Angulo v. Matheson Postal Services et al

Filing 29

STIPULATION AND ORDER. Signed by Magistrate Judge Bernard Zimmerman on 11/7/2008. (bzsec, COURT STAFF) (Filed on 11/7/2008)

CHRSTOPHER ARRAS (CA State Bar No. 169854) 1 TENAX LAW GROUP, P.C. 145 Park Place, Suite A 2 Point Richmond, CA 94801 Telephone: [phone] Facsimile: 510-234-6009 4 Attorneys for Plaintiff JORGE ANGULO 5 6 7 8 9 10 11 12 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION JORGE ANGULO, an individual, ) ) Plaintiff, ) ) v. ) ) MATHESON POSTAL SERVICES, a California ) Corporation, MARCOS BARRAGAN, and ) DOES 1-25 inclusive, ) ) Defendants. ) ) ) ) ) ) Case No. C08-00146 BZ STIPULATION AND ORDER TO CONTINUE THE DEADLINES FOR NON-EXPERT DISCOVERY AND DISPOSITIVE MOTIONS Date: Time: Hon. Bernard Zimmerman

TENAX LAW GROUP, PC

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Pursuant to Civil L.R. 7-12, the parties, through their undersigned counsel, stipulate as follows: 1. By Order of the court, dated August 28, 2008, the Parties to this action were

required to complete Non-expert Discovery by October 1, 2008. Furthermore, that same order set the deadline for hearing Dispositive Motions as November 25, 2008. Due to scheduling conflicts and attempts to resolve this matter without the need for further litigation, the Parties require additional time to complete discovery in this matter. The parties have participated in an Early Neutral Evaluation, conducted by John Beers, Esq. Pursuant to the ENE, it is believed by the parties, counsel and evaluator that the case has a much improved chance of settling; however, the key deadlines (and necessarily the trial date) need to be continued in order to eliminate the need for unnecessary attorneys' fees and costs which would detract from the potential for a settlement.
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STIPULATION RE TRIAL AND PRE-TRIAL DEADLINES

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2.

The Parties Stipulate and Agree that an extension of the deadline for Non-Expert

2 Discovery to December 31, 2008 and an extension of the deadline for Dispositive Motions to 3 February 27, 2009 will permit them the appropriate time to attempt complete discovery and obtain 4 a resolution by way of a settlement of this matter without the need for trial. 5 3. Accordingly, the Parties jointly request the Court enter an Order setting the

6 following deadlines and a new trial date: 7 8 9 10 11 12 Completion of Non-expert Discover by December 31, 2008 Last day for hearing Dispositive Motions, February 27, 2009 New trial date: Soonest date available after May 1, 2009 Respectfully submitted, DAVIS WRIGHT TREMAINE LLP By: /s/ Aaron Roblan Aaron Roblan

TENAX LAW GROUP, PC

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STIPULATION RE TRIAL AND PRE-TRIAL DEADLINES

Attorneys for Defendants MARCO BARRAGAN and MATHESON POSTAL SERVICES, INC.

TENAX LAW GROUP By: /s/ Christopher Arras Christopher Arras

Attorneys for the Plaintiff JORGE ANGULO

PURSUANT TO STIPULATION, IT IS SO ORDERED: Last day to hear Dispositive Motions: March 4, 2009 Trial date will be set on March 4, if necessary November 7, 2008 Date: _____________________ _________________________ Hon. Bernard Zimmerman