Chevron Global Technology Services Company et al v. Little

Filing 67

STIPULATION AND ORDER TO FURTHER STAY PROCEEDINGS AND CONTINUE CASE MANAGEMENT CONFERENCE. The Case Management Conference is continued to June 12, 2009. Signed by Judge Maxine M. Chesney on November 25, 2008. (mmclc2, COURT STAFF) (Filed on 11/25/2008)

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Michele Ballard Miller (SBN 104198) [e-mail] Lisa C. Hamasaki (SBN 197628) [e-mail] Katherine L. Kettler (SBN 231586) [e-mail] MILLER LAW GROUP A Professional Corporation 111 Sutter Street, Suite 700 San Francisco, CA 94104 Tel. [phone] Fax [phone]

A PROFESSIONAL CORPORATION SAN FRANCISCO, CALIFORNIA

MILLER LAW GROUP

7 Attorneys for Plaintiffs CHEVRON GLOBAL TECHNOLOGY SERVICES COMPANY, 8 (formerly known as CHEVRONTEXACO GLOBAL TECHNOLOGY SERVICES COMPANY) 9 and CHEVRON INTERNATIONAL EXPLORATION AND PRODUCTION COMPANY (formerly known as 10 CHEVRONTEXACO OVERSEAS PETROLEUM), a Division of CHEVRON U.S.A. INC. 11 Lisa Tan (SBN 228326) 12 [e-mail] RUSSAKOW | RYAN | JOHNSON 13 A Professional Law Corporation 225 S. Lake Avenue, 10th Floor 14 Pasadena, CA 91101 Tel. [phone] Fax [phone] Attorneys for Defendant MICHAEL S. LITTLE 17 18 19 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA Case No. C 06 3157 MMC STIPULATION AND [PROPOSED] ORDER TO FURTHER STAY PROCEEDINGS AND CONTINUE CASE MANAGEMENT CONFERENCE Complaint Filed: May 11, 2006

CHEVRON GLOBAL TECHNOLOGY 20 SERVICES COMPANY, (formerly known as CHEVRONTEXACO GLOBAL 21 TECHNOLOGY SERVICES COMPANY) and CHEVRON INTERNATIONAL 22 EXPLORATION AND PRODUCTION COMPANY (formerly known as 23 CHEVRONTEXACO OVERSEAS PETROLEUM), a Division of 24 CHEVRON U.S.A. INC. 25 26 v. 27 MICHAEL S. LITTLE, 28 Defendant.
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Plaintiffs,

STIPULATION AND [PROPOSED] ORDER TO FURTHER STAY PROCEEDINGS AND CONTINUE CMC Case No. C 06 3157 MMC

1 2 (CHEVRON

Plaintiffs CHEVRON GLOBAL TECHNOLOGY SERVICES COMPANY "GLOBETECH"), SERVICES AND formerly known as CHEVRONTEXACO CHEVRON ("CIEP"), GLOBAL

3 TECHNOLOGY 4 EXPLORATION

COMPANY,

and

INTERNATIONAL known as

PRODUCTION

COMPANY

formerly

5 CHEVRONTEXACO OVERSEARS PETROLEUM, a division of CHEVRON U.S.A. INC. 6 (referred to collectively as "Plaintiffs") and Defendant Michael S. Little, through their 7 respective counsel agree and stipulate as follows: 8 1. This is a diversity action for breach of contract and the implied covenant

9 of good faith and fair dealing in which Plaintiffs contend that by filing a lawsuit against 10 Plaintiffs in Venezuela ­ instead of California ­ Defendant breached forum selection clauses 11 entered into by the parties. 12 13
A PROFESSIONAL CORPORATION SAN FRANCISCO, CALIFORNIA

2. 3.

Defendant denies Plaintiffs' allegations. On August 10, 2007, a Venezuela court dismissed Defendant's case

MILLER LAW GROUP

14 against Plaintiffs on the merits. 15 4. On or about December 4, 2007, the Venezuelan appellate level court

16 denied Defendant's appeal. 17 5. In December 2007, Defendant appealed to the Venezuelan Supreme

18 Tribunal of Justice. 19 6. The parties have been informed that the Venezuelan Supreme Court

20 could take as many as 12 months to rule on Defendant's appeal. 21 22 appeal. 23 8. At the parties' further Case Management Conference held on 7. The Venezuelan Supreme Court has not yet ruled on the Defendant's

24 September 7, 2007, this Court vacated trial and related dates pending the outcome of the 25 parties' Venezuelan litigation. 26 9. In light of the fact that the appeal is ongoing, the parties agree and

27 request of the Court that all proceedings remain stayed until the Venezuelan litigation is 28 concluded.
STIPULATION AND [PROPOSED] ORDER TO FURTHER STAY PROCEEDINGS AND CONTINUE CMC Case No. C 06 3157 MMC

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10.

Further the parties agree and request of the Court that the Case

2 Management Conference scheduled for December 5, 2008, at 10:30 a.m., be continued to a 3 date at least six months from the date of this filing, at which time the parties will provide the 4 Court with a status update. 5 IT IS SO STIPULATED: 6 7 8 9 10 11 12 13
A PROFESSIONAL CORPORATION SAN FRANCISCO, CALIFORNIA

Dated: November 21, 2008

MILLER LAW GROUP A Professional Corporation By: /s/ Katherine L. Kettler Attorneys for Plaintiffs CHEVRON GLOBAL TECHNOLOGY SERVICES COMPANY, (formerly known as CHEVRONTEXACO GLOBAL TECHNOLOGY SERVICES COMPANY) and CHEVRON INTERNATIONAL EXPLORATION AND PRODUCTION COMPANY(formerly known as CHEVRONTEXACO OVERSEAS PETROLEUM), a Division of CHEVRON U.S.A. INC.

MILLER LAW GROUP

14 15 16 Dated: November 21, 2008 17 18 19 20 21 22

RUSSAKOW/ RYAN/ JOHNSON A Professional Law Corporation By: /s/ Lisa Tan Attorneys for Defendant MICHAEL S. LITTLE

ORDER IT IS HEREBY ORDERED that this action shall be further stayed until the

23 Venezuelan litigation is concluded, and the Case Management Conference scheduled for
June 12, 2009 24 December 5, 2008 at 10:30 a.m. shall be continued until __________________. The parties shall file a Joint Case Management Conference Statement no later than June 5, 2009. 25 November 25, 2008 Dated ___________________ ____________________________ 26 Hon. Maxine M. Chesney United States District Court Judge 27

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STIPULATION AND [PROPOSED] ORDER TO FURTHER STAY PROCEEDINGS AND CONTINUE CMC Case No. C 06 3157 MMC

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