Vega et al v. Weeks Wholesale Rose Grower, Inc.

Filing 65

STIPULATION and ORDER to Extend all Deadlines in Case. Deadline to complete depositions of key parties: 2/16/10. Deadline to file motion for class certification: 2/24/10. Deadline to complete all discovery: 4/26/10. Non-Dispositive Motions due by: 4/26/10. Dispositive Motions due by 6/8/10. Pretrial Conference set for 7/16/2010 at 01:30 PM in Courtroom 9 (DLB) before Magistrate Judge Dennis L. Beck. Jury Trial set for 9/14/2010 at 09:00 AM in Courtroom 9 (DLB) before Magistrate Judge Dennis L. Beck. Order signed by Magistrate Judge Dennis L. Beck on 12/14/2009. (Timken, A)

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STAN S. MALLISON (SBN 184191) HECTOR R. MARTINEZ (SBN 206336) LAW OFFICES OF MALLISON & MARTINEZ 1042 Brown Avenue, Suite A Lafayette, CA 94549 Telephone: [phone] Facsimile: [phone] [e-mail] [e-mail] Attorneys for PLAINTIFFS MICHAEL C. SAQUI (SBN 147853) ANDREW H. LEE (SBN 257403) THE SAQUI LAW GROUP 1615 Bunker Hill Way, Suite 240 Salinas, California 93906 Telephone: [phone] Facsimile: [phone] [e-mail] [e-mail] Attorneys for DEFENDANT

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA FRESNO DIVISION

SERGIO VEGA, ALFONSO RIVERA, JUAN MORALES, EMILIANO ARMENTA, PEDRO RIOS, and JOSE NAVA on behalf of themselves and all others similarly situated, PLAINTIFFS, vs.

Case No. 1:07-cv-00225- DLB CLASS ACTION STIPULATION TO EXTEND ALL DEADLINES IN CASE AND PROPOSED ORDER

WEEKS WHOLESALE ROSE GROWER, INC., doing business as "Weeks Wholesale Rose Grower" and "Weeks Roses," DEFENDANT

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Case No. 1:07-cv-000225-DEB

Stipulation to Extend All Deadlines in Case and Proposed Order

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Plaintiffs Sergio Vega, et al. and Defendant Weeks Wholesale Grower Inc., hereby stipulate as follows: 1. On July 1, 2009, the Court conducted a status teleconference at the parties' request regarding discovery disputes and scheduling of mediation. Following the conference, the Court adopted scheduling deadlines as referenced under the Minutes Order of July 1, 2009 (Doc. 61). 2. Defendant's current financial status has severely impacted Defendant's ability to litigate all cases against Defendant, including but not limited to the case at present. Stoel Rives, outside and separate counsel for Defendant has unilaterally engaged Plaintiffs' counsel in a global settlement of all claims against Defendant. 3. The parties previously request a temporary stay of litigation and extension of all key deadlines pending continued due diligence on the part of Plaintiffs' counsel as to the current financial status of Defendant as well as the settlement offer currently on the table. 4. After meeting and conferring, the parties agree that a 90-day extension of all key deadlines would be practical, efficient, and fair to all parties. 5. Accordingly, the parties request to extend all key deadlines in the case as follows: Deadline to complete depositions of key parties: Deadline to file motion for class certification: Hearing: Deadline to complete all discovery: Non-Dispositive Motions due by: Hearing: Dispositive motions due by: Hearing: Pretrial conference: Jury Trial: 2/16/10 2/24/10 4/06/10 4/26/10 4/26/10 5/17/10 6/08/10 7/02/10 7/16/10, 1:30PM 9/14/10, 9:00AM, CR 9

The parties stipulate as to this new proposed deadlines as set forth above, and respectfully request that this Court sign the below attached proposed order which reflects this change. The parties request that if this court has any questions or concerns with regard to this stipulation, that a conference call be arranged to address these concerns and to explain further the reasons for Case No. 1:07-cv-000225-TAG -2Stipulation to Extend All Deadlines in Case for Purposes of Mediation; Order Thereon

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this extension.

DATED: November 24, 2009

LAW OFFICES OF MALLISON & MARTINEZ By: /s/ Stan S. Mallison Stan S. Mallison Hector R. Martinez Attorneys for Plaintiffs THE SAQUI LAW GROUP By: /s/ Andrew H. Lee Michael C. Saqui Andrew H. Lee Attorneys for Defendant

DATED: November 24, 2009

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Case No. 1:07-cv-000225-TAG

Stipulation to Extend All Deadlines in Case for Purposes of Mediation; Order Thereon

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-4Case No. 1:07-cv-000225-TAG Stipulation to Extend All Deadlines in Case for Purposes of Mediation; Order Thereon

The parties having so stipulated and GOOD CAUSE APPEARING, that the schedule for this case is hereby amended as set forth above.

IT IS SO ORDERED. Dated:
DEAC_Signature-END:

December 14, 2009

/s/ Dennis

L. Beck

UNITED STATES MAGISTRATE JUDGE 3b142a