U.S. Equal Employment Opportunity Commission v. Dash Dream Plant Inc.

Filing 31

ORDER RE JOINT STATUS UPDATE AND REQUEST FOR EXTENSION OF TIME. The Court hereby grants the parties requested extension and orders the parties to file the settlement documents or a status update by August 31, 2017. Signed by Magistrate Judge Stanley A. Boone on 7/27/2017. (Hernandez, M)

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Anna Y. Park, CA SBN 164242
Sue Noh, CA SBN 192134
Rumduol Vuong, CA SBN 264392
Jennifer L. Boulton, CA SBN 259076
U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION
255 East Temple Street, Fourth Floor
Los Angeles, CA 90012
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Plaintiff
U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION

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Raimondo & Associates, A Law Corporation
Anthony Raimondo, CA SBN 200387
[e-mail]
Gerardo V. Hernandez, CA SBN 292809
[e-mail]
7080 N. Marks Avenue, Suite 117
Fresno, California 93711
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
Dash Dream Plant, Inc.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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)
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Plaintiff,
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vs.
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DASH DREAM PLANT, INC., and Does 1- )
10 inclusive,
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Defendant(s).
)
U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION,

Case No.: 1:16-CV-01395-DAD-EPG
JOINT STATUS UPDATE AND
REQUEST FOR EXTENSION OF
TIME; ORDER

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Plaintiff Equal Employment Opportunity Commission (the “EEOC”) and Defendant

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Dash Dream Plant, Inc. (“Defendant”) by and through their counsel of record, hereby submit a

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Joint Status Report and Request for Extension of Time to the Court.
The parties respectfully request that this Court grant the parties’ request for a thirty (30)

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day extension of time from the current deadline of July 31, 2017 to file the final settlement

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documents as good cause exists for such an extension. As relevant here, since the parties’ April

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27, 2017 settlement conference, the parties have worked towards finalizing the proposed consent

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decree and to that end, have exchanged drafts of the proposed decree. While the parties are

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committed to finalizing the decree, the parties’ efforts have been delayed by myriad events,

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including the recent birth of defense counsel’s child, heavy workloads, and prescheduled

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vacation/leave time. The parties’ efforts to finalize the settlement documents have also been

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delayed due to a recent disagreement as to some of the material terms of the consent decree. To

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resolve the matter, the parties first discussed the disputed terms via telephone. Unable to reach

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agreement, the parties then agreed to request a copy of the transcript from the settlement

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proceedings. On July 13, 2017, the parties received a copy of the transcript from the settlement

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proceedings. Although the transcript has facilitated resolution of some of the disputed terms;

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additional time is needed to finalize the terms of the consent decree, particularly with respect to

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the guaranties. Lastly, additional time is needed so that the parties can focus on resolving this

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matter as opposed to diverting attention and resources towards litigating this matter. Providing

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the parties with addition time would not only help to preserve the parties’ resources but also help

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to preserve the Court’s limited resources.

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As such, the parties respectfully request that the Court, for good cause, grant the parties’
request for an extension of time.

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Respectfully submitted,
Dated: July 27, 2017

_/s/ Jennifer L. Boulton _____
Jennifer L. Boulton,
Trial Attorney
U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION

Dated: July 27, 2017

_/s/ Gerardo V. Hernandez ___
Gerardo V. Hernandez
Attorney for Defendant
Dash Dream Plant Inc.

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ORDER

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GOOD CAUSE APPEARING:

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The Court hereby grants the parties’ requested extension and orders the parties to file the

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settlement documents or a status update by August 31, 2017.

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IT IS SO ORDERED.
Dated:

July 27, 2017
UNITED STATES MAGISTRATE JUDGE

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