Hernandez v. Trinity Technology Group, Inc. et al

Filing 17

STIPULATION AND ORDER RESETTING CMC FROM 11/4/09 TO 12/23/09 re 16 Notice (Other) filed by Trinity Technology Group, LLC, Trinity Technology Group, Inc.. Signed by Judge Edward M. Chen on 11/2/09. (bpf, COURT STAFF) (Filed on 11/2/2009)

1 JOANA L. BROOKS (State Bar No. 182986)
JACKSON LEWIS LLP
2 199 Fremont Street, 10th Floor

San Francisco, California 94105
3 Telephone: [phone]
Facsimile: 415.394.9401

4 Email: brooksi(qiacksonlewis.com
5 Attorneys for Defendants

TRINITY TECHNOLOGY GROUP, INC. and 6 TRINITY TECHNOLOGY GROUP, LLC,
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8

UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA - SAN FRACISCO DIVISION

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PHILIP HERNANDEZ, an individual,
Plaintiff,
v.

Case No. C 09-02412 EMC

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TRINITY TECHNOLOGY GROUP, INC., A VIRGINIA CORPORATION; TRINITY TECHNOLOGY GROUP, LLC, A VIRGINIA LIMITED LIABILITY COMPANY; and DOES 1 through 10, inclusive,
Defendants.

NOTICE OF TENTATIVE SETTLEMENT AND JOINT STIPULATION TO CONTINUE CASE MAAGEMENT CONFERENCE; AND (PROPOSED) ORDER
Date: November 4, 2009

Time: 1 :30 p.m.
Dept.: Courtroom C, 15th Floor

Judge: Honorable Edward M. Chen

19 TO THE HONORABLE COURT:

20 IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiff Philip
21 Hernandez ("Plaintiff') and Defendants Trinity Technology Group, Inc. and Trinity Technology
22 Group, LLC (collectively, "Defendants" or the "Parties"), by and through their respective counsel 23 of record, as follows:

24 WHEREAS, a Case Management Conference in this matter was originally set for
25 October 7, 2009 and continued to November 4, 2009 to give the parties time to conclude

26 settlement negotiations; and
27 WHEREAS, Plaintiff and Defendants continue to be engaged in the negotiation of a fair,

28 reasonable, and adequate settlement; and
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NOTICE OF TENTATIVE SETTLEMENT AN JOINT STIPULATION

TO CONTIN CASE MANAGEMENT CONFERENCE

Case No. C 09-02412 EMC

WHEREAS. the Parties have reached a tentative agreement on terms otthe settlement and
"1

still require additional time to finalize the written settlement agreement; and

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WHEREAS. the Parties believe an additional 30 days will enable them to finalize the
tentative settlement and allow dismissal of the action without further Court involvement.

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THE PARTIES THEREFORE STIPULATE AND PROPOSE AS FOLLOWS:
The Case Management Conference in this matter be continued for a period of at least 30
days to a date convenient on the Court's calendar.

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IT IS SO STIPULATED.
Dated:
,:1

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10

.2009

LAW OFFICES OF MICHAEL L. TRAC''i'
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By:

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Megan Ross Ilutdiins Attorneys for Plaintiff
PHILIP HERNANDEZ

Dated: )Q -:........3.9

.2009

JACKSON LEWIS LLP

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BY~~_
"rRINITY "rECHNOLOGY GROUP and
TRINITY TECllNOLOGY GROUP. LLC

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FOR GOOD CAUSE APPEARING. IT IS IlEREBY ORDERED:
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2.
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That the Case Management con ftrcnce set for November 4, 2009 is continued to
_u____..__.____.___________________________' 2009 at I :30 p.m.

December 23

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UNIT ED

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Dated:

November 2, 2009

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TO CONTI:-UE CASE MA:-i\CìF~IENT CONI:ERENCE

Case No. C 09-02412 EMC

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