John H. Weston (SBN: 46146), G. Randall Garrou (SBN: 74442), Jerome H. Mooney (SBN: 199542), Weston, Garrou & Mooney, Los Angeles, CA, Attorneys for Plaintiff IBIZ, LLC.
MICHAEL S. LAWSON (SBN: 048172), City Attorney, MICHAEL G. VIGILIA (SBN: 228353), Assistant City Attorney, CITY OF HAYWARD Hayward, CA, Attorneys for Defendant.
STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO FILE REPLY BRIEF
SAMUEL CONTI, District Judge.
COME NOW PLAINTIFF IBIZ AND DEFENDANT CITY AND STIPULATE AS FOLLOWS:
On May 7, 2013, Plaintiff IBIZ, LLC ("IBiz") filed its motion for preliminary injunction. On May 21, 2013, the City filed its papers in Opposition to the Motion. Pursuant to a prior stipulated extension request and order, IBiz' reply papers are due tomorrow, June 7, 2013.
Due to a combination of emergency litigation that has occupied lead drafting counsel for Plaintiff along with additional obligations he has with respect to the care of his wife, following her recent major shoulder surgery, counsel requests one final extension of time to complete the filing of Plaintiff's Reply papers in connection with the pending preliminary injunction motion. For these reasons, Plaintiff's counsel asked Counsel for the City if he would agree to one final 5 day extension of the due date for Plaintiff's Reply papers, subject to the approval of the Court. Counsel for the City graciously granted this request.
The requested extended filing date would be Wednesday, June 12th. The hearing on Plaintiff's motion is scheduled for June 21st.
The parties, by and through their counsel of record, HEREBY STIPULATE, subject to the approval of the Court, to extend the time IBIZ has to file its reply papers in support of its motion for preliminary injunction, presently due on June 7, 2013, to June 12, 2013.
Based on the stipulation of the parties, and good cause appearing therefore, the Court hereby extends the deadline for IBiz to file its reply papers in support of its Motion ...