Angulo v. Matheson Postal Services et al

Filing 34

ORDER setting Status Conference for March 30, 2009 at 4:00p.m. 33 Stipulation to stay all proceedings pending further notice filed by Matheson Postal Services, Marco Barragan. Signed by Magistrate Judge Bernard Zimmerman on 2/6/09. (sv, COURT STAFF) (Filed on 2/6/2009)

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HENRY E. FARBER (CA State Bar No. 110553) 1 DAVIS WRIGHT TREMAINE LLP 777 108th Avenue NE 2 Bellevue, Washington 98004-5149 Telephone: (425) 646-6100 3 Facsimile: (425) 646-6199 henryfarber@dwt.com 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: (415) 276-6500 7 Facsimile: (415) 276-6599 aaronroblan@dwt.com 8 Attorneys for Defendants 9 MATHESON POSTAL SERVICES, INC. and MARCO BARRAGAN 10 11 DAVIS WRIGHT TREMAINE LLP 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 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 TO STAY ALL PROCEEDINGS PENDING FURTHER NOTICE Date: Time: February 5, 2009 2:00 p.m. Hon. Bernard Zimmerman Pursuant to Civil L.R. 7-12, the parties, through their undersigned counsel, stipulate as follows: 1 STIPULATION TO STAY ALL PROCEEDINGS PENDING FURTHER NOTICE DWT 12424925v1 0050734-000018 1 1. By Order of the court, dated December 12, 2008, the trial date and pre-trial 2 conference in this matter were vacated. 3 2. The Parties continue to be engaged in efforts to resolve this matter amicably. The 4 Parties agree that it is in their mutual best interest, and the interest of judicial efficiency that: 5 6 7 3. all proceedings in this Court be stayed for a period of 45 days; all previously ordered trial and pre-trial deadlines be vacated; During the 45 day period of stay, the Parties will make all best efforts to resolve 8 this matter through settlement negotiations, including private mediation, if necessary. 9 4. In the event that settlement is not reached within 45 days of the filing of the present 10 Stipulation, the Parties will file a request for a scheduling conference, scheduling order and trial DAVIS WRIGHT TREMAINE LLP 11 date with the Court. 12 5. In the event that a new scheduling order and trial date is entered, the Parties will 13 proceed with the present litigation under the new scheduling order and will make no requests for 14 continuance or delay of that scheduling order, without good and sufficient cause. 15 16 17 18 19 20 21 22 23 24 25 26 27 28 // // // // 6. Accordingly, the Parties jointly request the Court enter an Order as follows: All proceedings in the present matter are stayed for a period of 45 days following the filing of the above stipulation; All previously ordered pre-trial and trial deadlines are vacated; The Parties are required, no later than 45 days following the filing of the above Stipulation, to file with the Court, a stipulation of dismissal of the present action, or a request for entry of a new scheduling order in the present matter. 2 STIPULATION TO STAY ALL PROCEEDINGS PENDING FURTHER NOTICE DWT 12424925v1 0050734-000018 1 2 3 4 5 6 7 8 9 10 11 Respectfully submitted, DAVIS WRIGHT TREMAINE LLP By: /s/ Aaron Roblan Aaron Roblan 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 . DAVIS WRIGHT TREMAINE LLP 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PURSUANT TO STIPULATION, IT UNIT ED ISTRIC ES D TC AT T IS SO ORDERED: RT U O S _________________________ Hon. Bernard Zimmerman E C RN F D IS T IC T O R 3 STIPULATION TO STAY ALL PROCEEDINGS PENDING FURTHER NOTICE DWT 12424925v1 0050734-000018 A LI FO Judge B ernard Z immerm an R NIA Date: _____________________ February 6, 2009 a Status Conference is scheduled for March 30, 2009 at 4:00p.m. NO RT H

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