Ferras v. Husqvarna Construction Products North America, Inc. et al

Filing 23

ORDER GRANTING 20 STIPULATION TO CHANGE DEADLINE TO FILE JOINT CASE MANAGEMENT CONFERENCE STATEMENT. Joint Case Management Statement due by 5/27/2016. Signed by Judge Saundra Brown Armstrong on 5/27/16. (jjoS, COURT STAFF) (Filed on 5/27/2016)

Case 4:16-cv-01081-SBA Document 20 Filed 05/25/16 Page 1 of 4

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Jason A. Geller (CA SBN 168149)
[e-mail]
Juan C. Araneda (CA SBN 213041)
[e-mail]
FISHER & PHILLIPS LLP
One Embarcadero Center, Suite 2050
San Francisco, CA 94111
Telephone: [phone]
Facsimile: 415/490-9001
Attorneys for Defendant
HUSQVARNA CONSTRUCTION PRODUCTS NORTH AMERICA, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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OAKLAND DIVISION

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GARY FERRAS, an individual,
Plaintiff,

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Case No.: 4:16-CV-01081-SBA
[Removed from Contra Costa County Superior
Court, Civil Case No.C16-00131]

vs.
HUSQVARNA CONSTRUCTION
PRODUCTS NORTH AMERICA, INC.,
HUSQVARNA NORTH AMERICA,
HUSQVARNA GROUP, and
DOES 1 through 100, inclusive,
Defendants.

STIPULATION AND [PROPOSED]
ORDER TO CHANGE DEADLINE TO
FILE JOINT CASE MANAGEMENT
CONFERENCE STATEMENT
[Local Rule 6-2]
Date:
Time:

June 1, 2016
2:30 p.m.

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Complaint Filed: January 25, 2016
Removal Date: March 4, 2016
Trial Date: None

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STIPULATION

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Pursuant to Local Rule 6-2, the parties hereby submit this Stipulation and [Proposed]

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Order to change the deadline in which to file the Joint Case Management Statement of Plaintiff

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Gary Ferras (“Plaintiff”) and Defendant Husqvarna Construction Products North America, Inc.

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(“Defendant”). The initial case management conference in this action is currently scheduled for

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June 1, 2016, at 2:30 p.m., and the deadline for the parties to file a joint case management

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statement is May 25, 2016.

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Case No.: 4:16-CV-01081-SBA
STIPULATION AND [PROPOSED] ORDER TO CHANGE DEADLINE TO
FILE JOINT CASE MANAGEMENT CONFERENCE STATEMENT
FPDOCS 31740696.1

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Case 4:16-cv-01081-SBA Document 20 Filed 05/25/16 Page 2 of 4

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WHEREAS, the parties have been meeting and conferring to finalize a written joint case
management statement to submit to the Court.
WHEREAS, on May 25, 2016, Plaintiff Gary Ferras’ counsel, Mr. Alan Cohen, suffered
a medical emergency;

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WHEREAS, Mr. Cohen has requested and, counsel for Defendant agrees, that to allow

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Mr. Cohen to attend to his medical emergency and sufficient time to review the joint case

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management statement the parties have been working on, the deadline to file the parties’ Joint

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Case Management Statement should be extended by two days to May 27, 2016.

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NOW, THEREFORE, THE PARTIES AGREE AS FOLLOWS:

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The deadline for deadline for Plaintiff and Defendant to file their joint case manage

statement is extended by two days to May 27, 2016.
SO STIPULATED.

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DATED: May 25, 2016

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By: /s/ Juan C. Araneda__________
Jason A. Geller
Juan C. Araneda
Attorneys for Defendant
HUSQVARNA CONSTRUCTION
PRODUCTS NORTH AMERICA, INC.

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Respectfully submitted,
FISHER & PHILLIPS LLP

DATED: May 25, 2016

LAW OFFICES OF ALAN F. COHEN
By: /s/ Alan F. Cohen____________
Alan F. Cohen
Attorneys for Plaintiff
GARY FERRAS

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Case No.: 4:16-CV-01081-SBA
STIPULATION AND [PROPOSED] ORDER TO CHANGE DEADLINE TO
FILE JOINT CASE MANAGEMENT CONFERENCE STATEMENT
FPDOCS 31740696.1

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Case 4:16-cv-01081-SBA Document 20 Filed 05/25/16 Page 3 of 4

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[PROPOSED] ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED:
The Court, having read and considered the parties’ Stipulation to Change Deadline To

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File Joint Case Management Conference Statement, and finding good cause in support

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thereof, hereby orders that the deadline for the parties to file their joint case management

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conference statement is extended as by two days to May 27, 2016.

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DATED: ____________________
May 27, 2016

___________________________________
HON. SAUNDRA B. ARMSTRONG
UNITED STATES DISTRICT JUDGE

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Case No.: 4:16-CV-01081-SBA
STIPULATION AND [PROPOSED] ORDER TO CHANGE DEADLINE TO
FILE JOINT CASE MANAGEMENT CONFERENCE STATEMENT
FPDOCS 31740696.1

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Case 4:16-cv-01081-SBA Document 20 Filed 05/25/16 Page 4 of 4

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DECLARATION OF CONSENT

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Pursuant to Local Rule 5-1(i)(3) regarding signatures, I attest under penalty of perjury that

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concurrence in the filing of this document has been obtained from the above-listed counsel for

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Plaintiff Gary Ferras.

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DATED: May 25, 2016

/s/Juan C. Araneda_________________
Juan C. Araneda

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Case No.: 4:16-CV-01081-SBA
STIPULATION AND [PROPOSED] ORDER TO CHANGE DEADLINE TO
FILE JOINT CASE MANAGEMENT CONFERENCE STATEMENT
FPDOCS 31740696.1

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