Heatherly et al v. Great China et al

Filing 32

STIPULATION AND ORDER to Continue Case Management Conference. Case Management Statement due by 1/19/2016. Case Management Conference set for 1/26/2016 at 1:30 PM. Signed by Judge Kandis A. Westmore on 11/24/15. (kawlc2S, COURT STAFF) (Filed on 11/24/2015)

1
2
3
4
5
6

THOMAS E. FRANKOVICH (State Bar No. 074414)
THOMAS E. FRANKOVICH,
A PROFESSIONAL LAW CORPORATION
1832-A Capitol Street
Vallejo, CA 94590
Telephone: [phone]
Facsimile:
[phone]
Attorney for Plaintiffs
IRMA RAMIREZ and
DAREN HEATHERLY

7

UNITED STATES DISTRICT COURT

8

NORTHERN DISTRICT OF CALIFORNIA

9
10
11
12
13
14
15
16
17
18

)
)
)
)
Plaintiffs,
)
)
)
v.
)
)
GREAT CHINA; JOSEPH MURPHY
)
CORP., a California Corporation; and
)
CHEN CHENG KUNG and KIM KUNG, )
dba GREAT CHINA,
)
)
)
Defendants.
)
___________________________________
DAREN HEATHERLY; and IRMA
RAMIREZ,

CASE NO. CV14-04012-KAW
STIPULATION and [PROPOSED] ORDER
TO CONTINUE CASE MANAGEMENT
CONFERENCE

19
20

Plaintiffs DAREN HEATHERLY and IRMA RAMIREZ, and defendants JOSEPH

21

MURPHY CORP., a California Corporation; and CHEN CHENG KUNG and KIM KUNG, dba

22

GREAT CHINA, by and through their respective attorney of record, hereby stipulate to continue

23

the Case Management Conference currently set for December 1, 2015 at 1:30 p.m.

24
25
26
27

1.

Whereas, plaintiffs counsel, Thomas E. Frankovich, will be out of state on a pre-

paid vacation from November 26, 2015 through December 8, 2015.
2.

Whereas, plaintiffs’ counsel’s office will be closed for the holidays from

December 21, 2015 through January 4, 2016.

28
STIPULATION and [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE

3.

1

Therefore, the parties respectfully request that the Case Management

2

Conference currently scheduled for December 1, 2015, at 1:30 p.m. be continued to sometime at

3

the end of January 2016 and/or to a date that is convenient to the Court.

4

IT IS SO STIPULATED.

5

This stipulation may be executed in counterparts and have the same force and effect as

6

though all signatures are on the same and/or consecutive pages. Photocopies and facsimile shall

7

have the same force and effect as originals.

8

Respectfully submitted,

9
10

Dated: November 23, 2015

11
12

By: /s/Thomas E. Frankovich
Thomas E. Frankovich
Attorney for Plaintiffs IRMA RAMIREZ; and
DAREN HEATHERLY

13
14
15
16

THOMAS E. FRANKOVICH,
A PROFESSIONAL LAW CORPORATION

Dated: November 23, 2015

CLEMENT, FITZPATRICK &
KENWORTHY PC

17
By: /s/ Peter C. De Golia
Peter C. De Golia
Attorney for Defendants JOSEPH MURPHY
CORP., a California Corporation; and CHEN
CHENG KUNG and KIM KUNG, dba GREAT
CHINA

18
19
20
21
22
23
24
25
26

//
//

27
28
STIPULATION and [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE

2

[PROPOSED] ORDER

1

IT IS SO ORDERED that the Case Management Conference set for December 1, 2015,

2
3

January 26
1:30
at 1:30 p.m., is vacated and/or continued to ________________, 2016, at____a.m./ p.m.

4

The parties shall file a Joint Case Management Statement no later than seven (7) days prior to

5

the

6

Conference.

7
8
9
10

November 24
Dated: _______________, 2015

___________________________________
Kandis A. Westmore
United States Magistrate Judge

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
STIPULATION and [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE

3