[GSA] Munoz et al v. Giumarra Vineyards Corporation

Filing 112

STIPULATION to extend time to file objections to proposed 109 Findings and Recommendations regarding class certification ; ORDER, signed by Chief Judge Anthony W. Ishii on 7/16/2012. ( Objections to F&R due by 8/2/2012) (Figueroa, O)

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Joseph E. Herman (SBN 58899)
Law Offices of Joseph E. Herman
114 S. Rossmore Avenue
Los Angeles, CA 90004
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Joseph C. Markowitz (SBN 146592)
Law Offices of Joseph C. Markowitz
444 S. Flower Street, Suite 1750
Los Angeles, CA 90071
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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FRESNO DIVISION

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Case No.: 1:09-cv-00703-AWI-JLT

RAFAEL MUNOZ, LIDIA CRUZ, YANET )
HERNANDEZ, SANTOS R. VALENZUELA, )
TRINIDAD RUIZ, MARTA A. RINCON de )
DIAZ, RAMON CERVANTES PERALES
)
and HUGO PEREZ RIOS on behalf of
)
themselves, and all current and former
)
employees, and on behalf of a class of
)
)
similarly situated employees,
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Plaintiffs,
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vs.
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GIUMARRA VINEYARDS CORPORTION, )
a California corporation, and DOES 1-20,
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)
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Defendants.
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STIPULATION TO EXTEND TIME TO
FILE OBJECTIONS TO PROPOSED
FINDINGS AND RECOMMENDATIONS
REGARDING CLASS CERTIFICATION

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Defendant Giumarra Vineyards Corporation (“Giumarra”) and Plaintiffs stipulate and
agree to the following:

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WHEREAS, Magistrate Judge Thurston issued findings and recommendations granting in
part and denying in part plaintiffs’ motion for class certification on July 5, 2012;
WHEREAS, Defendants’ counsel Joseph E. Herman is seriously ill and has been advised
by his doctor not to work for the next two weeks;
WHEREAS, Defendants’ counsel Joseph C. Markowitz is in the process of moving his

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office. The move is scheduled for July 22, 2012, and the office will be disrupted in preparation

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for the move.

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WHEREAS, in light of these severe time constraints, and the complexity of the issues
raised by the voluminous record on the class certification, the parties need additional time to
complete their papers.
WHEREAS, the parties agree that they will continue to pursue merits-related discovery

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with Defendant continuing to make documents available to Plaintiffs and arranging for Plaintiffs

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to scan and/or copy documents beginning July 24, 2012.

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THEREFORE, IT IS HEREBY STIPULATED AND AGREED AND THE COURT IS
REQESTED TO ORDER THE FOLLOWING:
Pursuant to 28 U.S.C. §636(b) (1)(B) and (c) and Local Rule 304(b), the time

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to file objections to the findings and recommendations of Magistrate Judge Thurston dated July

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5, 2012 is extended to and including August 2, 2012.

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Dated: July 12, 2012

LAW OFFICES OF JOSEPH E. HERMAN

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By: /s/ Joseph E. Herman
Joseph E. Herman

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Dated: July 12, 2012

LAW OFFICES OF JOSEPH C. MARKOWITZ

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By: /s/ Joseph C. Markowitz
Joseph C. Markowitz
Attorneys for Defendant,
Giumarra Vineyards Corporation
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Dated: July 12, 2012

MALLISON & MARTINEZ

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By: /s/ Stan S. Mallison
Stan S. Mallison

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Attorney for Plaintiffs,

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ORDER

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IT IS SO ORDERED.

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Dated: July 16, 2012

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CHIEF UNITED STATES DISTRICT JUDGE
DEAC_Signature-END:

0m8i788

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