Moore v. Dollar Tree Stores, Inc. et al.

Filing 55

STIPULATION and ORDER to Continue Date for Pretrial Conference and Request for Telephonic Appearance, Signed by District Judge Lawrence J. O'Neill on 12/3/2014. The Pretrial Conference set for 1/8/2015 is CONTINUED to 1/15/2015 at 08:30 AM in Courtroom 4 before District Judge Lawrence J. O'Neill. Counsel is permitted to appear telephonically at this conference. (Arellano, S.)

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1 2 3 4 5 6 Tanya E. Moore, SBN 206683 MOORE LAW FIRM, P.C. 332 North Second Street San Jose, California 95112 Telephone (408) 298-2000 Facsimile (408) 298-6046 Email: tanya@moorelawfirm.com Attorneys for Plaintiff Ronald Moore 12 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP A Limited Liability Partnership Including Professional Corporations GREGORY F. HURLEY, Cal. Bar No. 126791 ghurley@sheppardmullin.com MICHAEL J. CHILLEEN, Cal. Bar No. 210704 mchilleen@sheppardmullin.com 650 Town Center Drive, 4th Floor Costa Mesa, California 92626-1993 Telephone: 714.513.5100; Facsimile: 714.513.5130 13 Attorneys for Defendant DOLLAR TREE STORES, INC. 7 8 9 10 11 14 15 UNITED STATES DISTRICT COURT 16 EASTERN DISTRICT OF CALIFORNIA 17 18 RONALD MOORE, 19 20 21 22 23 24 Plaintiff, vs. DOLLAR TREE STORES, INC., dba DOLLAR TREE, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) No. 1:13-cv-01336-LJO-BAM STIPULATION TO CONTINUE DATE FOR PRE-TRIAL CONFERENCE AND REQUEST FOR TELEPHONIC APPEARANCES; ORDER 25 26 27 28 STIPULATION TO CONTINUE DATE OF PRE-TRIAL CONFERENCE; ORDER Page 1 1 2 3 4 5 6 WHEREAS, the pre-trial conference in this matter is currently scheduled for January 8, 2015; WHEREAS, counsel for Plaintiff, Ronald Moore (“Moore”), will be out of the country on January 8, 2015 and unable to attend the pre-trial conference as currently scheduled; WHEREAS, the Court has indicated its availability for January 15, 2015 at 8:30 a.m. for the pre-trial conference; and 7 WHEREAS, Moore’s counsel’s office is in San Jose, California, and Defendant, Dollar 8 Tree Stores, Inc. (“Dollar Tree”)’s counsel’s office is in Costa Mesa, California – both a 9 significant distance from the Fresno courthouse. Accordingly, counsel for Moore and Dollar 10 Tree both request that they be able to appear at the pre-trial conference by telephone in order to 11 save the parties significant fees and costs. 12 NOW, THEREFORE, Moore and Dollar Tree, by and through their respective attorneys 13 of record, hereby stipulate and agree to continue the pre-trial conference from January 8, 2015 14 to January 15, 2015 at 8:30 a.m., subject to Court approval. 15 Counsel for Moore and Dollar Tree hereby further request that they be permitted to 16 appear telephonically at the pre-trial conference, such appearance to be arranged by Moore’s 17 counsel through AT&T teleconference services who will have trial counsel on the line prior to 18 conferencing in chambers at 8:30 a.m. 19 IT IS SO STIPULATED AND REQUESTED. 20 21 22 23 Date: December 3, 2014 MOORE LAW FIRM, P.C. /s/ Tanya E. Moore Tanya E. Moore Attorneys for Plaintiff, Ronald Moore 24 25 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP 26 27 28 /s/ Gregory F. Hurley Gregory F. Hurley Attorneys for Defendant Dollar Tree Stores, Inc. dba Dollar Tree STIPULATION TO CONTINUE DATE OF PRE-TRIAL CONFERENCE; ORDER Page 2 1 ORDER 2 3 The parties having so stipulated and good cause appearing, 4 IT IS HEREBY ORDERED that the pre-trial conference be continued from January 8, 5 2015 to January 15, 2015 at 8:30 a.m. 6 IT IS FURTHER ORDERED that all counsel may appear telephonically at the pre-trial 7 conference, such appearances to be arranged by counsel for Plaintiff by ensuring both trial 8 counsel are on the line prior to conferencing in chambers at the designated time. 9 10 11 12 IT IS SO ORDERED. Dated: /s/ Lawrence J. O’Neill December 3, 2014 UNITED STATES DISTRICT JUDGE 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STIPULATION TO CONTINUE DATE OF PRE-TRIAL CONFERENCE; ORDER Page 3

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