Electrical Industry Service Bureau, Inc. et al v. Gausi

Filing 48

STIPULATION AND ORDER re 47 STIPULATION WITH PROPOSED ORDER TO CONTINUE DATE TO FILE MOTIONS FOR SUMMARY JUDGMENT filed by Electrical Industry Service Bureau, Inc. Case Management Statement due by 8/28/2014. Further Case Management Conference reset for 9/4/2014 10:30 AM in Courtroom 5, 17th Floor, San Francisco.. Signed by Judge Edward M. Chen on 7/23/14. (bpfS, COURT STAFF) (Filed on 7/23/2014)

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Richard K. Grosboll, State Bar No. 099729
Benjamin K. Lunch, State Bar No. 246015
NEYHART, ANDERSON, FLYNN & GROSBOLL
369 Pine Street, Suite 800
San Francisco, CA 94104
Tel. [phone]
Fax
[phone]
Email: [e-mail]

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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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ELECTRICAL INDUSTRY SERVICE
BUREAU, INC.; NORTHERN
CALIFORNIA ELECTRICAL WORKERS
PENSION TRUST; SAN FRANCISCO
ELECTRICAL INDUSTRY
APPRENTICESHIP AND TRAINING
TRUST; ELECTRICAL WORKERS
HEALTH AND WELFARE TRUST;
NATIONAL ELECTRIC BENEFIT FUND;
INTERNATIONAL BROTHERHOOD OF
ELECTRICAL WORKERS LOCAL 6
VACATION FUND; INTERNATIONAL
BROTHERHOOD OF ELECTRICAL
WORKERS LOCAL 6; and TIM
DONOVAN as Trustee of each of the
Plaintiff Trust Funds except the National
Electrical Benefit Fund and as agent for
Plaintiff National Electrical Benefit Fund,

Case No.

12-cv-06041-EMC

STIPULATION TO CONTINUE DATE
TO FILE MOTIONS FOR SUMMARY
JUDGMENT; [PROPOSED] ORDER

Judge:

Hon. Edward M. Chen

Plaintiffs,

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v.
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FARZAD GAUSI dba EUROPEAN
QUALITY ELECTRIC,
Defendants.

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NEYHART,
ANDERSON,
FLYNN &
GROSBOLL
ATTORNEYS AT LAW

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STIPULATION TO CONTINUE DATE TO FILE MOTIONS FOR SUMMARY JUDGMENT;
[PROPOSED] ORDER
Case No. 12-cv-06041-EMC
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STIPULATION

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WHEREAS, a settlement conference in the above-titled case has been set for August 13,

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2014, at 9:30 a.m. before the Honorable Elizabeth D. Laporte in the Northern District of

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California;

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WHEREAS, a case management conference has been set for August 28, 2014 at 1:30 p.m.
before the Honorable Edward M. Chen in the Northern District of California;

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WHEREAS, the present deadline for filing motions for summary judgment is set for July
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24, 2014;
WHEREAS, the parties understood that the Court had directed them to hold the settlement

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conference before filing motions for summary judgment;

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WHEREAS, prior counsel for the plaintiffs, Eileen Bissen, has left the Neyhart, Anderson,
Flynn & Grosboll firm, and other attorneys in the firm need time to become fully familiar with the

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case;
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WHEREAS, counsel for the parties are in agreement that a continuation of the deadline for

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filing motions for summary judgment until after the August 28, 2014 case management conference

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is in the best interests of the Court and the parties;

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The parties, by and through their counsel, hereby stipulate to continue the deadline for

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filing motions for summary judgment, currently scheduled for July 24, 2014, to a date to be

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selected at the August 28, 2014 case management conference.

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NEYHART,
ANDERSON,
FLYNN &
GROSBOLL
ATTORNEYS AT LAW

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STIPULATION TO CONTINUE DATE TO FILE MOTIONS FOR SUMMARY JUDGMENT;
[PROPOSED] ORDER
Case No. 12-cv-06041-EMC
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WE AGREE TO THE ABOVE
Dated: July 21, 2014

NEYHART, ANDERSON, FLYNN & GROSBOLL

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/s/ Benjamin K. Lunch
BENJAMIN K. LUNCH, Attorney for Plaintiffs

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Dated: July 21, 2014

LAW OFFICES OF HAROLD M. JAFFE

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/s/ Harold M. Jaffe
HAROLD M. JAFFE, Attorney for Defendant
FARZAD GAUSI, dba European Quality Electric

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NEYHART,
ANDERSON,
FLYNN &
GROSBOLL
ATTORNEYS AT LAW

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STIPULATION TO CONTINUE DATE TO FILE MOTIONS FOR SUMMARY JUDGMENT;
[PROPOSED] ORDER
Case No. 12-cv-06041-EMC
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[PROPOSED] ORDER
Having considered the parties’ stipulation to continue the deadline for filing motions for
summary judgment, and good cause appearing therefore,

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IT IS HEREBY ORDERED that the deadline for filing motions for summary judgment is
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RT
U
O

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RT

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NO

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DERED
SO OR ED
IT IS
DIFI
AS MO
dward
Judge E

ER

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n

M. Che

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UNIT
ED

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The August 28, 2014 CMC is reset scheduled to September 4, 2014
at 10:30 a.m. An updated joint CMC Statement shall be filed
by August 28, 2014.
S DISTRICT
7/23/14
TE
C
Dated: __________________________
_____________________________________
TA
HON. EDWARD M. CHEN
U.S. DISTRICT COURT JUDGE

R NIA

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hereby continued to a date to be selected at the August 28, 2014 case management conference.

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D IS T IC T O
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NEYHART,
ANDERSON,
FLYNN &
GROSBOLL
ATTORNEYS AT LAW

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STIPULATION TO CONTINUE DATE TO FILE MOTIONS FOR SUMMARY JUDGMENT;
[PROPOSED] ORDER
Case No. 12-cv-06041-EMC
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