Kelly v. Worth Holdings, LLC et al

Filing 30

STIPULATION AND ORDER re 29 STIPULATION WITH PROPOSED ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE AND RELATED DEADLINES filed by Thomas Kelly. Case Management Statement due by 12/14/2017. Further Case Management Conference reset for 12/21/2017 10:30 AM in Courtroom 5, 17th Floor, San Francisco. Signed by Judge Edward M. Chen on 11/27/17. (bpfS, COURT STAFF) (Filed on 11/27/2017)

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Michael G. Miller (SBN 136491)
[e-mail]
Nicole M. Jaffee (SBN 255944)
[e-mail]

KATHERINE S. CATLOS (SBN 184227)
[e-mail]
BRANDON KAHOUSH (SBN 311560)
[e-mail]

PERRY, JOHNSON, ANDERSON,
MILLER & MOSKOWITZ, LLP
438 1st Street, 4th Floor
Santa Rosa, California 95401
Telephone: [phone]
Facsimile: [phone]

KAUFMAN DOLOWICH & VOLUCK, LLP
425 California Street, Suite 2100
San Francisco, California 94104
Telephone: [phone]
Facsimile: [phone]

Attorneys for Plaintiff
THOMAS R. KELLY

Attorneys for Defendants
WORTH HOLDINGS, LLC,
E.S. WEST COAST, LLC,
ENERGY SYSTEMS

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA – SAN FRANCISCO

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THOMAS R. KELLY

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Plaintiff,
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v.
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WORTH HOLDINGS, LLC; E.S. WEST )
COAST, LLC individually and doing
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business as ENERGY SYSTEMS and
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DOES 1-20,
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Defendants.
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Case No.: 3:17-cv-02466-EMC
Action Filed: March 28, 2017
STIPULATION AND [PROPOSED]
ORDER TO CONTINUE CASE
MANAGEMENT CONFERENCE AND
RELATED DEADLINES
Date:
Time:
Courtroom:
Judge:

December 8, 2017
2:00 p.m.
5, 17th Floor
Hon. Edward M. Chen

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-1STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE AND RELATED
DEADLINES

USDC CASE NO. 3:17-CV-02466-EMC

This Stipulation is entered into by and among Plaintiff Thomas R. Kelly (“Plaintiff”)

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and Defendants E.S. West Coast, LLC dba Energy Systems and Worth Holdings, LLC

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(collectively referred to as “Defendants”), by and through their respective counsel.
WHEREAS, on November 20, 2017, the Court entered a Notice (Docket Number 28)

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continuing the Further Case Management Conference, initially set for December 7, 2017 to

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December 8, 2017 at 2:00 p.m. in Courtroom 5;
WHEREAS, pursuant to the foregoing Notice, a Joint Case Management Statement is

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currently due by December 1, 2017;

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WHEREAS, Plaintiff’s counsel, Michael G. Miller, has a scheduled deposition to

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commence on December 8, 2017 at 9:00 a.m. in Santa Rosa in another matter which cannot be

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rescheduled due to an upcoming trial date. The deposition will last at least six hours, which

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would not allow enough time for Mr. Miller to travel to San Francisco for the Further Case

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Management Conference on December 8, 2017;
WHEREAS, Mr. Miller and Defendants’ counsel, Brandon Kahoush, are both

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available to attend a Further Case Management Conference on December 21, 2017 at 1:30

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p.m. in Courtroom 5;
WHEREAS the parties agree that the continuance of the Case Management

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Conference and all related deadlines is necessary;
NOW, THEREFORE, pursuant to Local Rule 6-2(a), the Parties hereby stipulate and

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agree, through their respective counsel, as follows:
1.

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The December 8, 2017 Further Case Management Conference shall be taken off
10:30 a.m.

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calendar and rescheduled to December 21, 2017 at 1:30 p.m., or another date that is

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convenient to the Court.
2.

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The deadline to file the Joint Case Management Conference shall be continued

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to and including December 14, 2017.

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///

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-2STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE AND RELATED
DEADLINES

USDC CASE NO. 3:17-CV-02466-EMC

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IT IS SO STIPULATED

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DATED: November 27, 2017

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/s/ Brandon Kahoush

Michael G. Miller
Attorneys for Plaintiff
THOMAS R. KELLY

Brandon Kahoush
Attorneys for Defendants
WORTH HOLDINGS, LLC, E.S. WEST
COAST, LLC, ENERGY SYSTEMS

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dward
Judge E

ER

n

M. Che

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NO

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DATED: ___________, 2017

S DISTRICT
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C
___________________________________________
TA
UNITED STATES DISTRICT COURT JUDGE
HON. EDWARD M. CHEND
DERE
SO OR ED
IT IS
DIFI
AS MO

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U
O

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11/27

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PURSUANT TO STIPULATION, IT IS SO ORDERED (Revised above)

UNIT
ED

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R NIA

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/s/ Michael G. Miller

FO

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KAUFMAN DOLOWICH
& VOLUCK, LLP

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PERRY, JOHNSON, ANDERSON,
MILLER & MOSKOWITZ, LLP

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N

D IS T IC T
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OF

C

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-3STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE AND RELATED
DEADLINES

USDC CASE NO. 3:17-CV-02466-EMC

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ATTESTATION PURSUANT TO CIVIL LOCAL RULE 5-1
I, Michael G. Miller, attest that concurrence in the filing of this Stipulation to Continue

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the Case Management Conference and related deadlines has been obtained from the other

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signatory. I declare under penalty of perjury under the laws of the United States of America,

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that the foregoing is true and correct.

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Executed this 27th day of November 2017 in Santa Rosa, California.

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/s/ Michael G. Miller

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-4STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE AND RELATED
DEADLINES

USDC CASE NO. 3:17-CV-02466-EMC