J&J Sports Productions, Inc v. Nguyen et al

Filing 59

ORDER, Initial Case Management Conference set for 11/30/12 is continued to 1/11/2013 02:30 PM in Courtroom 10, 19th Floor, San Francisco. Signed by Judge Susan Illston on 11/27/12. Motions terminated: 58 STIPULATION WITH PROPOSED ORDER For an Order Continuing Case Management Conference filed by J&J Sports Productions, Inc.(tfS, COURT STAFF) (Filed on 11/28/2012)

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1 2 3 4 Kenneth N. Frucht, Esq. Frederick J. Geonetta, Esq. GEONETTA & FRUCHT, LLP 100 Montgomery Street, Suite 1600 San Francisco, CA 94104 Attorneys for Plaintiff Telephone: (415) 433.4589 Facsimile: (415) 392.7973 5 6 7 8 9 10 11 12 13 14 Attorneys for Plaintiff DAVID REY Steven R. Blackburn, State Bar No. 154797 Matthew A. Goodin, State Bar No. 169674 Lauren M. Cooper, State Bar No. 254580 EPSTEIN BECKER & GREEN, P.C. One California Street, 26th Floor San Francisco, California 94111-5427 Telephone: 415.398.3500 Facsimile: 415.398.0955 sblackburn@ebglaw.com mgoodin@ebglaw.com bbrown@ebglaw.com Attorneys for Defendants, C&H SUGAR COMPANY, INC. and AMERICAN SUGAR REFINING, INC. 15 UNITED STATES DISTRICT COURT 16 NORTHERN DISTRICT OF CALIFORNIA 17 SAN FRANCISCO DIVISION 18 19 DAVID REY, 20 21 22 23 CASE NO. CV 10-01970 SI Plaintiff, v. STIPULATION AND [PROPOSED] ORDER TO CONTINUE PRE-TRIAL CONFERENCE C&H SUGAR COMPANY, INC., a Delaware Corporation, AMERICAN SUGAR REFINING, INC., a Delaware Corporation, and DOES 1-100, inclusive, 24 Defendant. 25 26 27 The parties hereby stipulate and agree as follows: 28 WHEREAS; at the hearing on Defendants’ motion for summary judgment on October 5, 6653779v1 Stipulation and Proposed Order Re: Pretrial Conference CV 10-01970 SI 1 2012, the Court continued the trial date in this matter to January 22, 2013, the same date as the 2 trial date currently set in the matter of Leatherbury v. C&H Sugar, et al., C-10-01969 SI, and 3 informed the parties that they should choose which of the two cases would go to trial on January 4 22, 2013; WHEREAS; the parties have jointly agreed that the Rey matter should proceed to trial 5 6 on January 22, 2012; WHEREAS; the parties are awaiting a ruling on Defendants’ summary judgment motion 7 8 in this matter, and wish as much as possible to avoid unnecessary trial preparation in the event 9 Defendants’ motion for summary judgment is granted; WHEREAS; the parties do not at this time wish to continue the trial date of January 22, 10 11 2013; THE PARTIES HEREBY AGREE AND REQUEST a continuance of the Pretrial 12 13 Conference and related dates as follows: 14 Joint Pretrial Conference Statement due: December 18, 2012; 15 Pretrial Conference date: January 1, 2013; 16 17 /// 18 /// 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 28 -26653779v1 Stipulation and Proposed Order Re: Pretrial Conference Case No. CV 10-01970 SI 1 DATED: November 26, 2012 2 GEONETTA & FRUCHT, LLP By: /s/ Kenneth N. Frucht Kenneth N. Frucht, Esq. Frederick J. Geonetta, Esq. Attorneys for Plaintiffs DAVID REY 3 4 5 6 DATED: November 26, 2012 By: /s/ Matthew A. Goodin Steven R. Blackburn Matthew A. Goodin 7 8 9 Attorneys for Defendants, C&H SUGAR COMPANY, INC. and AMERICAN SUGAR REFINING, INC. 10 11 12 EPSTEIN BECKER & GREEN, P.C. [PROPOSED] ORDER IT IS HEREBY ORDERED that the pre-trial dates are continued as follows: 13 Joint Pretrial Conference Statement due: December 18, 2012; 13 at 3:30 p.,m. Pretrial Conference date: January 1, 2013; 14 15 16 17 18 19 PURSUANT TO THE STIPULATION, IT IS SO ORDERED. 11/27/12 Date: _______________ ________________________________________ JUDGE OF THE DISTRICT COURT 20 21 22 23 24 25 26 27 28 -36653779v1 Stipulation and Proposed Order Re: Pretrial Conference Case No. CV 10-01970 SI

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