Lopez v. Beavex Inc et al

Filing 30

ORDER GRANTING: 29 Stipulation Postponing Case Management Conference And Related Deadlines. Case Management Statement due by 5/22/2015. Case Management Conference set for 6/5/2015 11:00 AM in Courtroom 5, 2nd Floor, Oakland. Signed by Judge Jeffrey S. White on April 17, 2015. (jswlc3, COURT STAFF) (Filed on 4/17/2015)

Case4:15-cv-00550-JSW Document29 Filed04/14/15 Page1 of 4

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ROD M. FLIEGEL, Bar No. 168289
[e-mail]
ALISON S. HIGHTOWER, Bar No. 112429
[e-mail]
LITTLER MENDELSON, P.C.
650 California Street, 20th Floor
San Francisco, California 94108.2693
Telephone:
415.433.1940
Facsimile:
415.399.8490
Attorneys for Defendant
BEAVEX INCORPORATED

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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OAKLAND COURTHOUSE

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LEOBARDO LOPEZ, individually and on
behalf of himself and all others similarly
situated,

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Plaintiff,
v.

Case No. 4:15-CV-00550-JSW
STIPULATION AND [PROPOSED]
ORDER POSTPONING CASE
MANAGEMENT CONFERENCE AND
RELATED DEADLINES

BEAVEX, INC., a Georgia corporation,
LOWERS RISK GROUP, LLC, dba
PROFORMA SCREENING SOLUTIONS, a
Virginia limited liability corporation, and
Does 1 through 100, inclusive,
Defendants.

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LITTLER MENDELSON, P.C.
650 California Street
20th Floor
San Francisco, CA
94108.2693
415.433.1940

CASE NO. 4:15-CV-00550-JSW
STIP/ORDER POSTPONING CMC AND RELATED DEADLINES

Case4:15-cv-00550-JSW Document29 Filed04/14/15 Page2 of 4

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IT IS HEREBY STIPULATED AND REQUESTED by and between the parties who have

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to date appeared in this action, through their counsel of record, Michael D. Singer and Jennifer L.

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Connor of Cohelan Khoury & Singer and the Law Offices of Shaag Majarian II, attorneys for

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Plaintiff LEOBARDO LOPEZ (“Plaintiff”); Rod M. Fliegel and Alison S. Hightower of Littler

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Mendelson, P.C., attorneys for Defendant BEAVEX, INCORPORATED and Robert J. Romero,

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Edward F. Donohue and David I. Dalby for Defendant LFL Enterprises, LLC, dba Proforma

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Screening Solutions (collectively “Defendants”), based upon the following recitals:

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1.

WHEREAS on April 14, 2015 Defendants filed a motion to transfer venue to the

Northern District of Georgia set to be heard on the first available date, May 22, 2015 (Doc. 20);

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2.

WHEREAS this case is currently set for a Case Management Conference on May 8,

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2015 – two weeks before the hearing on the motion to transfer venue – and the parties are required to

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file a Joint Case Management Statement and make initial disclosures pursuant to Rule 26(a)(1)(C) by

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May 1, 2015, and to meet and confer pursuant to Rule 26(f) by April 17, 2015;

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3.

WHEREAS, a transfer of venue likely will result in additional or different case

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management schedules and requirements, and thus a modest delay on these obligations will further

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efficient and effective case management and thus serve the interests of economy for the Court and all

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Parties;

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STIPULATION

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Pursuant to this Court’s Standing Order and Civil Rule 16-2(e), so as to promote efficient and

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effective case management and thus serve the interests of economy for the Court and all Parties, the

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Parties hereby stipulate, agree and respectfully request:

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1.

That the Case Management Conference, currently set for May 8, 2015, be continued

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until ____________________, 2015, or _____ days after this Court’s service of an order on

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Defendant’s Motion To Transfer Venue, assuming that motion is denied;

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2.

The current May 1, 2015 deadline for the parties to file their Joint Case Management

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Conference Statement is extended until 14 days prior to the new date for this Case Management

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Conference;

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///

LITTLER MENDELSON
A PROFESSIONAL CORPORATION
650 California Street
20th Floor
San Francisco, CA 94108.2693
415.433.1940

1.

CASE NO. 4:15-CV-00550-JSW
STIP/ORDER POSTPONING CMC AND RELATED DEADLINES

Case4:15-cv-00550-JSW Document29 Filed04/14/15 Page3 of 4

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3.

That the last day for the Parties to meet and confer pursuant to this Court’s Standing

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Order, Civil Rule 16-3 and Federal Rule of Civil Procedure, Rule 26(f)(1) be extended to one week

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from the Court’s service of an order on Defendant’s Motion To Transfer Venue, assuming the

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motion is denied;

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4.

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The Parties shall then serve their initial disclosures pursuant to Rule 26 within 14

days of their Rule 26(f) conference; and
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In the event the Court grants Defendant’s pending Motion to Transfer Venue, these

deadlines will be vacated and will be set by the transferee district.
IT IS SO STIPULATED.
Dated: April 14, 2015.

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/s/ Jennifer L. Connor
JENNIFER L. CONNOR
COHELAN KHOURY & SINGER
Attorneys for Plaintiff
LEOBARDO LOPEZ

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Dated: April 14, 2015.

/s/ Alison S. Hightower
ROD M. FLIEGEL
ALISON S. HIGHTOWER
LITTLER MENDELSON, P.C.
Attorneys for Defendant
BEAVEX, INCORPORATED

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Dated: April 14, 2015.

/s/ David I. Dalby
ROBERT J. ROMERO
DAVID I. DALBY
HINSHAW & CULBERTSON LLP
Attorneys for Defendant LFL ENTERPRISES,
LLC (improperly sued as LOWERS RISK
GROUP, LLC.), dba PROFORMA
SCREENING SOLUTIONS)

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LITTLER MENDELSON
A PROFESSIONAL CORPORATION
650 California Street
20th Floor
San Francisco, CA 94108.2693
415.433.1940

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CASE NO. 4:15-CV-00550-JSW

STIP/ORDER POSTPONING CMC AND RELATED DEADLINES

Case4:15-cv-00550-JSW Document29 Filed04/14/15 Page4 of 4

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ORDER

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PURSUANT TO STIPULATION, THE COURT HEREBY ORDERS:

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1.

The Case Management Conference, currently set for May 8, 2015 is continued

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June 5
until ____________________, 2015, or _____ days after this Court’s service of an order on

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Defendant’s Motion to Transfer Venue, assuming that motion is denied;

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2.

The current May 1, 2015 deadline for the parties to file their Joint Case

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Management Conference Statement is extended until 14 days prior to the new date for this Case

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Management Conference; and

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3.

That the last day for the Parties to meet and confer pursuant to this Court’s

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Standing Order, Civil Rule 16-3 and Federal Rule of Civil Procedure, Rule 26(f)(1) be extended to

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one week from the Court’s service of an order on Defendant’s Motion To Transfer Venue, assuming

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the motion is denied;

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4.

The Parties shall then serve their initial disclosures pursuant to Rule 26 within

14 days of their Rule 26(f) conference; and
5.

In the event the Court grants Defendant’s pending Motion to Transfer Venue,

these deadlines will be vacated and will be set by the transferee district.

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Dated: April 17, 2015

HON. JEFFREY S. WHITE
U.S. DISTRICT COURT JUDGE

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Firmwide:132898913.1 062351.1012

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LITTLER MENDELSON
A PROFESSIONAL CORPORATION
650 California Street
20th Floor
San Francisco, CA 94108.2693
415.433.1940

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CASE NO. 4:15-CV-00550-JSW
STIP/ORDER POSTPONING CMC AND RELATED DEADLINES