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Garcia v. Dalton

United States District Court, Ninth Circuit

November 25, 2013

RACHEL GARCIA, Plaintiff,
v.
ANDREA DALTON, Defendant.

Gregory P. Arakawa (State Bar No. 159023), Alicia R. Kennon (State Bar No. 240569), WOOD, SMITH HENNING & BERMAN LLP, Concord. California, Dennis B. Polk, (Colo. State Bar No. 8777), HOLLEY, ALBERTSON & POLK, P.C., Golden, Colorado, (Admitted Pro Hec Vice). Attorneys for Defendant ANDREA DALTON and THE LAW OFFICE OF ANDREA DALTON. LLC.

HOWARD R. LLOYD, Magistrate Judge.

STIPULATION AND REQUEST TO CHANGE HEARING DATE PURSUANT TO CIVIL LOCAL RULES 6-2 AND 7-7

[Assigned for All Purposes to Magistrate Judge Howard R. Lloyd, Dept. 09]

COMES NOW Defendants ANDREA DALTON and THE LAW OFFICE OF ANDREA DALTON, LLC and pursuant to Civil Local Rule 6-2 and 7-7, hereby request and stipulate to a continuance of the hearing date on Defendants' Motion to Change Venue filed on November 21, 2013 and set for hearing on December 31, 2013 at 10:00 a.m.

Counsel for Defendants attempted to meet and confer with Plaintiff's counsel prior to the selection of the hearing date. When no response was received. Defendants timely filed a motion to change venue. Shortly after the motion was filed. Plaintiff's counsel requested a change in the hearing date, the reasons for which are outlined more fully in the stipulation attached hereto as Exhibit "A." Pursuant to the stipulation, the parties hereby request that the hearing date be continued to Tuesday January 14, 2014 at 10:00 a.m. or as soon thereafter as the Court may be available. Pursuant to Civil Local Rule 7-7, this request is being made prior to the deadline to oppose said motion.

The parties hereby waive their rights under Civil Rule 7-7(d) and request, and stipulate, that all filing deadlines pursuant to Civil Local Rule 7-3 be continued to reflect the change in the hearing date.

This request is being made by the parties by and through their respective counsel of record and pursuant to the executed stipulation and proposed order, filed concurrently herewith as Exhibit "A."

EXHIBIT A

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

Pursuant to Federal Rule of Civil. Procedure ___, the parties and each of them hereby stipulate to continue defendant's ANDREA DALTON and THE LAW OFFICE of ANDREA DALTON, LLC's Motion to Change Venue Pursuant to 28 U.S.C. 1404 (a) because of the following:

1. Plaintiff's counsel has surgery scheduled on December 5, 2013; Thanksgiving holiday; pre-operative appointment; depositions/meetings previously scheduled and a pre-paid vacation on the date of the hearing, December 31, 2013.

2. Parties thereby agree and stipulate that this hearing be moved to January 14, 2014 or a date after that ...


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