Equal Employment Opportunity Commission v. Cadit Company, Inc.

Filing 11

ORDER continuing cmc to 12/5/08. Signed by Judge Illston on 9/19/08. (ts, COURT STAFF) (Filed on 9/22/2008)

Case 3:08-cv-03151-SI

Document 10

Filed 09/18/2008

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THEODORA R. LEE [e-mail] LITTLER MENDELSON, P.C. 650 California Street, 20th Floor San Francisco, CA 94108-2693 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant CADIT COMPANY, INC. WILLIAM R. TAMAYO (SB# 084965) DAVID F. OFFEN-BROWN (SB# 063321) RAYMOND T. CHEUNG (SB# 176086) [e-mail] EQUAL EMPLOYMENT OPPORTUNITY COMMISSION San Francisco District Office 350 The Embarcadero, Suite 500 San Francisco, CA 94105-1260 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff EQUAL EMPLOYMENT OPPORTUNITY COMMISSION UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, Plaintiff, vs. CADIT COMPANY, INC., Defendant.

CASE NO. C-08-03151 SI STIPULATION TO EXTEND TIME FOR FILING RULE 26(F) REPORT, COMPLETE INITIAL DISCLOSURES, FILE CASE MANAGEMENT STATEMENT, AND INITIAL CASE MANAGEMENT CONFERENCE; DECLARATION OF RAYMOND T. CHEUNG IN SUPPORT THEREOF; AND [PROPOSED] ORDER

Case No. C-08-03151 SI

STIPULATION TO EXTEND TIME; DECL. OF R. CHEUNG; AND [PROPOSED] ORDER

Case 3:08-cv-03151-SI

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Pursuant to Northern District of California Local Rule 6-2(a), it is hereby stipulated by and between the parties hereto, though their respective counsel, that:

1.

The last day on which to file Rule 26(f) Report, complete initial disclosures

or state objection in Rule 26(f) Report and file Case Management Statement to be continued from September 26, 2008 to November 14, 2008; and

2.

The scheduling of the Initial Case Management Conference to be continued

from October 3, 2008 to December 5, 2008.

DATED: September 18, 2008

LITTLER MENDELSON, LLP

By: /s/ Theodora R. Lee THEODORA R. LEE Attorneys for Defendant CADIT COMPANY, INC. DATED: September 18, 2008 EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

By: /s/ Raymond T. Cheung RAYMOND T. CHEUNG Attorneys for Plaintiff

Case No. C-07-4810 CRB

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STIPULATION TO EXTEND TIME; DECL. OF R. CHEUNG; AND [PROPOSED] ORDER

Case 3:08-cv-03151-SI

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Case No. C-08-03151 SI

DECLARATION OF RAYMOND T. CHEUNG

I, Raymond T. Cheung, declare:

1.

I am an attorney at law licensed to practice before this Court. I am an

attorney for Plaintiff Equal Employment Opportunity Commission. If called as a witness, I would and could competently testify thereto to all facts within my personal knowledge except where stated upon information and belief.

2.

On July 1, 2008, the Court issued an order setting initial case management

conference and ADR deadlines. The Court scheduled September 26, 2008as the last day on which to file Rule 26(f) Report, complete initial disclosures or state objection in Rule 26(f) Report and file Case Management Statement.

3.

The Court also scheduled the Initial Case Management Conference for

October 3, 2008 at 2:00 p.m.

4.

Consistent with L.R. 6-2(a), the parties request through this Stipulation and

[Proposed] Order a continuance of the above schedule.

5. September 3, 2008.

The parties informally exchanged initial disclosure documents on

6.

The parties engaged in multiple substantive settlement discussions,

including an in-person settlement conference on September 11, 2008. The parties reached a tentative settlement agreement at that time and are in the process of finalizing the terms of the settlement.

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STIPULATION TO EXTEND TIME; DECL. OF R. CHEUNG; AND [PROPOSED] ORDER

Case 3:08-cv-03151-SI

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7.

The parties have not previously sought nor has the Court ordered a

continuance of the case scheduling or time modification in this matter.

8.

The stipulated proposed continuance would not have a substantive effect

on the scheduling of this case and may have a positive effect on judicial economy by allowing the parties to resolve the matter without imposing any additional burden on the court's resources.

I declare under penalty of perjury under the laws of the State of California and the United States that the foregoing is true and correct.

Executed this 18th day of September, 2008 at San Francisco, California.

/s/ Raymond T. Cheung ____________________________________ RAYMOND T. CHEUNG

[PROPOSED] ORDER PURSUANT TO STIPULATION, IT IS SO ORDERED. DATED: ________________ _________________________________________ Hon. SUSAN ILLSTON Judge, United States District Court

Case No. C-08-03151 SI

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STIPULATION TO EXTEND TIME; DECL. OF R. CHEUNG; AND [PROPOSED] ORDER