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Ronald Moore v. Cnc Apex Corporation Dba Fosters Freeze

July 15, 2011

RONALD MOORE, PLAINTIFF,
v.
CNC APEX CORPORATION DBA FOSTERS FREEZE, ET AL.,
DEFENDANTS.



The opinion of the court was delivered by: Dennis L. Bec United States Magistrate Judge

K. Randolph Moore, Esq., SBN 106933 Tanya E. Moore, Esq. SBN 206683 MOORE LAW FIRM, P.C. 332 North Second Street San Jose, California 95112 Telephone (408) 298-2000 Facsimile (408) 298-6046 Email: tanya@moorelawfirm.com Attorneys for Plaintiff Ronald Moore

STIPULATION TO EXTEND DATES SET IN SCHEDULING ORDER; ORDER AND RELATED CROSS-ACTIONS.

Complaint Filed: September 15, 2010

Plaintiff Ronald Moore ("Plaintiff"); Defendant, Cross-Claimant and Cross-Defendant CNC Apex Corporation dba Fosters Freeze; Cross-Defendants and Cross-Claimants Un Kyong and Eddie Chong; and Defendant, Cross-Claimant and Cross-Defendant Dubu, Inc. (Plaintiff, Defendants, Cross-Claimants and Cross-Defendants 24 collectively referred to herein as the "Parties"), through their attorneys of record, hereby 25 stipulate and agree as follows:

WHEREAS, the Parties have been diligently undertaking to complete discovery, having taken depositions, exchanged written discovery, and conducted a site inspection with 28 their experts; WHEREAS, the settlement conference in this matter was continued to accommodate Plaintiff's counsel's unavailability which settlement conference is now currently set one day 3 prior to the dispositive motion deadline; WHEREAS, the Parties desire to explore settlement prior to incurring the attorney fees which would result from the preparation of the dispositive motions; WHEREAS, the expert witness discovery cut-off is the same date as the dispositive motion filing deadline which does not afford the Parties proper time to receive, review, and 8 properly incorporate the expert witness discovery into a dispositive motion;

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and among the Parties, through their undersigned counsel, that the following deadlines be continued from the dates currently scheduled to dates on or near the dates proposed below:

Current Date Proposed Date Disclose Experts July 15, 2011 August 1, 2011

Disclose Supplemental Experts None August 19, 2011

Expert Cut-Off August 31, 2011 Unchanged

Non-Dispositive Motion Filing August 31, 2011 Unchanged

Non-Dispositive Motion Hearing September 30, 2011 Unchanged

Dispositive Motion Filing August 31, 2011 September 30, 2011

Dispositive Motion Hearing October 12, 2011 ...


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