Irma Ramirez, et al v. Original US Restaurant, et al

Filing 19

STIPULATION AND ORDER re 18 STIPULATION WITH PROPOSED ORDER TO CONTINUE THE FURTHER CASE MANAGEMENT CONFERENCE filed by Daren Heatherly, Irma Ramirez. Case Management Statement due by 11/4/2015. Further Case Management Conference set for 11/18/2015 at 2:00 PM in Courtroom 9, 19th Floor, San Francisco. Signed by Judge Jon S. Tigar on August 17, 2015. (wsn, COURT STAFF) (Filed on 8/17/2015)

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THOMAS E. FRANKOVICH (State Bar No. 074414)
THOMAS E. FRANKOVICH,
A PROFESSIONAL LAW CORPORATION
4328 Redwood Hwy., Suite 300
San Rafael, CA 94903
Telephone: [phone]
Facsimile:
[phone]
Attorney for Plaintiffs
IRMA RAMIREZ and
DAREN HEATHERLY

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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Plaintiffs,
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v.
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ORIGINAL US RESTAURANT; 501
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COLUMBUS LLC; and TRINACRIA
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BROS., INC.,
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Defendants.
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__________________________________ )
IRMA RAMIREZ and DAREN
HEATHERLY,

CASE NO. CV-14-03244-JST
STIPULATION and [PROPOSED]
ORDER TO CONTINUE THE FURTHER
CASE MANAGEMENT CONFERENCE

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Plaintiffs IRMA RAMIREZ and DAREN HEATHERLY, and defendants 501

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COLUMBUS LLC; and TRINACRIA BROS., INC., by and through their respective attorney of

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record stipulate to continue the further Case Management Conference set for August 19, 2015, at

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2:00 p.m. for the following reasons:

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Whereas, all defendants have been served with the summons and complaint, and

defendants have answered plaintiffs’ complaint; and
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Whereas, the parties conducted the General Order 56 Joint Site Inspection on

March 10, 2015; and
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Whereas, plaintiffs filed a notice of need for mediation on June 18, 2015.

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STIPULATION and [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE
CASE NO. CV-14-03244-JST

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The case has been referred to mediation, and mediator, Eric Ivary has been assigned to the

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matter;
4.

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Therefore, the parties respectfully request that the Case Management Conference

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currently scheduled for August 19, 2015, at 2:00 p.m. be continued to sometime after the

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mediation has been completed and/or to a date that is convenient to the Court.

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IT IS SO STIPULATED.

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This stipulation may be executed in counterparts and have the same force and effect as

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though all signatures are on the same and/or consecutive pages. Photocopies and facsimile shall

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have the same force and effect as originals.

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Respectfully submitted,

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Dated: August 12, 2015

THOMAS E. FRANKOVICH,
A PROFESSIONAL LAW CORPORATION

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By: ____/s/Thomas E. Frankovich_________

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Thomas E. Frankovich

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Attorney for Plaintiffs IRMA RAMIREZ; and

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DAREN HEATHERLY

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STIPULATION and [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE
CASE NO. CV-14-03244-JST

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Dated: August 12, 2015

MARC LIBARLE
LAW OFFICES OF MARC LIBARLE

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By:________/s/Marc Libarle___________

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Marc Libarle

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Attorney for Defendants 501 COLUMBUS LLC;

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and TRINACRIA BROS., INC.

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[PROPOSED] ORDER

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IT IS SO ORDERED that the Case Management Conference set for August 19, 2015,

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November 18
2:00
at 2:00 p.m. is vacated and/or continued to ________________, 2015, at______a.m./ p.m.
ten court
The parties shall file a Joint Case Management Statement no later than seven (7) days prior to the

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Conference.

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J u d ge J o

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R NIA

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___________________________________
Honorable Jon S. Tigar
California United States District Judge

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August 17
Dated: _______________, 2015

UNIT
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STIPULATION and [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE
CASE NO. CV-14-03244-JST

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