Osakan v. Apple American Group et al

Filing 18

STIPULATION AND ORDER, CASE MANAGEMENT SCHEDULING ORDER: Case Management Conference set for 6/17/2009 03:15 PM. VIA TELEPHONE. Signed by Judge ARMSTRONG on 3/26/09. (lrc, COURT STAFF) (Filed on 3/30/2009)

1 VILLARREAL HUTNER PC Lara Villarreal Hutner, Esq., Cal. Bar No. 178639 2 E-Mail: [e-mail] Tracy S. Todd, Esq., Cal. Bar No. 172884 3 E-Mail: [e-mail] 575 Market Street, Suite 300 4 San Francisco, California 94105 Telephone: [phone] Facsimile: 415.512.7674 6 Attorneys for Defendants APPLE AMERICAN GROUP LLC and 7 APPLE NORCAL LLC 8 9 10 11 12 CAESAR OSAKAN, individually, on behalf of all other similarly situated persons, and on 13 behalf of the California Labor and Workforce Development Agency and the State of 14 California, 15 16 v. Plaintiffs, CASE NO. 4:08-cv-04722-SBA STIPULATION AND ORDER CONTINUING CASE MANAGEMENT CONFERENCE AND RELATED DATES FOR SIXTY DAYS UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION

17 APPLE AMERICAN GROUP; APPLE NORCAL, LLC; and DOES 1-20, 18 Defendants. 19 20 21 Pursuant to Local Rule 6-2 of the United States District Court for the Northern

22 District of California, it is hereby stipulated and requested by and between the Plaintiff Caesar 23 Oskan (mistakenly identified as Caesar Osakan in the First Amended Complaint) and Defendants 24 Apple American Group LLC and Apple Norcal LLC that the Court continue for sixty days the 25 Case Management Conference, which is currently scheduled for April 14, 2009, and the deadline 26 by which the parties must file a Joint Status Report, which is currently due on April 7, 2009. The 27 parties make this request to allow them time to explore potential settlement of this matter and to -128 CASE NO. 4:08-cv-04722-SBA STIPULATION AND [PROPOSED] ORDER CONTINUING
CASE MANAGEMENT CONFERENCE AND RELATED DATES FOR SIXTY DAYS

1 further meet and confer over issues that could impact this litigation, including two agreements, 2 one being a general release of claims previously executed by Plaintiff for which Defendants 3 provided certain consideration, and the other being an agreement to arbitrate claims. In addition, 4 Defendants have retained new counsel, and a Notice of Substitution of Counsel was filed with the 5 Court on March 23, 2009. A sixty day continuance of these dates will also provide Defendants' 6 new counsel of record time to familiarize themselves further with the case. As a result, the parties 7 wish to preserve judicial resources and avoid any unnecessary law and motion practice in the 8 interim. 9 10 11 12 Dated: March 25, 2009 13 14 15 16 17 18 Dated: March 26, 2009 19 20 21 22 23 24 25 26 27 28 CASE NO. 4:08-cv-04722-SBA
STIPULATION AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT CONFERENCE AND RELATED DATES FOR SIXTY DAYS

IT IS SO STIPULATED.

VILLARREAL HUTNER PC

By:

/s/ Lara Villarreal Hutner_________ LARA VILLARREAL HUTNER Attorneys for Defendants APPLE AMERICAN GROUP LLC and APPLE NORCAL LLC

KLETTER & PERETZ

By:_ /s/ Yosef Peretz_________________ YOSEF PERETZ Attorney for Plaintiff CAESAR OSKAN

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ORDER IT IS HEREBY ORDERED THAT the Case Management Conference currently scheduled

3 for April 14, 2009 shall be CONTINUED to June 17, 2009 at 3:15 p.m. The parties shall meet 4 and confer prior to the conference and shall prepare a joint Case Management Conference 5 Statement which shall be filed no later than ten (10) days prior to the Case Management 6 Conference that complies with the Standing Order For All Judges Of The Northern District Of 7 California and the Standing Order of this Court. Plaintiffs shall be responsible for filing the 8 statement as well as for arranging the conference call. All parties shall be on the line and shall call 9 [phone] at the above indicated date and time. 10 11 PURSUANT TO STIPULATION, IT IS SO ORDERED. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CASE NO. 4:08-cv-04722-SBA
STIPULATION AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT CONFERENCE AND RELATED DATES FOR SIXTY DAYS

March 26, 2009

By:_______________________________________ THE HON. SAUNDRA BROWN ARMSTRONG

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