Opinion
Case No. 2:12-CV-00419-WBS-JFM
02-05-2013
SHAUN OWENS, Plaintiff, v. WALGREEN CO.; and DOES 1-100, inclusive, Defendant.
LAWRANCE A. BOHM, (SBN 208716) BOHM LAW GROUP ERIKA M. GASPAR, (SBN 238117) LAW OFFICE OF ERIKA M. GASPAR Attorneys for Plaintiff SHAUN OWENS
LAWRANCE A. BOHM, (SBN 208716)
BOHM LAW GROUP
ERIKA M. GASPAR, (SBN 238117)
LAW OFFICE OF ERIKA M. GASPAR
Attorneys for Plaintiff
SHAUN OWENS
STIPULATION FOR ORDER
SHORTENING TIME FOR HEARING
OF PLAINTIFF'S UNOPPOSED
MOTION TO CONTINUE THE DATE
OF TRIAL AND OF UNOPPOSED
MOTION OF PLAINTIFF'S
ATTORNEYS TO BE RELIEVED AS
COUNSEL; (PROPOSED) ORDER
Judge: Hon. William B. Shubb
Plaintiff, SHAUN OWENS, by and through his attorneys of record, Lawrance A. Bohm and Erika M. Gaspar and Defendant, WALGREEN CO., by and through their attorney of record Rex Darrell Berry stipulate to an Order Shortening Time pursuant to Federal Rules of Civil Procedure Rule 6 and Local Rule 144(e) for a hearing of Plaintiff's Motion to Continue the Date of Trial and of the Unopposed Motion of Plaintiff's Attorneys to be Relieved as Counsel, submitted herewith, to be set for February 11, 2013 at 2:00 p.m.
I. EXISTENCE OF GOOD CAUSE
1. Good cause exists in Plaintiff is seeking other counsel for representation in this matter.
2. Good cause exists in that Plaintiff will be prejudiced if the motions submitted herewith are not heard on shortened time. Defendant will not be prejudiced if the motions are heard on shortened time as it does not oppose the motions and does not intend to file an opposition.
3. Good cause exists in that before the referenced matters can be heard and ruled on by this Court pursuant to Local Rule 230 and Federal Rules of Civil Procedures 78, two crucial trial-related deadlines will have passed:
• the current date for disclosure of experts and reports per Rule 26(a)(2) is February 15, 2013. (Doc. 33);
• the current deadline by which responses are due to the currently outstanding written discovery, and the deadline for completion of the pending previously noted depositions is February 25, 2013 (Doc. 33).
4. Good cause exists in that counsel for the parties believe the interests of justice and efficiency would be served by an Order granting the request to shortening time.
By: _______________
LAWRANCE A. BOHM, ESQ.
ERIKA M. GASPAR, ESQ.
Attorneys for Plaintiff
SHUAN OWENS
By: _______________
REX DARRELL BERRY, ESQ.
BERRY & BLOCK LLP
Attorneys for Defendant
WALGREEN, CO.
ORDER
GOOD CAUSE APPEARING, the Court sets the matters for hearing as follows:
+-----------------------------------------------------------------------------+ ¦Motion: ¦Hearing Date & Time: ¦ +--------------------------------------------+--------------------------------¦ ¦Plaintiff's Unopposed Motion to Continue the¦ ¦ ¦Date of ¦ ¦ ¦ ¦ ¦ ¦Trial and to Modify the Status (Pretrial ¦February 11, 2013 at 2:00 p.m. ¦ ¦Scheduling) Order ¦ ¦ ¦ ¦February 11, 2013 at 2:00 p.m. ¦ ¦Unopposed Motion of Plaintiff's Attorneys to¦ ¦ ¦be Relieved ¦ ¦ ¦ ¦ ¦ ¦As Counsel. ¦ ¦ +-----------------------------------------------------------------------------+
Both motions shall be filed immediately. Counsel for plaintiff, Shaun Owens, is ordered to assure the plaintiff's appearance at the hearing on the motion to withdraw, set for February 11, 2013 at 2:00 p.m. IT IS SO ORDERED:
_______________
WILLIAM B. SHUBB
UNITED STATES DISTRICT JUDGE