Heatherly et al v. Kirin Restaurant/Chu's Family et al

Filing 12

STIPULATION AND ORDER re 10 STIPULATION RESETTING CASE MANAGEMENT CONFERENCE SET FOR JUNE 19, 2012 filed by Irma Ramirez, Daren Heatherly Case Management Statement due by 9/18/2012. Initial Case Management Conference set for 9/25/2012 10:00 AM in Courtroom E, 15th Floor, San Francisco. Signed by Judge Elizabeth D Laporte on 6/14/2012. (kns, COURT STAFF) (Filed on 6/14/2012)

1
2
3
4
5

THOMAS E. FRANKOVICH (State Bar No. 074414)
THOMAS E. FRANKOVICH,
A Professional Law Corporation
4328 Redw2ood Hwy, Suite 300
San Rafael, CA 94903
Telephone:
415/444-5800
Facsimile:
415/674-9900
Attorneys for Plaintiff
DAREN HEATHERLY; and IRMA RAMIREZ

6
7

UNITED STATES DISTRICT COURT

8

NORTHERN DISTRICT OF CALIFORNIA

9
10
11
12
13
14
15
16
17
18

)
)
)
)
Plaintiffs,
)
)
v.
)
KIRIN RESTAURANT/CHU’S FAMILY; )
)
CHU’S FAMILY CORPORATION, a
)
California Corporation dba KIRIN
)
RESTAURANT; and S&N COMPANY - )
)
ANNADEL LTD., a California Limited
)
Partnership,
)
)
Defendants.
)
___________________________________ )
DAREN HEATHERLY; and IRMA
RAMIREZ,

CASE NO. CV-11-5292-EDL
STIPULATION AND [PROPOSED]
ORDER RESETTING CASE
MANAGEMENT CONFERENCE SET FOR
JUNE 19, 2012

19
The parties, by and through their respective counsel, stipulate to continue the Case

20
21

Management Conference set for June 19, 2012, at 10:00 a.m.
Whereas, the parties have reached an agreement on the injunctive component of this case

22
23

(attached as Exhibit “A” is the executed Equitable Agreement); and

24

Whereas, on May 29, 2012, plaintiff filed a notice of need for mediation; and

25

Whereas, the parties are actively attempting to negotiate a settlement on the monetary

26

component in the above-referenced case, and wish to reduce fees, costs and litigation expenses in

27

so doing. The parties are hopeful that they will be able to reach an agreement; and

28

///
STIPULATION AND [PROPOSED] ORDER RESETTING CASE MANAGEMENT CONFERENCE SET FOR JUNE 19, 2012
CV-11-5292-EDL

1

Whereas, the parties believe it would be in the interests of efficient and economical to

1
2

continue the Case Management Conference.

3

Therefore, the parties respectfully request that the Case Management Conference set for

4

June 19, 2012, at 10:00 a.m. be continued up to and including ninety (90) days and/or a date that

5

is convenient to the court.
IT’S SO STIPULATED.

6
7

Respectfully submitted,

8
9

Dated: June 13, 2012

THOMAS E. FRANKOVICH
A PROFESSIONAL LAW CORPORATION

10
11

By: ___/s/Thomas E. Frankovich____________

12
13

Thomas E. Frankovich

14

Attorney for Plaintiffs DAREN HEATHERLY and

15

IRMA RAMIREZ

16

///

17

///

18

///

19

///

20

///

21

///

22

///

23

///

24

///

25

///

26

///

27

///

28

///
STIPULATION AND [PROPOSED] ORDER RESETTING CASE MANAGEMENT CONFERENCE SET FOR JUNE 19, 2012
CV-11-5292-EDL

2

September 25
10:00

June 14