Ramirez et al v. Ghilotti Bros., Inc. et al

Filing 23

ORDER by Judge Charles R. Breyer granting 20 Stipulation. (crblc2, COURT STAFF) (Filed on 12/21/2012)

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JEFFER MANGELS BUTLER & MITCHELL LLP
LOUISE ANN FERNANDEZ (Bar No. 86263)
MICHAEL J. HASSEN (Bar No. 124823 )
AN NGUYEN RUDA (Bar No. 215453)
1900 Avenue of the Stars, Seventh Floor
Los Angeles, California 90067-4308
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendants GHILOTTI BROS, INC. and
GHILOTTI BROTHERS CONSTRUCTION, INC.
ROSEN BIEN GALVAN & GRUNFELD LLP
GAY CROSTHWAIT GRUNFELD (Bar No. 121944)
KATHRYN G. MANTOAN (Bar No. 239649)
JENNY S. YELIN (Bar No. 273601)
315 Montgomery Street, Tenth Floor
San Francisco, CA 94104-1823
Telephone: [phone]
Facsimile: [phone]

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ELISA J. STEWART – 219557
WENDY E. MUSELL – 203507
STEWART & MUSELL, LLP
351 California Street, Suite 700
San Francisco, California 94104
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiffs
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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JOSE RAMIREZ, LUIS GOMEZ, and
MARCK MENA ORTEGA on behalf of
themselves and all other persons
similarly situated,

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Plaintiffs,
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v.

CASE NO. 3:12-cv-04590-CRB
STIPULATION AND [PROPOSED]
ORDER RESCHEDULING CASE
MANAGEMENT CONFERENCE
AND PLAINTIFF’S MOTION FOR
LEAVE TO FILE SECOND
AMENDED COMPLAINT

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GHILOTTI BROS, INC., a corporation;
GHILOTTI BROTHERS
CONSTRUCTION, INC., a corporation,
and DOES 1 through 50, inclusive,
Defendants.

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STIPULATION AND [PROPOSED]
ORDER RESCHEDULING CASE
MANAGEMENT CONFERENCE AND
MOTION FOR LEAVE TO FILE
SECOND AMENDED COMPLAINT

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WHEREAS, the parties have agreed to conduct a Mediation at the Judicial
Arbitration and Mediation Services (“JAMS”) on January 11, 2013;

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WHEREAS, Plaintiffs filed their Motion for Leave to File Second Amended
Complaint (Dkt. No. 18) on December 7, 2012;

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WHEREAS, the parties stipulated that the time for the hearing on the Motion

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for Leave to File Second Amended Complaint be shortened so that it may be heard on

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January 4, 2013 in conjunction with the Case Management Conference as then

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scheduled, and to accommodate the Mediation (see Dkt. No. 18-3);

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WHEREAS, the stipulation to shorten time on the Motion for Leave to File the

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Second Amended Complaint was not signed by the Court, and the Motion for Leave

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to File the Second Amended Complaint is set for January 11, 2013;

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WHEREAS, the Court ordered the Case Management Conference in this action

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originally set for January 4, 2013 be continued to January 11, 2013;WHEREAS, the

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Case Management Conference and Motion hearing set for January 11, 2013 pose a

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conflict with the Mediation scheduled by the parties;

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WHEREAS, the parties have been unable to identify any other date agreeable

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to all parties and the mediator on which the Mediation could be rescheduled, payment

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has been tendered for the Mediation, and multiple individuals from both parties

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cleared scheduling conflicts so that they might attend the Mediation and make a good

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faith effort at resolution of this matter;

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NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED by and

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between the parties to the above-captioned action, through their respective counsel, as

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follows:

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The hearing on Plaintiffs’ Motion for Leave to File Second Amended

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Complaint and the Case Management Conference will be continued to January 18,

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2013.

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STIPULATION AND [PROPOSED]
ORDER RESCHEDULING CASE
MANAGEMENT CONFERENCE AND
MOTION FOR LEAVE TO FILE
SECOND AMENDED COMPLAINT

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IT IS SO STIPULATED.
DATED: December 20, 2012

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ROSEN BIEN GALVAN & GRUNFELD LLP
GAY CROSTHWAIT GRUNFELD
KATHRYN G. MANTOAN
JENNY S. YELIN

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By: /s/ Gay Crosthwait Grunfeld
GAY CROSTHWAIT GRUNFELD

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Attorneys for Plaintiffs

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DATED: December 20, 2012

JEFFER, MANGELS, BUTLER &
MITCHELL LLP
LOUISE ANN FERNANDEZ
MICHAEL J. HASSEN
AN NGUYEN RUDA
By: /s/ An Nguyen Ruda
AN NGUYEN RUDA
Attorneys for Defendants GHILOTTI BROS.,
INC. and GHILOTTI BROTHERS
CONSTRUCTION, INC.

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STIPULATION AND [PROPOSED]
ORDER RESCHEDULING CASE
MANAGEMENT CONFERENCE AND
MOTION FOR LEAVE TO FILE
SECOND AMENDED COMPLAINT

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[PROPOSED] ORDER

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The Court, having reviewed the above Stipulation of the parties, and good

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cause appearing, hereby orders as follows:

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The hearing on Plaintiffs’ Motion for Leave to File Second Amended

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Complaint and the Case Management Conference is hereby continued to January 18,

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2013.

UNIT
ED

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harle
Judge C

RT

O ORD
IT IS S

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ERED

R NIA

DATED: December 21, 2012

RT
U
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yer

s R. Bre

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LI

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_________________________________
ER
C
Charles R. Breyer
N
OF
D I S TStates District Court
Judge of the United R I C T
A

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NO

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S DISTRICT
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TA

FO

IT IS SO ORDERED.
S

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STIPULATION AND [PROPOSED]
ORDER RESCHEDULING CASE
MANAGEMENT CONFERENCE AND
MOTION FOR LEAVE TO FILE
SECOND AMENDED COMPLAINT