K. Randolph Moore, SBN 106933 Tanya E. Moore, SBN 206683 2 MOORE LAW FIRM, P.C. 332 North Second Street 3 San Jose, California 95112 Telephone: (408) 298-2000 4 Facsimile: (408) 298-6046 5 Attorneys for Plaintiff Anthony Lerma
STIPULATION TO RESET DATE OF CASE MANAGEMENT CONFERENCE; DECLARATION OF TANYA E. MOORE; ORDER Current Date: July 5, 2011 Proposed Date: August 23, 2011
WHEREAS, the Court set a Case Management Conference for July 5, 2011 at 2:00 19 p.m.; 20
WHEREAS, counsel for Plaintiff Anthony Lerma ("Plaintiff") will be unavailable on the date set by the Court; 22
WHEREAS, no prior time modifications have been granted and no other deadlines set by the Court currently exist; 24
IT IS HEREBY STIPULATED by and between Plaintiff and Defendants A Bite of Wyoming, Inc.; S. Max Spurgeon and Esperanza J. Spurgeon, Trustees of the Spurgeon Living 26 Trust ("Defendants"), by and through their respective counsel, that pursuant to Local Rule 6-27 (a), the Case Management Conference currently set for July 5, 2011 be moved to August 23, 28 2011 at 2:00 p.m.
I, Tanya E. Moore, hereby declare as follows:
1. I am an attorney duly licensed and admitted to practice before the Federal
District Court, Northern District of California, and am a member of the Moore Law Firm, 21 attorneys of record for Plaintiff Anthony Lerma in this action. I have personal knowledge of 22 the following facts, and if called as a witness, I could and would competently testify thereto. 23
2. I will be on vacation on July 5, 2011, the date the Court set the Case Management Conference in this matter, and will not return until the end of July.
3. No other time modifications have been made in this matter; scheduling order the Court intends to issue by a little over one month.
4. Resetting the date of the Case Management Conference will delay any
I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed this 19th day of May 2011 at San Jose, California.
/s/ Tanya E. Moore Tanya ...