Maravill Jr. v. Rosas Brothers Construction et al

Filing 12

STIPULATION AND ORDER re 11 STIPULATION WITH PROPOSED ORDER to Continue CMC filed by Antonio Maravilla, Jr. Case Management Statement due by 4/3/2017. Initial Case Management Conference set for 4/12/2017 at 2:00 PM in Courtroom 9, 19th Floor, San Francisco. Signed by Judge Jon S. Tigar on February 28, 2017. (wsn, COURT STAFF) (Filed on 2/28/2017)

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Kevin M.(Casey) Christensen (Bar No. 168119)
[e-mail]
CHRISTENSEN LAW GROUP
2603 Camino Ramon, Suite 385
San Ramon, CA 94583
Telephone:
925.937.0800
Facsimile:
925.215.4514

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Attorneys for Defendants

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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ANTONIO MARAVILLA,

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Plaintiff,

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Case No. 3:16-CV-06117 JST
ORDER
STIPULATION AND PROPOSED TO
CONTINUE CASE MANAGEMENT
CONFERENCE [Civ. L.R. 7-12]

v.
ROSAS BROTHERS CONSTRUCTION,
INC.; VICTOR MANUEL ROSAS, JOSE
HUMBERTO ROSAS, and JOSE LUIS
ROSAS,

Date:
March 8, 2017
Time:
2:00 p.m.
Courtroom: 9

Defendants.

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STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE
The parties, through undersigned counsel, stipulate as follows:
1.

This matter was filed on October 24, 2017.

2.

Defendant Rosas Brothers Construction, Inc. was served on January 13, 2017. The

three individual defendants have not yet been served.
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This matter was assigned to the Hon. Jon S. Tigar effective January 20, 2017,

following plaintiff’s declination to consent to jurisdiction of a magistrate judge for all purposes.
4.

Counsel for defendants was first retained on February 9, 2017. The individual
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3:16 –CV-063:1631
JOINT REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE

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defendants will shortly acknowledge receipt of summons as requested by plaintiff’s counsel on
February 13, 2017.

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5.

Given the short amount of time between the appearance of defendants and their

counsel, the parties respectfully, and jointly, submit that it would be difficult for defendants to
engage meaningfully in meet and confer regarding the case, and prepare to exchange initial
disclosures, prior to the March 8, 2107 case management conference previously scheduled in this
matter.
6.

In addition, defendants’ counsel is on a previously scheduled vacation out of state

that will not conclude until February 28, 2017, making it significantly inconvenient for
defendants counsel to prepare for and meaningfully participate in the scheduled case management
conference.
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Accordingly, the parties respectfully, and jointly, request that the Court continue

the case management previously set for March 8, 2017, to a date not less than 90 days thereafter.

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Dated: February 24, 2017

CHRISTENSEN LAW GROUP

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Kevin M. (Casey) Christensen
Attorneys for Defendants Rosas Brothers
Construction, Inc., Victor Manuel Rosas, Jose
Humberto Rosas, and Jose Luis Rosas

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Dated: February 24, 2017

JUSTICE AT WORK LAW GROUP

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_____/s/ Tomas E. Margain___________
Tomas Margain
Attorneys for Plaintiff Antonio Maravilla

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3:16 –CV-06117 JST
JOINT REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE

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[PROPOSED] ORDER
Pursuant to stipulation, it is so ordered. The Case Management Conference previously set

April 12, 2017 at 2pm
for March 8, 2017, shall be continued to _________________, and all related matters/deadlines
shall be recomputed from this date.

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_________________________________

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Hon. Jon S. Tigar

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District Court Judge

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3:16 –CV-06117 JST
JOINT REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE