Gonzalez v. Two Jinn, Inc.

Filing 14

STIPULATION and ORDER for Continuance of Hearings Scheduled for August 15, 2011 signed by Judge Oliver W. Wanger on 7/27/2011. ( 8 Motion to Compel Arbitration and to Stay Proceedings and 10 Motion for Intradistrict Transfer Hearing previously set for 8/15/2011 have been CONTINUED to 9/12/2011 at 10:00 AM in Courtroom 3 (OWW) before Judge Oliver W. Wanger) (Figueroa, O)

1 FRED M. PLEVIN (SBN 126185)
[e-mail]

2 JEFFREY P. AMES (SBN 234871)
[e-mail]

3 PAUL, PLEVIN, SULLIVAN & CONNAUGHTON LLP
401 B Street, Tenth Floor

4 San Diego, California 92101-4232
Telephone:

5 Facsimile:

619-237-5200
619-615-0700

6 Attorneys for Defendant
TWO JINN, INC.

7

DAVID D. DEASON (SBN 207733)

8 [e-mail]

MATTHEW F. ARCHBOLD (SBN 210369)

9 [e-mail]
DEASON & ARCHBOLD

10 3300 Irvine Avenue, Suite 245
Newport Beach, CA 92660
949-794-9560
Facsimile:
949-794-9517

11 Telephone:
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Attorneys for Individual and Representative Plaintiff

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

16 MODESTA GONZALEZ, individually,

CASE NO. 1:11-CV-00205-OWW-GSA

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STIPULATION AND ORDER FOR
CONTINUANCE OF HEARINGS
SCHEDULED FOR AUGUST 15, 2011

and on behalf of the general public and all
others similarly situated,
Plaintiffs,

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v.

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20 TWO JINN, INC., a California corporation
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doing business as “Aladdin Bail Bonds;”
and DOES 1 through 10, inclusive

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Judge:
Courtroom:
Complaint Filed:
Trial Date:

Hon. Oliver W. Wanger
#3 (7th Floor)
February 4, 2011
Not set

Defendants.

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Plaintiff Modesta Gonzalez, as represented by her counsel, David D. Deason

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25 of Deason & Archbold, and Defendant Two Jinn, Inc., d/b/a Aladdin Bail Bonds
26 (“Aladdin”), as represented by Jeffrey P. Ames of Paul, Plevin, Sullivan &
27 Connaughton LLP, hereby enter into the following stipulation (“Stipulation”):
28 / / /
PAUL, PLEVIN,
SULLIVAN &
CONNAUGHTON LLP

STIPULATION FOR CONTINUANCE OF
HEARINGS SCHEDULED FOR AUGUST 15, 2011

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1:11-CV-00205-OWW-GSA

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WHEREAS, on July 7, 2011, Aladdin filed its Petition to Compel

2 Arbitration and to Stay Proceedings Pending Arbitration (“Petition to Compel
3 Arbitration”), currently set for hearing on August 15, 2011.
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WHEREAS, on July 13, 2011, Plaintiff filed her Motion to Transfer

5 Pursuant to 28 USC §1404(a) (“Motion to Transfer”), also set for hearing on
6 August 15, 2011.
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WHEREAS the parties are currently engaged in good faith discussions that

8 may result in resolution of this lawsuit, which would obviate the need for either
9 hearing.
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WHEREAS the parties need additional time to resolve certain issues that are
necessary to determine whether the lawsuit will be resolved.
WHEREAS the parties agree that a thirty (30) day continuance on the
hearings scheduled for August 15, 2011 would promote the interest of judicial
economy and may avoid unnecessary expenditures of party time and resources.
NOW, THEREFORE, the parties hereto stipulate as follows:
1. The hearing on Aladdin’s Petition to Compel Arbitration and
Plaintiff’s Motion to Transfer shall be continued from August 15,
2011 to September 12, 2011.
2. The corresponding briefing schedule for both the Petition to Compel
Arbitration and Motion to Transfer shall also be continued in
accordance with the Local Rules.
IT IS SO AGREED.

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Dated: July 26, 2011

PAUL, PLEVIN, SULLIVAN &
CONNAUGHTON LLP

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By: /s/ Jeffrey P. Ames
FRED M. PLEVIN
JEFFREY P. AMES
Attorneys for Defendant
Two Jinn, Inc.

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PAUL, PLEVIN,
SULLIVAN &
CONNAUGHTON LLP

STIPULATION FOR CONTINUANCE OF
HEARINGS SCHEDULED FOR AUGUST 15, 2011

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1:11-CV-00205-OWW-GSA

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Dated: July 26, 2011

DEASON & ARCHBOLD

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By: /s/ David D. Deason
DAVID D. DEASON
MATTHEW F. ARCHBOLD
Attorneys for Individual and
Representative Plaintiff

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IT IS SO ORDERED.

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Dated:

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July 27, 2011

/s/ Oliver W. Wanger
UNITED STATES DISTRICT JUDGE

DEAC_Signature-END:

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PAUL, PLEVIN,
SULLIVAN &
CONNAUGHTON LLP

STIPULATION FOR CONTINUANCE OF
HEARINGS SCHEDULED FOR AUGUST 15, 2011

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1:11-CV-00205-OWW-GSA