v. Hernandez et al

Filing 15

ORDER by Magistrate Judge Maria-Elena James granting 14 Stipulation to continue Case Management Conference. (rmm2S, COURT STAFF) (Filed on 2/15/2013)

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1 2 3 4 5 6 TOMAS E. MARGAIN (SBN 193555) HUY TRAN (SBN 288196) CASA LEGAL 84 W. SANTA CLARA STREET, STE. 790 SAN JOSE, CA 95113 TEL (408) 317-1100 FAX (408) 351-0105 Tomas@lacasalegal.com Attorney for Plaintiffs LIBORIO HERNANDEZ and ROGELIO RODRIGUEZ-PEREZ 7 8 JOANNA L. BROOKS (SBN 182986) DOUGLAS M. BRIA (SBN 226966) DAVID T. WANG (SBN 272015) JACKSON LEWIS LLP 50 California Street, 9th Floor San Francisco, CA 94111 TEL: (415) 394-9400 FAX: (415) 394-9401 brooksj@jacksonlewis.com briad@jacksonlewis.com david.wang@jacksonlewis.com Attorneys for Defendant NOR-CAL MOVING SERVICES 9 UNITED STATES DISTRICT COURT 10 FOR NORTHERN DISTRICT OF CALIFORNIA 11 SAN JOSE DIVISION 12 13 LIBORIO HERNANDEZ and ROGELIO RODRIGUEZ-PEREZ, 14 Plaintiffs, 15 16 v. 17 NOR-CAL MOVING SERVICES, 18 Defendant. 19 20 21 22 Case No.: CV12-05552 MEJ STIPULATION AND JOINT REQUEST TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE AND EXTEND INITIAL DEADLINES Date: February 21, 2013 Time: 10:00 a.m. Judge: Maria-Elena James Courtroom: B, 15th Floor Trial Date: Not yet set Plaintiff LIBORIO HERNANDEZ and ROGELIO RODRIGUEZ-PEREZ and Defendant NOR-CAL MOVING SERVICES, making a special appearance for purposes of this stipulation, through their attorneys’ of record, hereby stipulate as follows: 23 24 25 WHEREAS, an initial Case Management Conference is currently scheduled for February 21, 2013 at 10:00 a.m. -1STIPULATION TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE Case No. cv 12 05552 MEJ 1 2 WHEREAS, Defendant recently retained Jackson Lewis LLP as counsel in this matter, 3 who promptly contacted Plaintiff’s counsel to address deficiencies in Plaintiff’s attempted 4 service of the summons and complaint. 5 6 7 8 WHEREAS, Jackson Lewis LLP agreed to accept service of process by mail, including notice and acknowledgement of receipt, pursuant to applicable statutory requirements. WHEREAS, Plaintiff intends to initiate service of process by mail concurrent with the filing of this stipulation and request for continuance. 9 WHEREAS, to allow the parties sufficient time to meaningfully meet and confer on all 10 topics required by Federal Rules of Civil Procedure Rule 26, the Civil Local Rules, the Court’s 11 standing order, and to promote judicial economy, the parties believe it is appropriate to continue 12 the initial case management conference to a date following the statutory period for Defendant to 13 answer or otherwise respond to the complaint following valid service of process. 14 THEREFORE, IT IS HEREBY STIPULATED between the parties, through their 15 respective counsel of record, a joint request for continuance of the initial case management 16 conference to April 25, 2013, or such other date available to the Court, and if the case 17 management conference is continued, all other deadlines set forth in the Court’s Order Setting 18 19 20 21 22 23 24 25 -2STIPULATION TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE Case No. cv 12 05552 MEJ 1 Initial Case Management Conference and ADR Deadlines will be continued accordingly. 2 CASA LEGAL 3 4 DATED: February 15, 2013 5 By: /s/ Tomas Margain Tomas E. Margain Attorneys for Plaintiffs 6 JACKSON LEWIS LLP 7 8 DATED: By: JoAnna L. Brooks Douglas M. Bria David T. Wang Attorneys for Defendant Nor-Cal Moving Services 9 10 11 12 ORDER 13 BASED ON THE PARTIES’ STIPULATION, THE COURT’S FILE, AND GOOD 14 15 16 CAUSE SHOWN, THE COURT ORDERS AS FOLLOWS: The initial Case Management Conference and Rule 26 deadlines are continued as follows: April 11, 2013 17 18 x 19 Last Day to Meet and Confer Regarding Initial Discloses, ADR process election and discovery plan. 20 x Last Day to file ADR Certificate signed by Parties and Counsel. 21 x Last Day to either file a stipulation to ADR Process or Notice of Need for ADR Phone 22 Conference. 23 24 25 -3STIPULATION TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE Case No. cv 12 05552 MEJ 1 2 April 18, 2013 x Last Day to File Rule 26(f) Report, complete initial disclosures and file Joint Case Management Statement. 3 4 x 5 April 25, 2013 6 x 7 Last Day to File Magistrate Consent Form. Initial Case Management Conference in Courtroom B, 15th Floor, San Francisco Courthouse at 10:00 a.m. 8 9 10 IT IS SO ORDERED 11 12 13 DATED: February 15, 2013 Hon. MARIA-ELENA JAMES Magistrate Judge of the United States District Court 14 15 16 17 18 4829-2946-8690, v. 2 19 20 21 22 23 24 25 -4STIPULATION TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE Case No. cv 12 05552 MEJ

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