DENNIS C. HUIE (SBN 184377), SUHANI KAMDAR (SBN 218141) ROGERS JOSEPH O'DONNELL, San Francisco, Californial, Attorneys for Defendant CALIFORNIA-FRESNO INVESTMENT COMPANY.
MOORE LAW FIRM, P.C., Tanya E. Moore, Attorney for Plaintiff Ronald Moore
STIPULATION AND ORDER TO EXTEND TIME WITHIN WHICH DEFENDANT IS TO ANSWER OR OTHERWISE RESPOND TO COMPLAINT AND TO CONTINUE MANDATORY SCHEDULING CONFERENCE E.D. Local Rules 143, 144(a)
GARY S. AUSTIN, Magistrate Judge.
IT IS HEREBY STIPULATED by and between Plaintiff Ronald Moore ("Plaintiff") and Defendant California-Fresno Investment Company ("Defendant") (hereinafter collectively referred to as "the Parties"), through their respective counsel, as follows:
1. This action was originally filed on April 24, 2013, alleging violations of federal and state disabled access laws arising from 2585 South East Avenue, Fresno, California (hereinafter, the "Subject Premises").
2. A Mandatory Scheduling Conference has been set for July 25, 2013, at 9:30 a.m. before the Honorable Magistrate Judge Gary S. Austin.
3. Defendant's response to Plaintiff's complaint was originally due on June 3, 2013.
4. On or about May 24, 2013, counsel for the Parties stipulated to an extension for Defendant to respond to Plaintiff's Complaint, up to and including June 28, 2013.
5. Counsel for the Parties have commenced meet-and-confer discussions as set forth under Federal and local rules. As part of those meet-and-confer discussions, counsel for the Parties agreed to a site inspection to be conducted by Plaintiff's counsel and her disability access consultant at the Subject Premises. This site inspection is necessary to further meet-and-confer discussions, including discussions about potential resolution.
6. The Parties have agreed to a site inspection on July 12, 2013.
7. Counsel for the parties anticipate having further meet-and-confer discussions, including discussions about potential resolution after the site inspection. To further these discussions, the parties hereby stipulate as follows:
a. To continue Defendant's responsive pleading deadline by an additional 60 days, giving Defendant up to and including August 27, 2013, to answer or otherwise respond to the Complaint.
b. To continue the Mandatory Scheduling Conference to September 25, 2013, at 10:00 a.m., or to the first available date thereafter on the Court's calendar.
NOW THEREFORE, pursuant to Local Rules 143 and 144(a), Plaintiff and Defendant, by and through their undersigned ...