Angulo v. Matheson Postal Services et al

Filing 31

STIPULATION AND ORDER CONTINUING SETTLEMENT CONFERENCE. Signed by Magistrate Judge Bernard Zimmerman on 11/19/2008. (bzsec, COURT STAFF) (Filed on 11/19/2008)

HENRY E. FARBER (CA State Bar No. 110553) 1 DAVIS WRIGHT TREMAINE LLP 777 108th Avenue NE 2 Bellevue, Washington 98004-5149 Telephone: [phone] Facsimile: [phone] [e-mail] 4 AARON ROBLAN (CA State Bar No. 244308) 5 DAVIS WRIGHT TREMAINE LLP 505 Montgomery Street, Suite 800 6 San Francisco, California 94111-6533 Telephone: [phone] Facsimile: [phone] [e-mail] 8 Attorneys for Defendants 9 MATHESON POSTAL SERVICES, INC. and MARCO BARRAGAN 10 11

DAVIS WRIGHT TREMAINE LLP

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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. ) ) 0 0 ) ) Case No. C08-00146 BZ STIPULATION TO CONTINUE SETTLEMENT CONFERENCE BEFORE HON. WAYNE D. BRAZIL Date: November 19, 2008

Judge Bernard Zimmerman

Pursuant to Civil L.R. 7-12, the parties, through their undersigned counsel, stipulate as follows:

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STIPULATION DWT 12141686v1 0050734-000018

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By Order of the court, a Settlement Conference was previously scheduled to occur

2 on November 20, 2008 before Judge Wayne D. Brazil. 3 2. The Parties Stipulate and Agree that it is in their mutual best interest, and will

4 further their efforts to informally resolve this matter, to continue the Settlement Conference to a 5 date to be determined by the filing of a future stipulation of the parties, if necessary. This 6 continuation will permit the parties the appropriate time to attempt complete discovery and seek 7 resolution of this matter without the need for trial. 8 3. Accordingly, the Parties jointly request the Court enter an Order taking the present

9 Settlement Conference off calendar and continuing said conference to a date to be determined. 10 11

DAVIS WRIGHT TREMAINE LLP

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STIPULATION DWT 12141686v1 0050734-000018

Respectfully submitted, DAVIS WRIGHT TREMAINE LLP By: /s/ Aaron Roblan Aaron Roblan

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Attorneys for Defendants MARCO BARRAGAN and MATHESON POSTAL SERVICES, INC. TENAX LAW GROUP By:
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/s/ Christopher Arras Christopher Arras

Attorneys for the Plaintiff JORGE ANGULO

PURSUANT TO STIPULATION, IT IS SO ORDERED: November 19, 2008 Date: _____________________ _________________________ Hon. Bernard Zimmerman

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Proof of Service

I, Christina Karo, declare under penalty of perjury under the laws of the State of California 3 that the following is true and correct: 4 I am employed in the City and County of San Francisco, State of California, in the office of a member of the bar of this court, at whose direction the service was made. I am over the age of 5 eighteen (18) years, and not a party to or interested in the within-entitled action. I am an employee of DAVIS WRIGHT TREMAINE LLP, and my business address is 505 Montgomery Street, Suite 6 800, San Francisco, California 94111-6533. 7 8 9 10 11 I caused to be served the following document: STIPULATION TO CONTINUE SETTLEMENT CONFERENCE BEFORE HON. WAYNE D. BRAZIL I caused the above document to be served on each person on the attached list by the following means: I enclosed a true and correct copy of said document in an envelope and placed it for collection and mailing with the United States Post Office on November 19, 2008 following the ordinary business practice. (Indicated on the attached address list by an [M] next to the address.) I enclosed a true and correct copy of said document in an envelope, and placed it for collection and mailing via Federal Express on [ ], for guaranteed delivery on [ ], following the ordinary business practice. (Indicated on the attached address list by an [FD] next to the address.) I consigned a true and correct copy of said document for facsimile transmission on _____________. (Indicated on the attached address list by an [F] next to the address.) I enclosed a true and correct copy of said document in an envelope, and consigned it for hand delivery by messenger on (Indicated on the attached address list by an [H] next to the address.)

DAVIS WRIGHT TREMAINE LLP

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I am readily familiar with my firm's practice for collection and processing of 21 correspondence for delivery in the manner indicated above, to wit, that correspondence will be deposited for collection in the above-described manner this same day in the ordinary course of 22 business. 23 24 25 26 27 28
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STIPULATION DWT 12141686v1 0050734-000018

Executed on November 19, 2008, at San Francisco, California. /s/ Christina Karo Christina Karo

1 2 3 4 5 6 7 8 9 10 11 [M] John W. Schilt Christopher Arras Tenax Law Group LLP 145 Park Place, Suite A Point Richmond, CA 94801
Key: [M] Delivery by Mail [F] Delivery by Facsimile

Service List
[FD] Delivery by Federal Express [FM] Delivery by Facsimile and Mail [H] Delivery by Hand

Attorneys for Plaintiff

DAVIS WRIGHT TREMAINE LLP

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STIPULATION DWT 12141686v1 0050734-000018