Helm v. MSR Group Inc

Filing 25

STIPULATION AND ORDER re 24 STIPULATION WITH PROPOSED ORDER to Continue Case Management Conference (CMC) filed by Linda Helm Case Management Statement due by 2/24/2014. Further Case Management Conference set for 2/27/2014 09:00 AM in Courtroom 5, 17th Floor, San Francisco. An updated joint CMC Statement shall be filed by 2/24/14. Signed by Judge Edward M. Chen on 2/19/14. (bpf, COURT STAFF) (Filed on 2/19/2014)

Case3:13-cv-03473-EMC Document24 Filed02/19/14 Page1 of 4

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LAW OFFICES OF TODD M. FRIEDMAN, P.C.
Todd M. Friedman, Esq. (SBN: 216752)
[e-mail]
369 S. Doheny Dr., #415
Beverly Hills, CA 90211
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff

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GOODWIN PROCTER LLP
Robert B. Bader, Esq. (SBN: 233165)
[e-mail]
Three Embarcadero Center, 24th Floor
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA

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LINDA HELM, INDIVIDUALLY AND
ON BEHALF OF ALL OTHERS
SIMILARLY SITUATED,

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Plaintiff,

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v.

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THE MSR GROUP, LLC,

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Defendant.
________________________________

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) Case No. 3:13-cv-03473-EMC
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) STIPULATION TO CONTINUE CASE
) MANAGEMENT CONFERENCE
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_____________________________

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COMES NOW, Plaintiff, LINDA HELM (“Plaintiff”), and Defendant, THE MSR

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GROUP, LLC (“Defendant”), by and through the undersigned counsel and hereby stipulate to

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continue the Case Management Conference currently scheduled for February 20, 2014.

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GOOD CAUSE now exists for continuing the Case Management Conference, as
follows:
a) On December 13, 2013, Defendant filed its Answer to Plaintiff’s Complaint.

Stipulation to Continue Case Management Conference- 1

Case3:13-cv-03473-EMC Document24 Filed02/19/14 Page2 of 4

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b) On February 13, 2014, the parties submitted the Joint Case Management Statement

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as required by this Court in preparation for the February 20, 2014 Case Management

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Conference.

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c) During this time, the parties, through counsel, have been actively engaged in
discussions surrounding the facts, claims and defenses asserted in this matter.
d) Furthermore, the parties, through counsel, have been actively engaged in

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discussions regarding potential early resolution of the instant matter in an effort to
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avoid substantial litigation.
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e) The parties believe that good cause exists to continue the Case Management
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Conference seven (7) days (or a date as soon thereafter as is convenient to the
Court) to allow the parties to continue the aforementioned discussions as the parties
may be able to reach a resolution absent incurring further litigation fees and costs.

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f) This stipulation is submitted in good faith and not for the purposes of delay.

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g) No party will be prejudiced by the requested continuance.

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IT IS SO STIPULATED.

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Respectfully submitted this 19th day of February 2014
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By: s/Todd M. Friedman______________
TODD M. FRIEDMAN
Attorney for Plaintiff

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Respectfully submitted this 19th day of February 2014

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By: s/Robert B. Bader______________
ROBERT B. BADER
Attorney for Defendant

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Stipulation to Continue Case Management Conference- 2

Case3:13-cv-03473-EMC Document24 Filed02/19/14 Page3 of 4

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ECF CERTIFICATION
Pursuant to General Order No. 45, § X.B., the filing attorney attests that he has obtained
concurrence regarding the filing of this document from the signatories to the document.

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Dated: February 19, 2014

By: /s/ Todd M. Friedman
TODD M. FRIEDMAN
Attorney for Plaintiff

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Stipulation to Continue Case Management Conference- 3

Case3:13-cv-03473-EMC Document24 Filed02/19/14 Page4 of 4

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PROOF OF SERVICE

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I, Todd M. Friedman, state the following:

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I am employed in Los Angeles, California; I am over the age of 18 and am
not a party to this action; my business address is 369 S. Doheny Dr., Ste. 415,
Beverly Hills, CA 90211. On February 19, 2014, I served the following
documents:

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STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE
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On the parties listed below:

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GOODWIN PROCTER LLP
Robert B. Bader, Esq. (SBN: 233165)
[e-mail]
Three Embarcadero Center, 24th Floor
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant

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By the following means of service:

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[X]

BY ELECTRONIC CASE FILING: I filed the submitted the document
listed above via the court’s Electronic Case Filing (ECF) system which
provides electronic mail (email) service of the listed document directly to
the party listed above to his/her “email address of record.”

[X]

STATE: I declare under penalty of perjury under the laws of California
that the above is true and correct.

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Executed on February 19, 2014, at Beverly Hills, California.

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By:_/s/ Todd M. Friedman
Todd M. Friedman

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Stipulation to Continue Case Management Conference- 4

Case3:13-cv-03473-EMC Document24-1 Filed02/19/14 Page1 of 1

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UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA

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LINDA HELM, INDIVIDUALLY AND
ON BEHALF OF ALL OTHERS
SIMILARLY SITUATED,
Plaintiff,

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v.

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THE MSR GROUP, LLC,
Defendant.
________________________________

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Case No. 3:13-cv-03473-EMC
[PROPOSED] ORDER GRANTING
STIPULATION TO CONTINUE CASE
MANAGEMENT CONFERENCE

______________________________

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UPON STIPULATION OF THE PARTIES AND GOOD CAUSE SHOWING, it is

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hereby ORDERED that the February 20, 2014 Case Management Conference is continued to

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___________________, 2014 at ____________am.

9:00

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NO

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ORDERED

Judge Edward

M. Chen

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By:___________________________________
Judge E

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Hon. United States District Court Judge

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Order- 1

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Date:_________
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2/19/14

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DERED

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IT IS SO ORDERED.

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February 27

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