this Court; 20

NOW, THEREFORE, the undersigned parties, through their respective counsel, hereby stipulate and agree as follows: 22

1. All dispositive motions shall be filed, served, and noticed by January 12, 2012, or some later date as is convenient for the Court. 24 25

2. The January 5, 2012 deadline for hearing dispositive motions shall be removed from the calendar and continued until February 16, 2012, or some later date as is convenient for 3 the Court. 4

3. Deadlines for any Opposition or Reply motions will be set in accordance with the Civil Local Rules and the Federal Rules of Civil Procedure. 6

PURSUANT TO STIPULATION, IT IS SO ORDERED that all dispositive motions shall be filed, served, and noticed by ___________________. January 12, 2012

The Court shall hear dispositive motions 23 on ___________________ February 16, 2012 at ______________. 10:00 a.m.

26

DECLARATION OF CONSENT

Pursuant to General Order 45, the undersigned certifies that concurrence in the filing of this document was obtained from each of the other signatories. 4

Dated: April 29, 2011 By: s/Caroline Wilson Caroline Wilson


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