Han et al v. Synergy Homecare Franchising, LLC

Filing 50

STIPULATION AND ORDER AS MODIFIED re 47 Stipulation, filed by Alice Lai-Bitker, John Han, Synergy Homecare Franchising, LLC, Veris Eastbay Homecare, Inc. Case Management Statement due by 4/4/2017. Initial Case Management Conference set for 4/11/2017 01:30 PM. Signed by Magistrate Judge Kandis A. Westmore on 1/31/17. (sisS, COURT STAFF) (Filed on 1/31/2017)

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CALVIN E. DAVIS (SBN: 101640)
[e-mail]
GORDON & REES LLP
633 West Fifth Street, 52nd Floor
Los Angeles, CA 90071
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
SYNERGY HOMECARE FRANCHISING, LLC

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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Gordon & Rees LLP
633 West Fifth Street, 52nd Floor
Los Angeles, CA 90071

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John Han, an individual, Alice Lai-Bitker, an
individual, Veris Eastbay Homecare, Inc., a
California corporation

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Plaintiffs,

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vs.
Synergy Homecare Franchising, LLC, an Arizona
limited liability company,

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Defendant.
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CASE NO. 4:16-cv-03759-KAW
STIPULATION AND (PROPOSED)
ORDER TO CONTINUE THE
INITIAL CASE MANAGEMENT
CONFERENCE AS MODIFIED

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WHEREAS on January 13, 2017, plaintiffs John Han, Alice Lai-Bitker, and Veris

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Eastbay Homecare, Inc. (collectively, “Plaintiffs”) filed a Motion for Leave to Amend the

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Complaint in the above-captioned matter;

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WHEREAS Plaintiff’s Motion for Leave to Amend the Complaint is currently scheduled
to be heard on March 2, 2017;

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WHEREAS the initial Case Management Conference (“CMC”) is scheduled to take place
on February 7, 2017;

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WHEREAS the deadline for the parties to file their Rule 26(f) Report and Joint Case

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Management Conference Statement is currently January 31, 2017;

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STIPULATION AND (PROPOSED) ORDER TO CONTINUE THE INITIAL CASE
MANAGEMENT CONFERENCE (CASE NO. 4:16-cv-03759-KAW)

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WHEREAS counsel for the parties have met and conferred and have agreed that

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economy and efficiency support continuing the CMC until after the Court decides the pending

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Motion to Amend the Complaint;

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IT IS STIPULATED that (1) the parties’ deadline to file their Rule 26(f) Report and Joint

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Case Management Conference Statement be continued to April 4, 2017 and (2) the CMC be

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continued to April 11, 2017, at 1:30 p.m.

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Dated: January 27, 2017

GORDON & REES LLP

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By:

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Gordon & Rees LLP
633 West Fifth Street, 52nd Floor
Los Angeles, CA 90071

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Dated: January 27, 2017

/s/ Calvin E. Davis___________
Calvin E. Davis
Attorneys for Defendant
SYNERGY HOMECARE
FRANCHISING, LLC

MILESTONE LEGAL, P.C.

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By:

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_/s/ Philip Milestone_________
(as authorized on 1/27/17)
Philip Milestone
Attorneys for Plaintiffs JOHN
HAN, ALICE LAI-BITKER,
and VERIS EASTBAY
HOMECARE, INC.

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PURSUANT TO STIPULATION, IT IS SO ORDERED: AS MODIFIED

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Dated: __1/31____, 2017

___________________________________
United States Magistrate Judge

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1122132/29622159v.1

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STIPULATION AND (PROPOSED) ORDER TO CONTINUE THE INITIAL CASE
MANAGEMENT CONFERENCE (CASE NO. 4:16-cv-03759-KAW)