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Law Offices Rynn & Janowsky, Llp Oakland, California 94620 v. Robert Sbragia; John Sbragia; Steven Sbragia; and Patricia Cini Aka Patti Cini

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA BERTI PRODUCE -- SAN FRANCISCO,


July 23, 2012

LAW OFFICES RYNN & JANOWSKY, LLP OAKLAND, CALIFORNIA 94620 P.O. BOX 20799 (510) 705-8894 FAX (510) 705-8737 INC.; EDWIN CHIN DBA NEW CITY FRUIT & PRODUCE; JACOBS, MALCOLM & BURTT; NORTH BAY PRODUCE, INC.; FOR ADR WASHINGTON VEGETABLE COMPANY;
SESSION, DISCOVERY, & WHAT A TOMATO PRODUCE COMPANY, DISPOSITIVE MOTIONS INC.; AND
COOSEMANS SAN FRANCISCO, INC.,
PLAINTIFFS,
v.
ROBERT SBRAGIA; JOHN SBRAGIA; STEVEN SBRAGIA; AND PATRICIA CINI AKA PATTI CINI,
DEFENDANTS.

The opinion of the court was delivered by: Chief Magistrate Judge Maria-Elena James

STIPULATION & REQUEST TO EXTEND DEADLINE

Plaintiffs and Defendants respectfully request that the Court extend the deadline to hold an ADR session from July 15, 2012 to August 11, 2012. This is the parties' second request for 23 an extension. Although they have attempted to schedule the mediation session, because one of 24 the defendants has a new job and the others are unable to attend on the dates available, the parties are unable to schedule the mediation before the deadline. Given the number of parties 2 involved, obtaining a mutually available date has been difficult, but the parties, their attorneys, 3 and the mediator are committed to reschedule the mediation session as soon as possible. 4

Counsel for both parties believe that mediation may be fruitful, and they are engaging in 5 informal settlement discussions, but they would appreciate this extension to insure that the 6 mediation session will take place should informal discussions not result in a resolution of the 7 dispute. 8

Trial is not scheduled until March 4, 2013; however, five deadlines will be affected by 9 the extension of the mediation deadline. As a result, the parties also respectfully request that 10 Action Current Deadline Proposed Deadline

Disclosure of Expert Witnesses 08/03/2012 09/03/2012 LAW OFFICES P.O. BOX 20799 (510) 705-8894 RYNN & JANOWSKY, LLP OAKLAND, CALIFORNIA 94620 Disclosure of Rebuttal Experts 08/13/2012 09/13/2012 FAX (510) 705-8737 Discovery Cutoff 08/28/2012 10/13/2012 Dispositive Motions Must Be Filed, Served, & Noticed 09/27/2012 11/15/2012 Hearing On Dispositive Motions 11/01/2012 12/20/2010 Date: July 12, 2012 RYNN & JANOWSKY, LLP 17 By: /s/ Marion I. Quesenbery Marion I. Quesenbery Attorneys for Plaintiffs Date: July 12, 2012 COHEN AND JACOBSON, LLP 20 21 By: ________________________________ Lawrence A. Jacobson Attorney for Defendants

IT IS SO ORDERED. The following deadlines and dates contained in the Case Management Order dated February 24, 2012 are changed: (1) for the parties to complete ADR to 3 August 11, 2012, (2) for the disclosure of experts to September 3, 2012, (3) for the disclosure of 4 rebuttal experts to September 13, 2012, (4) for the discovery cutoff to October 13, 2012, (4) for 5 filing, service, and noticing of dispositive motions to November 15, 2012, and (5) for the hearing All subsequent pretrial and trial date for dispositive motions December 20, 2012 at 10:00 a.m. deadlines are VACATED.

LAW OFFICES P.O. BOX 20799 (510) 705-8894 RYNN & JANOWSKY, LLP OAKLAND, CALIFORNIA 94620 FAX (510) 705-8737

20120723

© 1992-2012 VersusLaw Inc.



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