Free Motion to Amend/Correct - District Court of California - California

Case 3:07-cv-02125-W-AJB

Document 10

Filed 01/30/2008

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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 Attorneys for Plaintiffs

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

CHRIS KOHLER, Plaintiff, vs. PETCO ANIMAL SUPPLIES STORES, INC., et al, Defendants.

) ) No. 07cv2125 W (AJB) ) ) ) Joint Motion to Amend the ) Complaint ) ) ) ) ) ) ) ) ) )

The parties, subject to approval of the Court, stipulate as follows: 1. Plaintiff brought this action concerning Petco Store #927 and the parking lot and common area adjacent to it located at 3875 Mission Avenue, Oceanside, California. 2. It has come to plaintiff's attention that defendants Jones-Horakh, LLC and Janet P. Horakh, Trustee of the Janet P. Horakh Living Trust Dated March 8, 1995 were improperly named in this suit.
Kohler v. Petco Animal Supplies Stores, Inc. Joint Motion to Amend the Complaint Case No. 07cv2125 W (AJB)

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Case 3:07-cv-02125-W-AJB

Document 10

Filed 01/30/2008

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3. Plaintiff now wishes to name Golden Eagle Management, LLC as a defendant, as they are the correct party. 4. Plaintiff has attached hereto as Exhibit A a true and correct copy of the Proposed Amended Complaint. 5. The parties hereby stipulate, good cause being shown, that the Complaint should be amended to include this new entity. 6. Defendant Petco Animal Supplies Stores, Inc. shall not be required to file an Answer to the Amended Complaint; their initial answer shall be deemed responsive. Dated: January 30, 2008 DISABLED ADVOCACY GROUP, APLC

/s/ Lynn Hubbard, III, Esquire LYNN HUBBARD, III Attorneys for Plaintiffs

Dated: January 29, 2008

MAZZARELLA CALDARELLI, LLP

/s/ Michael Fabiano, Esquire MICHAEL FABIANO Attorneys for Defendant Petco Animal Supplies Stores, Inc.

Kohler v. Petco Animal Supplies Stores, Inc. Joint Motion to Amend the Complaint

Case No. 07cv2125 W (AJB)

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