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STIPULATION AND [PROPOSED] ORDER TO CONTINUE

HEARING ON DEFENDANTS’ MOTION FOR MONETARY

SANCTIONS...

CIV.S-04-0755 GEB PAN

-1-

ROBERT L. MEZZETTI II, SBN 114282

MEZZETTI LAW FIRM, INC.

31 East Julian Street

San Jose, California 95112

(408) 279-8400 / (408) 279-8448 fax

Attorney for Defendants THE WILLIFORD 

FAMILY PARTNERSHIP, L.P., a California 

limited partnership

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF CALIFORNIA

SUSAN BOWMAN, an individual; and

DISABILITY RIGHTS ENFORCEMENT

EDUCATION SERVICES; HELPING YOU

HELP OTHERS, a California public benefit

corporation,

Plaintiffs,

v.

BEST WESTERN STATION HOUSE INN;

THE WILLIFORD FAMILY PARTNERSHIP,

L.P. a California limited partnership; BEST

WESTERN INTERNATIONAL, INC., an

Arizona corporation and LEWIS T. 

WILLIFORD an individual dba BEST

WESTERN STATION HOUSE INN, 

Defendants.

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NO. CIV.S-04-0755 GEB PAN

STIPULATION AND [PROPOSED] ORDER TO

CONTINUE HEARING ON DEFENDANTS’

MOTION FOR MONETARY SANCTIONS

AGAINST THOMAS E. FRANKOVICH AND

THE FRANKOVICH GROUP

CURRENTLY SCHEDULED FOR:

Date: February 27, 2006

Time: 9:00 a.m.

Dept.: 10

Hon. Hon. Garland E. Burrell, Jr.

Plaintiff, through her undersigned counsel, and Defendants, through their undersigned counsel,

respectfully submit the following:

WHEREAS, the Hearing on the the above-captioned matter is currently scheduled for February

27, 2006, at 9:00 a.m., and the Reply Brief is currently due no later than February 17, 2006;

WHEREAS, Plaintiff, by and through her counsel, due to an inadvertent uploading and/or

technical error, did not receive until February 15, 2006, certain Exhibits to the Declaration of Robert L.

Mezzetti II filed with the subject Motion and have not had adequate time to review and respond to said

exhibits; and

Case 2:04-cv-00755-GEB-PAN Document 56 Filed 02/22/06 Page 1 of 3
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STIPULATION AND [PROPOSED] ORDER TO CONTINUE

HEARING ON DEFENDANTS’ MOTION FOR MONETARY

SANCTIONS...

CIV.S-04-0755 GEB PAN

-2-

WHEREAS, in the interests of justice and judicial economy a continuance is warranted;

THE PARTIES HEREBY STIPULATED AND REQUEST THAT THE COURT GRANT THE

FOLLOWING:

1. That the Hearing on the Motion for Monetary Sanctions shall be continued until March

27, 2006, at 9:00 a.m., in Department 10 of the above-entitled court.

2. Plaintiff’s Supplement Opposition papers regarding the missing exhibits “D” and “E”

shall be filed and served by no later than March 6, 2006.

3. Defendants’ Reply papers shall be filed and served by no later that March 13, 2006.

IT IS SO STIPULATED.

It is further stipulated by and between counsel that this document may be executed in

counterparts and sent by facsimile with the same force and effect of an original signature.

DATED:________________, 2006 MEZZETTI LAW FIRM, INC.

BY__________________________________

 ROBERT L. MEZZETTI II

Attorneys for Defendant THE WILLIFORD

FAMILY PARTNERSHIP, L.P., a California

limited partnership

DATED:________________, 2006 THOMAS E. FRANKOVICH

A PROFESSIONAL LAW CORPORATION

BY__________________________________

 Julia M. Adams

Attorneys for Plaintiff, SUSAN BOWAN

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE

HEARING ON DEFENDANTS’ MOTION FOR MONETARY

SANCTIONS...

CIV.S-04-0755 GEB PAN

-3-

DATED:________________, 2006 BONETATI, SASAKI, KINCAID & KINCAID,

INC.

BY__________________________________

 Laura M. Sasaki

Attorneys for Defendant BEST WESTERN

INTERNATIONAL, INC.

ORDER

IT IS SO ORDERED.

Dated: February 21, 2006

/s/ Garland E. Burrell, Jr.

GARLAND E. BURRELL, JR.

United States District Judge

Case 2:04-cv-00755-GEB-PAN Document 56 Filed 02/22/06 Page 3 of 3