Crisostomo v. Akima Facilities Management, LLC

Filing 31

STIPULATION AND MODIFIED ORDER re 30 STIPULATION Extending Time for Defendnat to File a Respsonsive Pleading and Set Scheduling Order filed by Akima Facilities Management, LLC. Case Management Statement due by 6/20/2014. Case Management Conference set for 6/27/2014 10:30 AM in Courtroom 4, 17th Floor, San Francisco. Signed by Judge Vince Chhabria on 4/28/2014. (knm, COURT STAFF) (Filed on 4/28/2014)

1
2
3
4
5
6

Kathleen Maylin (State Bar No. 155371)
Joshua A. Kuns (State Bar No. 272206)
JACKSON LEWIS P.C.
50 California Street, 9th Floor
San Francisco, California 94111-4615
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
E-mail: [e-mail]
Attorneys for Defendant
Akima Facilities Management, LLC

7
8

UNITED STATES DISTRICT COURT

9

NORTHERN DISTRICT OF CALIFORNIA

10
11

DANIEL CRISOSTOMO,

12
13
14

Plaintiff,
v.
AKIMA FACILITIES MANAGEMENT,
LLC, and DOES 1 to 10,

15
16

Defendants.

Case No. 4:13-cv-05187-VC
JOINT STIPULATION AND
[PROPOSED] ORDER EXTENDING
TIME FOR DEFENDANT AKIMA
FACILITIES MANAGEMENT, LLC TO
FILE A RESPONSIVE PLEADING AND
SET SCHEDULING ORDER AS
MODIFED
Ctrm.:
Judge:

4; 17th Floor
Hon. Vince Chhabria

17
Removal Filed: 11/6/2013
Trial Date: None Set

18
19

Plaintiff DANIEL CRISOSTOMO (“Plaintiff”) and Defendant AKIMA FACILITIES
20
MANAGEMENT, LLC (“Defendant”), through their respective counsel, hereby stipulate as
21
follows:
22
WHEREAS the parties entered into a stipulation on March 31, 2014, extending the time
23
for Defendant to file a responsive pleading so that the parties could pursue informal resolution
24
before incurring the costs of litigation (“Joint Stipulation”);
25
WHEREAS the parties’ Joint Stipulation was signed by the Honorable Yvonne Gonzalez
26
Rogers on April 2, 2014;
27
WHEREAS Defendant’s response to Plaintiff’s First Amended Complaint was extended
28
1
JT. STIP. & [PROPOSED] ORDER EXT. TIME FOR DEF’T
TO FILE RESP. PLEADING AND SET SCHEDULING ORDER Case No. 4:13-cv-05187-VC

1

to April 30, 2014;

2
3

WHEREAS the parties have agreed to participate in an informal settlement conference in
May 2014;

4
5

WHEREAS the parties continue to desire to defer the costs associated with litigation
before attending the informal settlement conference in May 2014;

6

THEREFORE, IT IS HEREBY STIPULATED BY THE PARTIES AS FOLLOWS:

7

1.

8

First Amended Complaint;

9
10

Defendant shall have a 60-day extension to file a responsive pleading to Plaintiff’s

2.

Defendant’s response to Plaintiff’s First Amended Complaint shall now be due on

or before June 30, 2014;

11

3.

All other dates, including the deadline to exchange initial disclosures and a joint

12

discovery plan, and the case management conference, shall be scheduled to occur after June 30,

13

2014.

14
15

Respectfully submitted,
Dated: April 28, 2014

JACKSON LEWIS P.C.

16
17

By:

18
19
20
21
22

/s/ Kathleen Maylin
Kathleen Maylin
Joshua A. Kuns
Attorneys for Defendant
Akima Facilities Management, LLC

“I hereby attest that I have on file all holographic signatures corresponding to any signatures
indicated by a conformed signature (/S/) within this e-filed document.”
Dated: April 28, 2014

BROCK LAW OFFICE

23
24

By:

25
26

///

27

///

28

/s/ Gregory P. Brock
Gregory P. Brock
Attorneys for Plaintiff
Daniel Crisostomo

///
2
JT. STIP. & [PROPOSED] ORDER EXT. TIME FOR DEF’T
TO FILE RESP. PLEADING AND SET SCHEDULING ORDER Case No. 4:13-cv-05187-VC

5
6
7
8
9

orders as follows:
1.

Defendant’s response to Plaintiff’s First Amended Complaint shall now be due on

or before June 13, 2014;
2.

All other dates, including the deadline to exchange initial disclosures and a joint

discovery plan, and the case management conference, shall be scheduled as follows:
A case management conference shall be scheduled for Friday, June 27, 2014, at 10:30 a.m. The
joint case management conference statement shall be due no later than June 20, 2014.

10
11

Dated: April 28, 2014
14

S

UNIT
ED

13

RT
U
O

IT IS SO ORDERED.
12

S DISTRICT
TE
C
TA

ERED
O ORD D
IT IS S
IFIE
SM D
Hon. Vince Chhabria O
A

R NIA

4

Having reviewed and considered the parties’ above stipulation, the Court hereby finds and

United States District Court Judge
hhabr ia
Vi n c e C
J u d ge

NO

15

RT

16

ER

H

17
18

FO

3

LI

2

///
TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

A

1

N

D IS T IC T
R

OF

C

19
20
21

4833-1788-7258, v. 2

22
23
24
25
26
27
28
3
JT. STIP. & [PROPOSED] ORDER EXT. TIME FOR DEF’T
TO FILE RESP. PLEADING AND SET SCHEDULING ORDER Case No. 4:13-cv-05187-VC