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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1 2 3 4 5 6 Michele Ballard Miller (SBN 104198) mbm@millerlawgroup.com Lisa C. Hamasaki (SBN 197628) lch@millerlawgroup.com Katherine L. Kettler (SBN 231586) klk@millerlawgroup.com MILLER LAW GROUP A Professional Corporation 111 Sutter Street, Suite 700 San Francisco, CA 94104 Tel. (415) 464-4300 Fax (415) 464-4336 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 ltan@rrjlaw.com RUSSAKOW | RYAN | JOHNSON 13 A Professional Law Corporation 225 S. Lake Avenue, 10th Floor 14 Pasadena, CA 91101 Tel. (626) 683-8869 15 Fax (626) 683-8870 16 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. 1 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 2 1 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 28 STIPULATION AND [PROPOSED] ORDER TO FURTHER STAY PROCEEDINGS AND CONTINUE CMC Case No. C 06 3157 MMC 3

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