Sorihin et al v. Nguyen

Filing 60

STIPULATION AND ORDER re 59 STIPULATION WITH PROPOSED ORDER to Continue Case Management Conference filed by Thoai Van Nguyen. Case Management Statement due by 12/11/2017. Initial Case Management Conference set for 12/20/2017 at 2:00 PM in Courtroom 9, 19th Floor, San Francisco. Signed by Judge Jon S. Tigar on October 26, 2017. (wsn, COURT STAFF) (Filed on 10/26/2017)

1 LEWIS BRISBOIS BISGAARD & SMITH LLP
LYNN L. KRIEGER, SB# 209592
2 MATTHEW W.J. JOHNSTON, SB# 300222
333 Bush Street, Suite 1100
3 San Francisco, California 94104-2872
Telephone: [phone]
4 Facsimile: 415.434.0882
5 Attorneys for Defendant and Counter-Claimant
THOAI VAN NGUYEN
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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11 SORIHIN, aka SORIHIN SORIHIN, an
individual; and ABDUL FATAH, an
12 individual,
Plaintiff,

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CASE NO. 3:16-cv-05422 JST
STIPULATION AND [PROPOSED]
ORDER TO CONTINUE CASE
MANAGEMENT CONFERENCE

vs.

15 THOAI VAN NGUYEN, an individual doing
business as SEA QUEEN II,
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Defendant.
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18 AND RELATED CROSS-ACTIONS
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The Parties in the above-entitled action jointly submit this Stipulation and Proposed Order

21 and request the Court to adopt it as the Order in this case.
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WHEREAS, this Court scheduled a Case Management Conference in the above referenced

23 matter for November 8, 2017 at 2:00 p.m.
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WHEREAS, the Parties have reached a tentative settlement and are negotiating settlement

25 terms in an effort to resolve this suit, with the ongoing assistance of court-appointed neutral
26 Howard Herman;
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LEWIS

WHEREAS, the Parties intend to continue working with Mr. Herman to finalize the

28 remaining settlement terms in the coming weeks;

BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

4817-3523-8994.1

16-5422
STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE

1

WHEREAS, the Parties have agreed to continue the Case Management Conference to

2 December 6, 2017 at 2:00 p.m. or to a later date and time convenient to the Court;
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THEREBY, the Parties stipulate to and respectfully request a continuance of the upcoming

4 Case Management Conference on November 8, 2017 to a date on or after December 6, 2017.
5 Respectfully submitted,
6 DATED: October 25, 2017

LEWIS BRISBOIS BISGAARD & SMITH

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By:

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9

LLP

/s/ Lynn L. Krieger
Lynn L. Krieger
Matthew W.J. Johnston
Attorneys for Defendant and Counter-Claimant
THOAI VAN NGUYEN

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11 DATED: October 25, 2017

LEGAL AID AT WORK

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By:

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/s/ Mana Barari
Mana Barari
Carole Vigne
Agnieszka Fryszman
COHEN MILSTEIN SELLERS & TOLL PLLC

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Yenny Teng-Lee
THE LAW OFFICE OF YENNY TENG-LEE

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Attorneys for Plaintiffs SORIHIN, aka SORIHIN
SORIHIN and ABDUL FATAH

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ATTESTATION PURSUANT TO CIVIL LOCAL RULE 5-1(i)(3)
I, Lynn L. Krieger, attest that concurrence in the filing of this document has been obtained

23 from each of the other signatories. I declare under penalty of perjury under the laws of the United
24 States of America that the foregoing is true and correct.
25
26 October 25, 2017

By:

/s/ Lynn L. Krieger
Lynn L. Krieger

27

LEWIS

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BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

4817-3523-8994.1

16-5422
2
STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE

[PROPOSED] ORDER

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2

Based upon the agreement of the Parties, and the Court finding good cause, IT IS

3 HEREBY ORDERED THAT the Parties’ Stipulation to Continue the Case Management
4 Conference is GRANTED and entered as an Order of the Court. The Case Management
5 Conference currently scheduled for November 8, 2017 at 2:00 p.m. is continued to
December 20
2:00 p.m.
6 _________________, 2017 at __________.

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8 IT IS SO ORDERED.
9
October 26
10 DATED: _______________, 2017

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12
HONORABLE JON S. TIGAR
United States District Court Judge

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LEWIS

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BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

4817-3523-8994.1

16-5422
3
STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE