U.S. Equal Employment Opportunity Commission v. Pape Material Handling, Inc. et al

Filing 57

JOINT STIPULATION TO EXTEND THE DEADLINE FOR THE PARTIES TO FILE PROPOSED CONSENT DECREE AND ORDER signed by Magistrate Judge Barbara A. McAuliffe on 5/2/19. (Lundstrom, T)

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RYAN L. EDDINGS, Bar No. 256519
[e-mail]
ANDREW H. WOO, Bar No. 261120
[e-mail]
LITTLER MENDELSON, P.C.
5200 North Palm Avenue, Suite 302
Fresno, CA 93704.2225
Telephone: [phone]
Facsimile: 559.244.7525
Attorneys for Defendant
PAPE MATERIAL HANDLING, INC.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION,
Plaintiff,

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v.
PAPE MATERIAL HANDLING,
INC.,
Defendants.

Case No. 1:17-CV-01291-AWI-BAM
JOINT STIPULATION TO EXTEND
THE DEADLINE FOR THE
PARTIES TO FILE THE
PROPOSED CONSENT DECREE;
AND ORDER
Complaint Filed: September 27, 2017

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TO THE HONORABLE DISTRICT COURT JUDGE, MAGISTRATE
JUDGE, PLAINTIFF, AND ALL ATTORNEYS OF RECORD:

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Plaintiff United States Equal Employment Opportunity Commission

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(“Plaintiff”) and Defendant Pape Material Handling, Inc. (“Defendant”), through their

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respective counsel of record, hereby submits this Joint Stipulation for the Court to

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extend the deadline for the Parties to file the Proposed Consent Decree from May 2,

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2019 to May 9, 2019.

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As previously stated, the Plaintiff and Defendant (hereinafter collectively

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“Parties”) were able to reach a settlement on September 20, 2018, and have agreed in

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principle to the monetary amount and major terms of the injunctive remedies. (ECF

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LITTLE R MEND ELSO N, P .C .
5200 N orth Palm Avenue
Suite 302
Fresno, CA 93704.2225
559.244.7500

Joint Stip. to Extend Deadline to File
Consent Decree; Order

CASE NO. 1:17-CV-01291-AWI-BAM

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No. 38) Per the Parties’ request, the Court ordered the Parties to file the Proposed

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Consent Decree no later than May 2, 2019. (ECF No. 55).

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During this time, the Parties have finalized the many details of the

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Proposed Consent Decree and its exhibit. While the Parties have worked diligently, the

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Parties need a one-week extension to have the Proposed Consent Decree executed by

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all Parties.

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As such, good cause exists to extend the deadline to file the Proposed

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Consent Decree, as such action would minimize costs and conserve judicial resources

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to concentrate on finalizing the Proposed Consent Decree. Furthermore, the requested

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continuance will not result in any undue delay or prejudice to either party.
Accordingly, the Parties request that this Court extend the May 2,

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2019 deadline for the Parties to file the Proposed Consent Decree to May 9, 2019.

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Dated: May 2, 2019

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U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION

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By: /s/ Lorena Garcia-Bautista
LORENA GARCIA-BAUTISTA
Attorneys for Plaintiff U.S. EEOC

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Dated: May 2, 2019

LITTLER MENDELSON, P.C.

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By: /s/ Ryan L. Eddings
RYAN L. EDDINGS
Attorneys for Defendant
PAPE MATERIAL HANDLING,
INC.

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I, Ryan L. Eddings, certify that the content of this document is acceptable

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to all persons required to sign the document as I obtained authorization for the

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electronic signatures of all parties on the document.

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LITTLE R MEND ELSO N, P .C .
5200 N orth Palm Avenue
Suite 302
Fresno, CA 93704.2225
559.244.7500

Joint Stip. to Extend Deadline to File
Consent Decree; Order

2.

CASE NO. 1:17-CV-01291-AWI-BAM

ORDER

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Pursuant to the parties’ stipulation, and good cause appearing, IT IS HEREBY

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ORDERED that the deadline to file the Proposed Consent Decree and other settlement

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documents is extended to May 9, 2019. No further extensions of time shall be granted

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absent a demonstrated showing of good cause.

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IT IS SO ORDERED.
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Dated:

/s/ Barbara

May 2, 2019

A. McAuliffe

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UNITED STATES MAGISTRATE JUDGE

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LITTLE R MEND ELSO N, P .C .
5200 N orth Palm Avenue
Suite 302
Fresno, CA 93704.2225
559.244.7500

Joint Stip. to Extend Deadline to File
Consent Decree; Order

3.

CASE NO. 1:17-CV-01291-AWI-BAM