DENNIS C. HUIE (SBN 184377), SUHANI KAMDAR (SBN 218141), ROGERS JOSEPH O'DONNELL, San Francisco, California, 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
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 September 25, 2013, at 10:00 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 and is currently due on August 12, 2013, as per a previously approved stipulation between the Parties.
4. 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. Plaintiff conducted this site inspection on July 12, 2013.
5. On August 7, 2013, counsel for Defendant received Plaintiff's proposed remediation measures and list of alleged violations, which Defendant will evaluate.
6. Counsel for the parties anticipate having further meet-and-confer discussions, including discussions about potential resolution after the review of Plaintiff's proposed remediation measures. To further these discussions, the parties hereby stipulate as follows:
To continue Defendant's responsive pleading deadline by an additional 29 days, giving Defendant up to and including September 10, 2013, to answer or otherwise respond to the Complaint.
NOW THEREFORE, pursuant to Local Rules 143 and 144(a), Plaintiff and Defendant, by and through their undersigned counsel, stipulate as set forth above.
Good cause appearing, the Court hereby ADOPTS the Parties' stipulation. Accordingly, the deadline for Defendant to answer or otherwise respond to the Complaint shall be ...