Levine et al v. Sleep Train, Inc. et al

Filing 26

STIPULATION and ORDER 24 for continuance signed by Senior Judge William B. Shubb on 4/14/2015. Status Conference is RE-SET for 5/11/2015 at 2:00 PM in Courtroom 5 (WBS). A Joint Case Management Conference Statement shall be due 2 weeks prior to Conference on 4/27/2015. (Marciel, M)

1
2
3
4
5
6
7
8

CELIA MCGUINNESS, Esq. (SBN 159420)
PAUL L. REIN, Esq. (SBN 43053)
CATHERINE CABALO, Esq. (SBN 248198)
LAW OFFICES OF PAUL L. REIN
200 Lakeside Drive, Suite A
Oakland, CA 94612
Telephone:
510/832-5001
Facsimile:
510/832-4787
[e-mail]
Attorneys for Plaintiffs
ROBERT LEVINE and VERONICA GUZMAN
* Defendants’ counsel listed after the caption.

9

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

10
11
12

ROBERT LEVINE and VERONICA
GUZMAN,

13
14
15
16
17
18
19
20
21
22
23
24
25
26
27

Plaintiffs,
v.

CASE NO. CV 15-00002 WBS
Civil Rights
STIPULATION AND [PROPOSED] ORDER
TO CONTINUE STATUS CONFERENCE
DATE

THE SLEEP TRAIN, INC.; LIVE NATION
ENTERTAINMENT, INC.; COASTAL
BREEZE LIMOUSINE, LLC; BGE YUBA,
LLC; and DOES 1-20, Inclusive,
Defendants.
SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
A Limited Liability Partnership
Including Professional Corporations
GREGORY F. HURLEY, Cal. Bar No. 126791
[e-mail]
BRADLEY J. LEIMKUHLER, Cal. Bar No. 261024
[e-mail]
650 Town Center Drive, 4th Floor
Costa Mesa, California 92626-1993
Telephone: [phone]
Facsimile: 714.513.5130
Attorneys for Defendants
LIVE NATION ENTERTAINMENT, INC.
and THE SLEEP TRAIN, INC.

28
29
30

STIPULATION AND [PROPOSED] ORDER
TO CHANGE DATE OF STATUS CONFERENCE
CASE NO. C15-00002 WBS

-1-

G:\DOCS\SHU\DSHU2\inBOX\Signed\15cv2 Levine - Stip to Cont Schedg Conf.docx

1

TO THE CLERK OF THE ABOVE-ENTITLED COURT AND TO ALL PARTIES AND TO

2

THEIR RESPECTIVE ATTORNEYS OF RECORD:

3

STIPULATION
Plaintiffs Robert Levine and Veronica Guzman (“Plaintiffs”) through their counsel of record

4
5

make this unopposed request that the Court continue the Status Conference from April 27, 2015, to

6

May 11, 2015, or a date thereafter that is agreeable to the Court. This request is based on the

7

following good cause:
1. Plaintiffs’ counsel is scheduled to take a deposition in another matter on April 27, 2015, that

8
9

was scheduled before the Court set this Status Conference.

10

2. It would be difficult to reschedule the deposition because of the deadlines in the other case

11

and because of the number of attorneys and others involved.

12

3. A delay in the Status Conference in this case will allow the parties to make progress on

13

discovery and planning, which will make them more prepared to discuss the case in detail.

14

4. All parties are available for a Status Conference on May 11, 2015.

15

5. Defendants Live Nation Entertainment, Inc. and The Sleep Train, Inc. (“Defendants”) do not

16

oppose this request.

17

Therefore, Plaintiffs hereby make this unopposed request, through their counsel, that this

18

Court continue the date of the Status Conference from April 27, 2015, to May 11, 2015, or a date

19

thereafter agreeable to the Court and the Joint Status Conference Statement shall be due two weeks

20

prior to the conference.

21
22
23

Date: April 13, 2015

LAW OFFICE OF PAUL L. REIN

24
By: /s/ Celia McGuinness
CELIA McGUINNESS, ESQ.
Attorneys for Plaintiffs
ROBERT LEVINE and VERONICA GUZMAN

25
26
27

//

28
29
30

STIPULATION AND [PROPOSED] ORDER
TO CHANGE DATE OF STATUS CONFERENCE
CASE NO. C15-00002 WBS

-2-

G:\DOCS\SHU\DSHU2\inBOX\Signed\15cv2 Levine - Stip to Cont Schedg Conf.docx

1

Date: April 13, 2015

2

SHEPPARD, MULLIN, RICHTER & HAMPTON
LLP

3
By: /s/ Bradley J. Leimkuhler
BRADLEY J. LEIMKUHLER, ESQ.
Attorneys for Defendants
LIVE NATION ENTERTAINMENT, INC.
and THE SLEEP TRAIN, INC.

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
29
30

STIPULATION AND [PROPOSED] ORDER
TO CHANGE DATE OF STATUS CONFERENCE
CASE NO. C15-00002 WBS

-3-

G:\DOCS\SHU\DSHU2\inBOX\Signed\15cv2 Levine - Stip to Cont Schedg Conf.docx

1
2

ORDER
Pursuant to stipulation, and for good cause shown, IT IS SO ORDERED.

3

The Case Management Conference in the above captioned case is hereby moved from April 27,

4

2015, to May 11, 2015 at 2:00 p.m. A Joint Case Management Conference statement shall be due

5

two weeks prior to the conference on April 27, 2015

6
7

Dated: April 14, 2015

8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30

STIPULATION AND [PROPOSED] ORDER
TO CHANGE DATE OF STATUS CONFERENCE
CASE NO. C15-00002 WBS

-4-

G:\DOCS\SHU\DSHU2\inBOX\Signed\15cv2 Levine - Stip to Cont Schedg Conf.docx