Opinion
Case No. 3:11-cv-05104-YGR-NJV
10-18-2011
ROSS, SINCLAIRE & ASSOCIATES, LLC, Plaintiffs, v. PREMIER SENIOR LIVING, LLC; PREMIER SENIOR LIVING DELAWARE, LLC; 5690 STATE BRIDGE, LLC; 8700 LAWYERS, LLC; 460 MEDLOCK, LLC; 6441 HOLDER, LLC; 2147 DAVIE, LLC; 915 HOOK, LLC; 5835 MEDLOCK BRIDGES, LLC; 1049 ANNA KNAPP, LLC; and 1224 VILLAGE CREEK, LLC, Defendants.
BRYAN CAVE LLP James Goldberg, Cal. Bar No. 107990 Kenneth Lee Marshall, Cal. Bar No. 277092 Mary Gassmann Reichert (pro hac vice) Bahareh Mostajelean, Cal. Bar No. 258903 Attorneys for Plaintiff ROSS, SINCLAIRE & ASSOCIATES, LLC
BRYAN CAVE LLP
James Goldberg, Cal. Bar No. 107990
Kenneth Lee Marshall, Cal. Bar No. 277092
Mary Gassmann Reichert (pro hac vice)
Bahareh Mostajelean, Cal. Bar No. 258903
Attorneys for Plaintiff
ROSS, SINCLAIRE & ASSOCIATES, LLC
Honorable Yvonne Gonzalez Rogers
Magistrate Nandor J. Vadas
STIPULATED DISCOVERY AND MOTION
SCHEDULE; [PROPOSED] ORDER
SETTING DISCOVERY AND MOTION
SCHEDULE
(AS MODIFIED BY THE COURT)
Trial Date: Not Assigned
STIPULATED DISCOVERY AND MOTION SCHEDULE
Pursuant to this Court's December 22, 2011 Order granting Plaintiff's Motion for Expedited Discovery, Plaintiff Ross, Sinclaire & Associates, LLC ("RSA") and Defendants Premier Senior Living, LLC; Premier Senior Living Delaware, LLC; 5690 State Bridge, LLC; 8700 Lawyers, LLC; 460 Medlock, LLC; 6441 Holder, LLC; 2147 Davie, LLC; 915 Hook, LLC; 5835 Medlock Bridges, LLC; 1049 Anna Knapp, LLC; and 1224 Village Creek, LLC (collectively, "Defendants"), submit this stipulated discovery and motion schedule:
• February 27 - March 23, 2012: All depositions completed
• April 13, 2012: Last day to file Motion to Compel Arbitration and Motion for Preliminary Injunction
• April 27, 2012: Last day to file Oppositions to Motion to Compel Arbitration and Motion for Preliminary Injunction
• May 7, 2012: Last day to file Replies in support of Motion to Compel Arbitration and Motion for Preliminary Injunction
• May 18, 2012: Approximate date for Hearings on Motion to Compel Arbitration and Motion for Preliminary Injunction
The parties respectfully request this Court order the discovery and motion schedule as set forth above.
Respectfully submitted,
BRYAN CAVE LLP
James Goldberg
Kenneth Lee Marshall
Mary Gassmann Reichert
Bahareh Mostajelean
By: _______________
Bahareh Mostajelean
Attorneys for Plaintiff
ROSS, SINCLAIRE & ASSOCIATES, LLC
SHEPHERD SMITH EDWARDS & KANTAS, LLP
By: __________
Robert A. Kantas
Attorneys for Defendants
PREMIER SENIOR LIVING, LLC; PREMIER
SENIOR LIVING DELAWARE, LLC; 5690 STATE
BRIDGE, LLC; 8700 LAWYERS, LLC; 460
MEDLOCK, LLC; 6441 HOLDER, LLC; 2147
DAVIE, LLC; 915 HOOK, LLC; 5835 MEDLOCK
BRIDGES, LLC; 1049 ANNA KNAPP, LLC; and
1224 VILLAGE CREEK, LLC
I, Bahareh Mostajelean, attest that the content of this document is acceptable to all persons required to sign the document.
Bahareh Mostajelean
[PROPOSED] ORDER SETTING DISCOVERY AND MOTION SCHEDULE
FOR GOOD CAUSE SHOWN, IT IS HEREBY ORDERED that the Stipulated Discovery Schedule of Plaintiff Ross, Sinclaire & Associates, Inc. ("RSA") and Defendants Premier Senior Living, LLC; Premier Senior Living Delaware, LLC; 5690 State Bridge, LLC; 8700 Lawyers, LLC; 460 Medlock, LLC; 6441 Holder, LLC; 2147 Davie, LLC; 915 Hook, LLC; 5835 Medlock Bridges, LLC; 1049 Anna Knapp, LLC; and 1224 Village Creek, LLC (collectively, "Defendants") is GRANTED as modified below.
IT IS HEREBY ORDERED that Discovery and Motions may proceed according to the following schedule:
• February 27 - March 23, 2012: All depositions completed
• April 13, 2012: Last day to file Motion to Compel Arbitration and Motion for Preliminary Injunction
• April 27, 2012: Last day to file Oppositions to Motion to Compel Arbitration and Motion for Preliminary Injunction
• May 7, 2012: Last day to file Replies in support of Motion to Compel Arbitration and Motion for Preliminary Injunction
• May 21, 2012 at 10:00 a.m.: Date for Hearings on Motion to Compel Arbitration and Motion for Preliminary Injunction
This Order terminates Dkt. No. 35.
IT IS SO ORDERED.
______________________________
YVONNE GONZALEZ ROGERS
United States District Court Judge