Vargas v. Delivery Outsourcing, LLC et al

Filing 23

STIPULATION AND ORDER re 22 STIPULATION WITH PROPOSED ORDER TO EXTEND PLAINTIFFS TIME TO FILE OPPOSITION TO DEFENDANTS MOTION TO COMPEL ARBITRATION AND STAY PROCEEDINGS AND RELATED DEADLINES AND HEARING filed by Salvador Vargas. Signed by Judge Jon S. Tigar on January 19, 2016. (wsn, COURT STAFF) (Filed on 1/19/2016)

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Arlo Garcia Uriarte, Esq., SBN 231764
Un Kei Wu, Esq., SBN 270058
LIBERATION LAW GROUP, P.C.
2760 Mission Street
San Francisco, CA 94110
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
Salvador Vargas

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UNITED STATES DISTRICT COURT
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FOR THE NORTHERN DISTRICT OF CALIFORNIA
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Salvador Vargas,
Plaintiff,

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Case No. 15-cv-03408 JST

v.
Delivery Outsourcing, LLC, Luggage Services
and Logistics, LLC, Bags, Inc., and DOES 110,
Defendants.

STIPULATION TO EXTEND
PLAINTIFF’S TIME TO FILE
OPPOSITION TO DEFENDANT’S
MOTION TO COMPEL ARBITRATION
AND STAY PROCEEDINGS AND
RELATED DEADLINES AND HEARING;
AND
[PROPOSED] ORDER
Hon. Jon. S. Tigar
Date: February 11, 2016
Location: Courtroom 9
Time: 2:00 p.m.

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COME NOW the parties, and by and through their respective counsel hereby stipulate that:
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1. Plaintiff requested and Defendants agreed to allow Plaintiff additional time to file his
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opposition to Defendant’s Motion to Compel Arbitration and Stay Proceedings after the
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deadline for such had passed. The parties have agreed to the time for Plaintiff to file an
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Opposition may be extended to January 21, 2016;
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-1STIPULATION TO EXTEND PLAINTIFF’S TIME TO FILE OPPOSITION TO DEFENDANT’S MOTION TO COMPEL
ARBITRATION AND STAY PROCEEDINGS; AND [PROPOSED] ORDER

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2. The deadline for Defendants to file a Reply to Plaintiff’s Opposition to Defendant’s Motion
to Compel Arbitration and Stay Proceedings shall be February 4, 2016; and

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3. If convenient to the Court, the hearing on Defendant’s Motion to Compel Arbitration and

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Stay Proceedings shall be rescheduled to February 25, 2016, to allow the Court sufficient

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time to review the papers.

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The parties respectfully submit that there is good cause for the requested extensions of
time. Please see Declaration of Un Kei Wu, submitted in support of this Stipulation.
IT IS SO STIPULATED.

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DATED: January 19, 2016

/s/ Maureen K. Bogue____________________
MAUREEN K. BOGUE
Attorney for Defendant Delivery Outsourcing, LLC

DATED: January 19, 2016

/s/ Elaine Lerner________________________
ELAINE LERNER
Attorney for Defendants Luggage Services and
Logistics, LLC and Bags Inc.

DATED: January 19, 2016

/s/ Un Kei Wu_________________________
UN KEI WU
Attorney for Plaintiff Salvador Vargas

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FILER’S ATTESTATION

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Pursuant to Civil Local Rules, rule 5-1(i)(3), I attest under penalty of perjury that
concurrence in the filing of the document has been obtained from its signatory.
Dated: January 19, 2016

/s/ Un Kei Wu______________
UN KEI WU
Attorney for Plaintiff Salvador Vargas

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-2STIPULATION TO EXTEND PLAINTIFF’S TIME TO FILE OPPOSITION TO DEFENDANT’S MOTION TO COMPEL
ARBITRATION AND STAY PROCEEDINGS; AND [PROPOSED] ORDER

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[PROPOSED] ORDER ON STIPULATION

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Having reviewed the parties’ stipulation and supporting declaration, and good cause

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appearing therein,

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IT IS HEREBY ORDERED that Plaintiff’s time to file his opposition to Defendant’s

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Motion to Compel Arbitration and Stay Proceedings be extended to and through January 21, 2016.

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Defendant’s Reply to Plaintiff’s Opposition shall be due on February 4, 2016. The hearing on the

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motion, presently set for February 11, 2016, shall be rescheduled to February 25, 2016.
PURSUANT TO STIPULATION, IT IS SO ORDERED.

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DATED: January ___, 2016

_________________________________
Hon. Jon S. Tigar
ERED
Judge of theIS SO ORD
Northern District

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-3STIPULATION TO EXTEND PLAINTIFF’S TIME TO FILE OPPOSITION TO DEFENDANT’S MOTION TO COMPEL
ARBITRATION AND STAY PROCEEDINGS; AND [PROPOSED] ORDER