U.S. Equal Employment Opportunity Commission v. Timeless Investments, Inc. et al

Filing 63

STIPULATION to Continue the Due Date of the Consent Decree; and ORDER: filing of the Consent Decree extension from 10/22/2010 to 12/13/2010 - Granted. signed by Magistrate Judge Sandra M. Snyder on 10/20/2010. (Herman, H)

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YARRA, KHARAZI & ASSOCIATES 1250 Fulton Mall Fresno, CA 93721

H. Ty Kharazi, SBN 187894 YARRA, KHARAZI & ASSOCIATES 1250 Fulton Mall, Fresno, CA 93721 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant Timeless Investments, Inc.

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA FRESNO DIVISION U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, ) ) ) ) ) Plaintiff, ) ) ) v. ) ) TIMELESS INVESTMENTS, INC. dba ) EZ TRIP GOLDEN STATE SHELL, ) ) DOES 1 -10, inclusive, ) ) ) Defendant. ) ) ) ) Case No.: 1:08-CV-01469 AWI (SMS) STIPULATION TO CONTINUE THE DUE DATE OF THE CONSENT DECREE; AND ORDER Hon. Sandra M. Snyder U.S. Magistrate Judge

TO THE HONORABLE SANDRA M. SNYDER: Counsel for Plaintiff U.S. Equal Employment Opportunity Commission ("EEOC") and Defendant Timeless Investments, Inc. dba EZ Trip Golden State Shell ("Defendant"), by and through their undersigned counsels, request that this Court continue the due date of the consent decree from October 22, 2010 to forty-five to fifty (45-50) days.
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STIPULATION TO CONTINUE DUE DATE OF CONSENT DECREE; AND PROPOSED ORDER

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YARRA, KHARAZI & ASSOCIATES 1250 Fulton Mall

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YARRA, KHARAZI & ASSOCIATES 1250 Fulton Mall Fresno, CA 93721

On August 31, 2010, the parties appeared before this Court for a settlement conference and settled the case. A part the settlement includes the filing of a Consent Decree ("Decree"). The Court ordered the parties to submit the Decree by October 22, 2010. The parties are working diligently towards finalizing the Decree. A second draft of the Decree was distributed by the EEOC to Defendant on or about October 12, 2010. According to Defendant's counsel, he was engaged in a jury trial during October 8-15th at Fresno County Superior Court. Therefore, Defendant's counsel was unable to review the Decree until October 18th because of his trial schedule. On October 18, 2010 a set of revisions were proposed by Defense to the Plaintiff. The parties are very close. After taking into consideration the counsels' schedule and the issues to be resolved, the parties jointly and respectively ask for an additional forty-five to fifty (45-50) days to complete this work. The parties anticipate that the details can be worked out within that time frame and the Decree will be filed. Therefore, the parties are asking for an extension from October 22, 2010 to forty-five to fifty (45-50) days to file the Consent Decree. SO STIPULATED. Respectfully submitted, U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION Date: October_19_, 2010 By: /s/ Lorena Garcia-Bautista _____________________________ Anna Y. Park Lorena Garcia-Bautista Amrita Mallik Attorneys for Plaintiff U.S. EEOC

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YARRA, KHARAZI & ASSOCIATES 1250 Fulton Mall

STIPULATION TO CONTINUE DUE DATE OF CONSENT DECREE; AND PROPOSED ORDER

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YARRA, KHARAZI & ASSOCIATES 1250 Fulton Mall Fresno, CA 93721

YARRA, KHARAZI, & ASSOCIATES /s/ H. Ty Kharazi Date: October_19_, 2010 By: H. Ty Kharazi Attorney for Defendant Timeless Investments, Inc., et al.

ORDER GOOD CAUSE APPEARING, IT IS ORDERED THAT the parties must submit the Consent Decree by on or before December 13 , 2010.

Dated:

October 20, 2010

/s/ Sandra M. Snyder UNITED STATES MAGISTRATE JUDGE

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YARRA, KHARAZI & ASSOCIATES 1250 Fulton Mall

STIPULATION TO CONTINUE DUE DATE OF CONSENT DECREE; AND PROPOSED ORDER