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Richard Skaff; and Connie Arnold v. Safari West

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA


August 22, 2011

RICHARD SKAFF; AND CONNIE ARNOLD, PLAINTIFFS,
v.
SAFARI WEST, INC., A CALIFORNIA CORPORATION; PETER ANTON LANG AND NANCY ANNE LANG, INDIVIDUALS AND AS TRUSTEES OF THE LANG 2003 TRUST DBA SAFARI WEST; AND DOES 1 THROUGH 10 INCLUSIVE,
DEFENDANTS.

The opinion of the court was delivered by: Laurel Beeler U.S. District Judge

BARBOSA, METZ & HARRISON, LLP PATRICIA BARBOSA, SBN 125865 2 PBarbosa@bmihlaw.com JEFF A. HARRISON, SBN 151227 3 JHarrison@bmihlaw.com 17547 Ventura Blvd., Suite 310 4 Encino, CA 91316 Telephone: (818) 386-1200 5 Facsimile: (818) 386-1212 6 Attorneys for Richard Skaff and Connie Arnold 7 HANSON BRIDGETT LLP 8 KURT A. FRANKLIN, SBN 172715 kfranklin@hansonbridgett.com 9 MOLLY A. LEE, SBN 232477 mlee@hansonbridgett.com 10 425 Market Street, 26th Floor San Francisco, California 9 4105 11 Telephone: (415) 777-3200 Facsimile: (415) 541-9366 12 Attorneys for SAFARI WEST, INC., a 13 California Corporation; PETER ANTON LANG and NANCY ANNE LANG, 14 individuals and as Trustees of the LANG 2003 TRUST dba SAFARI WEST

Civil Rights STIPULATED REQUEST FOR ORDER CHANGING TIME TO CONTINUE THE SCHEDULING ORDER DATES FOR 60 DAYS AND [PROPOSED] ORDER

3166330.2

Pursuant to Local Rule 6-2, Plaintiffs RICHARD SKAFF and CONNIE ARNOLD 2 and Defendants SAFARI WEST, Inc., a California Corporation; PETER ANTON LANG 3 and NANCY ANNE LANG, individuals and as Trustees of the LANG 2003 TRUST dba Barbosa Metz & Harrison and Kurt A. Franklin of Hanson Bridgett LLP state as follows: 6

1. Plaintiffs filed their Complaint on February 24, 2011, with service completed 7 on all Defendants by April 25, 2011. 8

Asserting Denial Of Right Of Access Under Americans With Disabilities Act Title II & III, 10 which ordered the Parties to hold a joint inspection of the premises, with or without a 11 meet-and-confer regarding settlement, no later than June 6, 2011. 12

3. On May 30, 2011, the Parties filed a joint stipulation to continue the 13 remaining Scheduling Order dates for 60 days to accommodate the calendars of counsel 14 and their respective experts and to allow sufficient time for the Parties to meet and 15 explore early resolution. This is the second request for an extension of the site 16 inspection date. 17

4. On June 2, 2011, the Court continued the remaining Scheduling Order 18 dates for 60 days, and ordered the Parties to hold a joint inspection of the premises by 19 2011. On July 6, 2011, Plaintiffs, their counsel, and their experts arrived on site to 21 conduct a site inspection as required by the Court to narrow the issues and evaluate 22 early resolution. Defendants also provided to Plaintiffs' counsel plans to resolve most of 23 the claims for injunctive relief. The site inspection for the two designated accessible 24 guestrooms and for the issue of accessible transportation for the wild life tour was not 25 completed because the guestrooms were occupied on the date of the inspection and the 26 accessible transportation was not ready for Plaintiff's consultant to evaluate. 27

5. The parties have actively conferred and attempted to schedule a date to 28 complete their joint inspection prior to the Court's August 8, 2011 deadline, but the parties SAFARI WEST, by and through their respective attorneys of record, Patricia Barbosa of

2. On February 24, 2011 the Court issued its Scheduling Order for Cases

August 8, 2011. Plaintiffs noticed a joint site evaluation at the subject property on July 6, 20

have been unable to coordinate dates to inspect the two guestrooms or coordinate the 2 calendars of counsel and their respective experts by August 8, 2011. The Parties have 3 scheduled the continued joint inspection of Safari West for September 19, 2011 and 4 intend to continue negotiations of Plaintiffs' claims for injunctive relief. 5

6. As all of the remaining deadlines contained in the Court's Case Scheduling 6

Order are based on the August 8, 2011 date for joint site inspection, the Parties will also 7 be unable to comply with the remaining deadlines for the meeting of counsel. 8

7. The Parties agree that an extension of the current deadline for joint 9 inspection to September 19, 2011, and for the remaining case schedule dates dependent 10 thereon, is necessary so that the Parties can meet on-site with their respective experts to 11 complete the joint inspection and continue their settlement negotiations. 12

8. The requested extension of dates will not conflict with the Court's trial 13 schedule as none has been set in this case under General Order 56. 14

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and 15 between the undersigned, as follows: 16

The August 8, 2011 deadline for joint inspection of the premises shall be extended 17 to September 19, 2011, with all remaining case schedule dates extended as well. 18 19

FOR GOOD CAUSE SHOWN, IT IS HEREBY ORDERED:

The August 8, 2011 deadline for joint inspection of the premises shall be extended 9 to September 19, 2011, and all remaining case schedule dates shall also be extended 10 from the September 19, 2011 date.

IT IS SO ORDERED. ES DI T

T T HONORABLE

IT IS SO ORDERED

Judge Laurel Beeler

20110822

© 1992-2011 VersusLaw Inc.



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