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JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE TRIAL 

LYNN HUBBARD, III, SBN 69773 

SCOTTLYNN J HUBBARD, IV, SBN 212970

LAW OFFICES OF LYNN HUBBARD

12 WILLIAMSBURG LANE 

CHICO, CA. 95926 

TELEPHONE: (530) 895-3252 

FACSIMILE: (530) 894-8244 

Attorney for Plaintiff JAMES SANFORD 

UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF CALIFORNIA 

JAMES SANFORD, 

Plaintiff, 

vs. 

RED ROBIN INTERNATIONAL, INC., 

dba RED ROBIN #78, 

 

 Defendants. 

Case No. CIV.S 04-1791 

JOINT STIPULATION AND 

[PROPOSED] ORDER TO CONTINUE 

TRIAL 

Trial Date: March 28, 2006 

Honorable William B. Shubb 

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JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE TRIAL 

STIPULATION

WHEREAS, Sanford is suffering from pneumonia and a Stage II decubitus ulcer; 

WHEREAS, Sanford visited his treating physician on Friday, March 10, 2006; 

WHEREAS, that physician prescribed bed rest until Sanford’s health improves 

(i.e., 60 to 90 days); 

WHEREAS, trial counsel for defendant, Catherine Manske, will be unavailable 

and out of the country during the month of July 2006; 

THEREFORE, the parties jointly stipulate and request that this Court enter an 

order as follows: 

1. Each party shall exchange copies of all exhibits identified in the Court’s 

Pretrial Order dated March 3, 2006, by not later than August 14, 2006; 

2. The trial date of March 28, 2006 shall be continued to August 29, 2006; 

3. This stipulation shall not affect any other previously expired deadlines, 

except as set out in this stipulation. 

4. Attached is Doris Sanford’s declaration in support of a continuation of 

trial. 

IT IS SO STIPULATED. 

Dated: March 13, 2006 LAW OFFICES OF LYNN J. HUBBARD, III 

By: /s/ Lynn Hubbard, III 

 Lynn Hubbard, III 

Attorneys for Plaintiff JAMES SANFORD 

Dated: March 14, 2006 GORDON & REES 

By: /s/ Catherine Manske 

 Catherine Manske 

Attorneys for Defendant RED ROBIN 

INTERNATIONAL, INC. dba RED ROBIN # 78 

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JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE TRIAL 

ORDER

 

IT IS THEREFORE ORDERED that: 

1. Each party shall exchange copies of all exhibits identified in the Court’s 

Pretrial Order dated March 3, 2006, by not later than August 14, 2006; 

2. The trial shall be continued to August 29, 2006 at 9:00 a.m.; 

3. This stipulation shall not affect any other previously expired deadlines, 

except as set out in this stipulation. 

DATED: March 17, 2006 

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