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Case 1:13-cv-00611-AWI-BAM Document 10 Filed 07/31/13 Page 1 of 3



(408) 298-2000
(408) 298-6046

MOORE LAW FIRM, P.C.
TANYA E. MOORE, SBN 206683
[email protected]
332 North Second Street
San Jose, California 95112
Telephone:
Facsimile:

Attorneys for Plaintiff
RONALD MOORE

HANSON BRIDGETT LLP
KURT A. FRANKLIN, SBN 172715
MEGAN OLIVER THOMPSON, SBN 256654
425 Market Street, 26th Floor
San Francisco, California 94105
Telephone:
Facsimile:

Attorneys for Defendants King of Central
Valley and Central Valley Group, Inc.




(415) 777-3200
(415) 541-9366

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF CALIFORNIA



RONALD MOORE,


Plaintiff,



v.


KING OF CENTRAL VALLEY, a California
General Partnership; CENTRAL VALLEY
GROUP, INC., a California corporation,
dba BURGER KING #7705;,


Defendants.

CASE NO. 13-CV-00611-AWI-BAM


STIPULATION AND ORDER FOR
EXTENSION OF TIME TO RESPOND TO
COMPLAINT AND TO RESCHEDULE
SCHEDULING CONFERENCE

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Pursuant to Local Rules 143 and 144, Plaintiff Ronald Moore and Defendants King

of Central Valley and Central Valley Group, Inc., through their undersigned counsel,

hereby stipulate as follows:

WHEREAS, this action was filed on April 26, 2013;

WHEREAS, Defendants waived service on May 28, 2013;

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5244405.1







WHEREAS, Defendants' answer to the Complaint is currently due on July 19,

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STIP AND ORDER TO EXTEND TIME TO
RESPOND TO COMPLT AND RESCHEDULE
SCHED CONF

Case 1:13-cv-00611-AWI-BAM Document 10 Filed 07/31/13 Page 2 of 3



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2013;

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WHEREAS, the Court's Mandatory Scheduling Conference is currently set for

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August 13, 2013 at 9:00 a.m.;

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WHEREAS, the parties are in the process of negotiating a settlement of this action

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and, therefore, have agreed to extend Defendants' time to respond to the complaint to

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August 30, 2013;

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NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED by the parties,

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through their counsel, as follows:

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1)

Defendants shall have to and including August 30, 2013 to answer or

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otherwise respond to the complaint; and

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2)

In the interest of judicial economy and efficient use of resources, the parties

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hereby request that the Court reschedule the Mandatory Scheduling Conference to a

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date after September 1, 2013 that is convenient for the Court’s calendar.

IT IS SO STIPULATED.

DATED: July 30, 2013








DATED: July 30, 2013






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5244405.1

MOORE LAW FIRM, P.C.

/S/ Tanya E. Moore
(as authorized on July 18, 2013)

By:

TANYA E. MOORE
Attorneys for Plaintiff
RONALD MOORE

HANSON BRIDGETT LLP

By:

/S/ Megan Oliver Thompson

KURT A. FRANKLIN
MEGAN OLIVER THOMPSON
Attorneys for Defendants KING OF CENTRAL
VALLEY and CENTRAL VALLEY GROUP,
INC.

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STIP AND ORDER TO EXTEND TIME TO
RESPOND TO COMPLT AND RESCHEDULE
SCHED CONF

Case 1:13-cv-00611-AWI-BAM Document 10 Filed 07/31/13 Page 3 of 3

Based on the above Stipulation, and for good cause shown, Defendants' deadline

ORDER



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to respond to Plaintiff’s complaint is hereby extended to August 30, 2013. Further, the

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Scheduling Conference currently scheduled for August 13, 2013 is continued to

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September 24, 2013.

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IT IS SO ORDERED.


Dated: July 30, 2013





/s/ Barbara A. McAuliffe _
UNITED STATES MAGISTRATE JUDGE

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5244405.1







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STIP AND ORDER TO EXTEND TIME TO
RESPOND TO COMPLT AND RESCHEDULE
SCHED CONF