Document for Kimberly vs. North Bay Animal Services

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                                KAUFMAN DOLOWICH & VOLUCK, LLP
1    Tad A. Devlin (SBN 190355)
2    Kartikey A. Pradhan (SBN 291870)
     425 California Street, Suite 2100
 3   San Francisco, California 94104
     Telephone: (415) 926-7600
4    Facsimile: (415) 926-7601
5    Email:       tdevlin@kdvlaw.com
                  kpradhan@kdvlaw.com
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     Attorneys for Defendants
7    NORTH BAY ANIMAL SERVICES and
8    MARK SCOTT

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                        SUPERIOR COURT FOR THE STATE OF CALIFORNIA
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11                               IN AND FOR THE COUNTY OF SONOMA

12                                     UNLIMITED JURISDICTION
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     MARK KIMBERLY,                                    Case No.: SCV-269151
15                                                     Action Filed: August 26, 2021
                    Plaintiff,                         Trial Date: April 5, 2024
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            V.                                         [Assigned to the Hon. Christopher Honigsberg,
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                                                       Dept. 18]
18   NORTH BAY ANIMAL SERVICES, a
     California 501(c)(3) Domestic Nonprofit           THE PARTIES' JOINT STIPULATION AND
19   corporation; MARK SCOTT, an individual            ORDER TO EXTEND DISCOVERY CUTOFF
     and DOES 1 through 20, inclusive,
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21                  Defendant(s).                      Original Discovery Cutoff:       March 6, 2024
                                                       New Discovery Cutoff:            March 26, 2024
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24          1.      Plaintiff Mark Kimberly ("Plaintiff') and Defendants North Bay Animal Services and

25   Mark Scott ("Defendants") (collectively, "the Parties") are in the process of completing fact

26   discovery.

27          2.      The Parties have served written requests for production of documents, requests for

28   admissions, and interrogatories, but the Parties need an extension of time to serve responses to the
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                        THE PARTIES' JOINT STIPULATION AND ORDER TO EXTEND DISCOVERY CUTOFF
1    requests. The Parties may also need to conduct additional depositions and need to conduct Expert
2    Depositions.
3           3.      The discovery cutoff deadline is currently March 6, 2024.
4           4.      Trial is set for April 5, 2024.
5                                                STIPULATION
6           The Parties, by and through their respective counsel of record, hereby stipulate and agree as
7    follows:
8           1.      The discovery cutoff is extended to March 26, 2024.
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10          IT IS SO STIPULATED.
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                                                        LAW OFFICE OF JAMES K. COBB
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15                                                                   ys for Plaintiff
                                                                    K KIMBERLY
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            3/5/2024
     Dated: ----------                                  KAUFMAN DOLOWICH LLP
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                                                                     Kartikey Pradhan
                                                         By--------------­
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                                                            Tad A. Devlin
22                                                          Kartikey A. Pradhan
                                                            Attorneys for Defendants
23                                                          NORTH BAY ANIMAL SERVICES and
                                                            MARK SCOTT
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                        THE PARTIES' JOINT STIPULATION AND ORDER TO EXTEND DISCOVERY CUTOFF
 1                                                ORDER
 2         GOOD CAUSE APPEARING, the Court hereby approves the Parties' Joint Stipulation to
 3   Extend Discovery Cutoff.
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 5         IT IS SO ORDERED.
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     Dated: ---------
 9                                                       JUDGE OF THE SUPERIOR COURT
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                      THE PARTIES' JOINT STIPULATION AND ORDER TO EXTEND DISCOVERY CUTOFF
 1                                          PROOF OF SERVICE

 2                             Mark Kimberly v. North Bay Animal Services
                            Sonoma County Superior Court Case No. SCV-269151
 3

 4           I am employed in the County of San Francisco, State of California. I am over the age of 18
     and not a party to this action. My business address is 425 California Street, Suite 2100, San
 5   Francisco, California 94104. On the execution date below and in the manner stated herein, I served
     the following documents:
 6       1. THE PARTIES’ JOINT STIPULATION AND ORDER TO EXTEND DISCOVERY
             CUTOFF
 7   on all interested parties in this action by placing [ ] the original or [X] a true copy of the original
 8   thereof enclosed in sealed envelopes addressed as follows:

 9     James K. Cobb
       Kay Wright
10     250 D Street, Suite 200
       Santa Rosa, CA 95404
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       Telephone: (707) 571-8112
12     Facsimile: (707) 571-0218
       Email: jcobblawoffice@gmail.com
13     kaywright@pacbell.net

14     Attorneys for Plaintiff
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     [X]    BY ELECTRONIC TRANSMISSION Based on a court order or an agreement of the parties
17   to accept service by e-mail or electronic transmission, I caused the documents to be sent to the
     person(s) at the e-mail address(es) so indicated on the attached list. I did not receive, within a
18   reasonable time after the transmission, any electronic message or other indication that the
     transmission was incomplete or unsuccessful.
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20   [X]    (STATE) I declare under penalty of perjury under the laws of the State of California that the
     above is true and correct.
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            Executed on March 5, 2024, at San Francisco, California.
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24                                                 ___________________________
                                                   Gisselle Castillo
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                                               PROOF OF SERVICE