Linares v. Alliance One Receivables Management Inc.

Filing 59

STIPULATION AND ORDER CONTINUING BRIEFING SCHEDULE AND HEARING DATE RE: PLAINTIFF'S MOTION FOR ATTORNEY FEES AND CONTINUING CASE MANAGEMENT CONFERENCE: Re 58 Stipulation, filed by Alliance One Receivables Management Inc. Case Managemen t Conference set for 1/16/2014 at 9:30 AM in Courtroom C, 15th Floor, San Francisco. Plaingiff's Motion for Attorney Fees Hearing set for 1/16/2014 at 9:30 AM in Courtroom C, 15th Floor, San Francisco before Magistrate Judge Laurel Beeler. Signed by Magistrate Judge Laurel Beeler on 10/31/2013. (ls, COURT STAFF) (Filed on 10/31/2013)

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JEFFREY A. TOPOR (SBN 195545)
[e-mail]
CHRISTOPHER M. SPAIN (SBN 265465)
[e-mail]
SIMMONDS & NARITA LLP
44 Montgomery Street, Suite 3010
San Francisco, CA 94104-4816
Telephone: [phone]
Facsimile: [phone]

Attorneys for defendant
ALLIANCE ONE RECEIVABLES
7 MANAGEMENT INC.
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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PEDRO LINARES, on behalf of
himself and all others similarly
situated,

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Plaintiff,

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vs.

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ALLIANCE ONE RECEIVABLES
MANAGEMENT INC.,
Defendant.

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CASE NO.: 3:12-cv-05680-LB
STIPULATION TO CONTINUE
BRIEFING SCHEDULE AND
HEARING DATE RE: PLAINTIFF’S
MOTION FOR ATTORNEY FEES,
AND TO CONTINUE CASE
MANAGEMENT CONFERENCE
ORDER

Assigned to: Magistrate Judge Laurel
Beeler

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LINARES V. ALLIANCE ONE RECEIVABLES M ANAGEMENT INC. (CASE NO.: 3:12-cv-05680-LB)
STIPULATION TO CONTINUE BRIEFING SCHEDULE AND HEARING DATE
RE: PLAINTIFF’S MOTION FOR ATTORNEY FEES, AND TO
CONTINUE CASE MANAGEM ENT CONFERENCE

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Whereas Plaintiff Pedro Linares (“Linares”) and Defendant AllianceOne

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Receivables Management, Inc. (“AllianceOne”) hereby stipulate and agree as

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follows:

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1.

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On September 2, 2013, Plaintiff Linares filed his Notice of

Acceptance of Offer of Judgment. See Notice (Doc. No. 50).
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On September 5, 2013, the Court issued an Order regarding Plaintiff’s

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Notice of Acceptance, directing the parties to advise the court on issues related to

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Plaintiff’s attorneys’ fees and noting that the Court was keeping the case

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management conference set for November 14, 2013. See Order (Doc. No. 52).

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3.

On October 17, 2013, Plaintiff filed his Motion for Attorney Fees and

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set the matter for hearing on November 21, 2013 at 9:30 a.m. See Motion (Doc.

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No. 54). Accordingly, AllianceOne’s response is currently due on October 31,

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2013 and Plaintiff’s reply is due on November 7, 2013. See id.

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4.

The parties recently reached an agreement as to the amount of

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attorneys’ fees and costs that Plaintiff is entitled to as a result of Plaintiff’s Notice

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of Acceptance of Offer of Judgment.

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5.

Plaintiff Linares and Defendant AllianceOne hereby stipulate and

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agree, and hereby jointly request that the Court continue the filing deadlines for

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AllianceOne’s response to Plaintiff’s fee motion and Plaintiff’s reply, as well as

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the November 21, 2013 hearing date, for 45 days to allow the parties to finalize

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their agreement. The parties also jointly request that the Court continue the

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November 14, 2013 case management conference and the parties’ deadline to file

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a joint case management report for 45 days.

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IT IS SO STIPULATED.

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[signatures on the next page]

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LINARES V. ALLIANCE ONE RECEIVABLES M ANAGEMENT INC. (CASE NO.: 3:12-cv-05680-LB)
STIPULATION TO CONTINUE BRIEFING SCHEDULE AND HEARING DATE
RE: PLAINTIFF’S MOTION FOR ATTORNEY FEES, AND TO
CONTINUE CASE MANAGEM ENT CONFERENCE

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DATED: October 28, 2013

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SIMMONDS & NARITA LLP
JEFFREY A. TOPOR
CHRISTOPHER M. SPAIN

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By:

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/s/ Christopher M. Spain
Christopher M. Spain
Attorneys for Defendant AllianceOne
Receivables Management, Inc.

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DATED: October 28, 2013

HORWITZ, HORWITZ & ASSOCIATES
O. RANDOLPF BRAGG

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/s/ O. Randolph Bragg
O. Randolph Bragg
Attorney for Plaintiff

Case Management Conference and Motion for Attorney Fees reset to January 16, 2014
at 9:30 a.m.
Date: October 31, 2013

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LINARES V. ALLIANCE ONE RECEIVABLES M ANAGEMENT INC. (CASE NO.: 3:12-cv-05680-LB)
STIPULATION TO CONTINUE BRIEFING SCHEDULE AND HEARING DATE
RE: PLAINTIFF’S MOTION FOR ATTORNEY FEES, AND TO
CONTINUE CASE MANAGEM ENT CONFERENCE

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