Cruz v. HFS North America LLC

Filing 53

STIPULATION AND ORDER: That the deadline to conduct Early Neutral Evaluation has been EXTENDED to 04/01/10 at 10:00 AM. Case referred to early neutral evaluation. Signed by Judge Saundra Brown Armstrong, on 2/9/10. (lrc, COURT STAFF) (Filed on 2/10/2010) Modified on 2/11/2010 (jlm, COURT STAFF).

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JOSEPH A. SCHWACHTER, Bar No. 108124 RICHARD H. RAHM, Bar No. 130728 ROSSANA S. ELTANAL, Bar No. 221145 LITTLER MENDELSON A Professional Corporation 650 California Street, 20th Floor San Francisco, CA 94108.2693 Telephone: [phone] Facsimile: 415.399.8490 Email: [e-mail] Email: [e-mail] Email: [e-mail] Attorneys for Defendant HFS NORTH AMERICA LLC LAW OFFICES OF PAUL L. KRANZ PAUL L. KRANZ, Bar No. 114999 2560 Ninth Street, Suite 213 Berkeley, CA 94710 Telephone: [phone] Facsimile: 510.549.5901 Email: [e-mail] Attorneys for Plaintiffs ARNULFO CRUZ, ET AL. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION

ARNULFO CRUZ, et al., Plaintiffs, vs.

Case No.: C08-05078 SBA JOINT STIPULATION FOR ADDITIONAL TIME TO COMPLETE ADR AND ORDER Compl. Filed: November 6, 2008 Judge Saundra Brown Armstrong

HFS NORTH AMERICA, LLC, a Delaware corporation and DOES 1-50, 24 inclusive,
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Defendant.

1. C08-05078 SBA JOINT STIPULATION FOR ADDITIONAL TIME TO COMPLETE ADR AND [PROPOSED] ORDER

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Plaintiffs Arnulfo Cruz, et al., and defendant HFS North America LLC (collectively, the "parties"), by their respective counsel, hereby stipulate and agree as follows: WHEREAS, the Court's scheduling order provides that the parties shall complete Early Neutral Evaluation "ENE" by February 16, 2010; WHEREAS, as a result of counsel's schedule there is certain discovery that has not been completed and which discovery the parties agree is necessary for the ENE to likely be successful; WHEREAS, counsel have reviewed their calendars, have conferred with the appointed Evaluator Roderick P. Bushnell, Esq., and have agreed that if the Court will extend the time to complete the ENE the ENE will be conducted on April 1, 2010 at 10:00 a.m.; and WHEREAS, the Court's docket as of February 2, 2010, reflects that the ENE hearing is set for April 1, 2010 at 10:00 a.m. at the offices of Litter Mendelson.

NOW THEREFORE, IT IS HEREBY RESPECTFULLY REQUESTED by the parties hereto that the Court extend the time to complete ENE for forty-five (45) days until April 2, 2010.

IT IS SO STIPULATED. DATED: February 3, 2010 /s/ Paul L. Kranz Paul L. Kranz, Bar No. 114999 Law Offices of Paul L. Kranz Attorneys for Plaintiffs ARNULFO CRUZ, et al. DATED: February 3, 2010 /s/ Rossana S. Eltanal Joseph A. Schwachter, Bar No. 108124 Richard H. Rahm, Bar No. 130728 Rossana S. Eltanal, Bar No. 221145 LITTLER MENDELSON A Professional Corporation Attorneys for Defendant HFS North America LLC ATTESTATION OF CONCURRENCE Pursuant to the Court's General Order 45, Section X(B), the filer of the document attests that concurrence in the filing of this document has been obtained from each of the signatories. 2. C08-05078 SBA JOINT STIPULATION FOR ADDITIONAL TIME TO COMPLETE ADR AND [PROPOSED] ORDER

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Firmwide:93960340.1 063623.1002

ORDER The deadline to conduct the Early Neutral Evaluation session is extended to April 2, 2010. The ENE will be conducted on April 1, 2010, at 10:00 a.m. PURSUANT TO STIPULATION, IT IS HEREBY ORDERED.

DATED: _2/9/10

__________________________________ HON. SAUNDRA BROWN ARMSTRONG United States District Court Judge

3. C08-05078 SBA JOINT STIPULATION FOR ADDITIONAL TIME TO COMPLETE ADR AND [PROPOSED] ORDER