Borromeo v. 99 Cents Only Stores

Filing 9

STIPULATION and ORDER 8 extending time signed by Judge Morrison C. England, Jr. on 4/6/2011. Defendant 99 Cents Only Stores may responde to Complaint by filing Motion to Compel Arbitration no later than 4/29/2011. Any further response to Complaint is DEFERRED until Motion is resolved. (Marciel, M)

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-KJN Borromeo v. 99 Cents Only Stores Doc. 9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MALCOLM A. HEINICKE (SBN 194174) Malcolm.Heinicke@mto.com VICTORIA L. BOESCH (SBN 228561) Victoria.Boesch@mto.com MUNGER, TOLLES & OLSON LLP 560 Mission Street Twenty-Seventh Floor San Francisco, CA 94105-2907 Telephone: (415) 512-4000 Facsimile: (415) 512-4077 Attorneys for Defendant 99 CENTS ONLY STORES UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA IRENE BORROMEO, Plaintiff, vs. CASE NO. 2:11-cv-00149-MCE-KJN STIPULATION AND ORDER EXTENDING TIME TO RESPOND TO COMPLAINT Judge: Hon. Morrison C. England, Jr. 99 CENTS ONLY STORES, Defendant. 13575801.1 STIP AND [PROPOSED] ORDER TO EXTEND COMPLAINT-RESPONSE TIME 2:11-CV-00149 -MCE-KJN Dockets.Justia.com 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 13575801.1 In accordance with Eastern District of California Local Rule 144(a), the parties hereby agree to and seek court approval of an extension of time for Defendant 99 Cents Only Stores to respond to Plaintiff Irene Borromeo's Complaint in this action. The requested extension follows an initial 28-day extension agreed upon by the parties. This further extension will allow the parties to meet and confer about potentially staying this action pending arbitration. The parties believe that it may conserve judicial resources to meet and confer in this manner, potentially avoiding unnecessary motion practice. In the event that the parties are unable to resolve this issue through meeting and conferring, they agree that Defendant 99 Cents Only Stores may respond to the Complaint by filing a motion to compel arbitration by April 29, 2011, with any further response to the Complaint deferred until that motion is resolved. DATED: March 31, 2011 Munger, Tolles & Olson LLP MALCOLM A. HEINICKE VICTORIA L. BOESCH By: s/ Victoria L. Boesch VICTORIA L. BOESCH Attorneys for Defendant 99 CENTS ONLY STORES DATED: March 31, 2011 Legal Aid Society Employment Law Center ELIZABETH KRISTEN TAMIKA LA KUE BUTLER By: s/ Elizabeth Kristen (authorized 3/31/11) ELIZABETH KRISTEN Attorneys for Plaintiff IRENE BORROMEO - 1- STIP AND [PROPOSED] ORDER TO EXTEND COMPLAINT-RESPONSE TIME 2:11-CV-00149 -MCE-KJN 1 2 3 4 5 6 7 8 9 10 DEAC_Signature-END: In accordance with the foregoing stipulation, the Court orders that Defendant 99 Cents Only Stores may respond to Plaintiff Irene Borromeo's Complaint by filing a motion to compel arbitration by April 29, 2011, with any further response to the Complaint deferred until that motion is resolved. IT IS SO ORDERED. Dated: April 6, 2011 __________________________________ MORRISON C. ENGLAND, JR UNITED STATES DISTRICT JUDGE 11 04if0d0-fkhfkh 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 13575801.1 - 2- STIP AND [PROPOSED] ORDER TO EXTEND COMPLAINT-RESPONSE TIME 2:11-CV-00149 -MCE-KJN

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