US Equal Employment Opportunity Commission v. Hospital Housekeeping Systems of Houston, Inc.

Filing 53

STIPULATION to Extend Deadline to Submit Consent Decree; ORDER - to extend deadlines is hereby approved and the parties shall submit an agreed proposed consent decree or their letter briefing addressing the disputed terms of the consent decree on or before 12/9/2013. signed by Magistrate Judge Barbara A. McAuliffe on 12/3/2013. (Herman, H)

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Anna Y. Park, CA SBN 164242
Rumduol Vuong, CA SBN 264392
U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION
255 East Temple Street, Fourth Floor
Los Angeles, CA 90012
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorney for Plaintiff
U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION
UNITED STATES DISTRICT COURT
EATERN DISTRICT OF CALIFORNIA

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U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION,

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Plaintiff,

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vs.
HOSPITAL HOUSKEEPING SYSTEMS,
LTD., HOSPITAL HOUSEKEEPING
SYSTEMS OF HOUSTON, INC,
HOSPITAL HOUSEKEEPING SYSTEMS,
INC., HOSPITAL HOUSKEEPING
SYSTEMS, LLC, AND DOES 1-10,
INCLUSIVE,

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Defendant(s).

) Case No.: 1:11-CV-1658 LJO BAM
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) STIPULATION TO EXTEND DEADLINE
) TO SUBMIT CONSENT DECREE
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Plaintiff United States Equal Employment Opportunity Commission (“EEOC” or

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“Plaintiff”) and Defendants Hospital Housekeeping Systems Inc. and Hospital Housekeeping

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Systems, LLC (“Defendants”), through their respective counsel of record herein, hereby

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respectfully request a one week continuance of the deadline to submit a proposed consent decree.

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On November 21, 2013, the Court adopted the Magistrate Judge’s Findings and

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Recommendations and granted Defendants’ motion to enforce. The Court ordered that the

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parties meet and confer and submit a proposed consent decree or a letter addressing the disputed

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terms on or before December 2, 2013.

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The parties have attempted to engage meaningfully in the meet and confer process and

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consult with their respective clients.

However, such efforts have been hampered by the

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Thanksgiving holiday and the unavailability of counsel for other reasons.

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plaintiff’s counsel was on two weeks leave (November 18, 2013 to November 29, 2013) to care

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for a family member and defense counsel is unavailable for most of today.

For instance,

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The parties thereby request an extension of the current deadline to submit the consent

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decree by one week. An extension would permit the parties to resolve several, if not all, of the

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remaining issues, thereby either decreasing the number of issues the parties will need to submit

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to the Court or resolution or permitting the parties to submit a final consent decree.

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Stipulation to Extend Deadlines

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The parties stipulate that the Scheduling Order be amended to reflect the following new

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deadlines:
1. The parties shall submit an agreed proposed consent decree or their letter briefing
addressing the disputed terms of the consent decree on or before 12/9/2013.

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IT IS SO STIPULATED.
U.S. EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION

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Date: December 3, 2013

By:

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/s/ Rumie Vuong
Rumie Vuong
Attorney for Plaintiff U.S. EEOC

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FULLBRIGHT & JAWORSKI LLP

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Date: December 3, 2013

By:

/s/
Julie M. Capell
Attorney for Defendants Hospital Housekeeping
Systems Inc. and Hospital Housekeeping Systems,
LLC

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ORDER
For good cause shown, the stipulation to extend discovery deadlines is hereby approved

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and the parties shall submit an agreed proposed consent decree or their letter briefing addressing

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the disputed terms of the consent decree on or before December 9, 2013.

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IT IS SO ORDERED.

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Dated:

/s/ Barbara

December 3, 2013

A. McAuliffe

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UNITED STATES MAGISTRATE JUDGE

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