Abanto Shinno v. Hewlett Packard Enterprise

Filing 21

STIPULATION AND ORDER RE 20 To Extend Time To Respond To Complaint And Continue Case Management Conference. Case Management Statement due by 2/20/2020. Initial Case Management Conference set for 2/27/2020 at 10:00 AM in San Francisco, Courtroom 03, 17th Floor. Signed by Judge Richard Seeborg on 1/13/2020. (cl, COURT STAFF) (Filed on 1/13/2020)

1 DANIEL J. BERGESON, SBN 105439
[e-mail]
2 SUSAN E. BOWER, SBN 173244
[e-mail]
3 REBECCA N. KAUFMAN, SBN 199534
[e-mail]
4 ADAM C. TRIGG, SBN 261498
[e-mail]
5 BERGESON, LLP
111 N. Market Street, Suite 600
6 San Jose, CA 95113
Telephone:
[phone]
7 Facsimile:
[phone]
8 Attorneys for Defendant
HEWLETT PACKARD ENTERPRISE
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION

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13 CARLOS ABANTO SHINNO,

Case No. 3:19 cv 07175 RS

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STIPULATION AND [PROPOSED]
ORDER TO EXTEND TIME TO
RESPOND TO COMPLAINT AND
CONTINUE CASE MANAGEMENT
CONFERENCE

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Plaintiff,
v.

16 HEWLETT PACKARD ENTERPRISE,
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Defendant.

Judge: Hon. Richard Seeborg
Crtrm.: 3, 17 Floor

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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT AND
CONTINUE CASE MANAGEMENT CONFERENCE
Case No. 3:19-cv-07175-RS

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Pursuant to Civil Local Rules 6-1, 7-12, and 16-2, Plaintiff Carlos Abanto Shinno

2 (“Shinno”), and the Defendant Hewlett Packard Enterprise (“HPE”) (collectively, the “Parties”)
3 jointly submit the following Stipulation.
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WHEREAS, Plaintiff filed the complaint in this action on October 30, 2019;

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WHEREAS, on November 26, 2019, the Parties’ filed a joint Stipulation to Extend Time to

6 Respond to Complaint that continued the deadline for HPE to respond to the Complaint to January
7 15, 2020;
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WHEREAS, there is currently a Case Management Conference set for January 30, 2020,

9 with a Case Management Statement due by January 23, 2020;
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WHEREAS, the Parties are in active settlement discussions and have agreed to extend the

11 time for Defendant to answer the Complaint to February 14, 2020;
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WHEREAS, to conserve the resources of the Court and the Parties while settlement

13 discussions continue, the Parties stipulate to and request that the Court continue the Case
14 Management Conference to February 27, 2020 or another date after February 14, 2020 convenient
15 for the Court;
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IT IS HEREBY STIPULATED by and between the Parties, as follows:

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The time for Defendant to answer the Complaint is extended to February 14, 2020.

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The Case Management Conference set for January 30, 2020 will be continued to

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February 27, 2020 or another date set by the Court.

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A Case Management Statement shall be filed no later than seven days before the

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Case Management Conference.

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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT AND
CONTINUE CASE MANAGEMENT CONFERENCE
Case No. 3:19-cv-07175-RS

1 Dated: January 13, 2020

BERGESON, LLP

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By:

/s/ Adam C. Trigg
Adam C. Trigg

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Attorneys for Defendant
HEWLETT PACKARD ENTERPRISE

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Dated: January 13, 2020

MEXICAN AMERICAN LEGAL DEFENSE AND
EDUCATIONAL FUND

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By:

/s/ Andres Holguin-Flores
Andres Holguin-Flores

Attorneys for Plaintiff
CARLOS ABANTO SINNO

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16 PURSUANT TO STIPULATION, IT IS SO ORDERED
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19 ___________________________________
Honorable Richard Seeborg
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UNITED STATES DISTRICT JUDGE

______________
1/13/2020

DATE

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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT AND
CONTINUE CASE MANAGEMENT CONFERENCE
Case No. 3:19-cv-07175-RS