Premier Floor Care Inc. v. Service Employees International Union, United Service Workers West

Filing 66

ORDER by Judge Haywood S. Gilliam, Jr. Granting 65 Stipulation for Extension to Complete Reply Brief Re 60 MOTION for Summary Judgment. (ndrS, COURT STAFF) (Filed on 5/17/2019)

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1 6 ANTONIO RUIZ, Bar No. 155659 CAROLINE N. COHEN, Bar No. 278154 WEINBERG, ROGER & ROSENFELD A Professional Corporation 1001 Marina Village Parkway, Suite 200 Alameda, California 94501 Telephone (510) 337-1001 Fax (510) 337-1023 E-Mail: courtnotices@unioncounsel.net aruiz@unioncounsel.net ccohen@unioncounsel.net 7 Attorneys for Defendant 8 11 PATRICK W. JORDAN, Bar No. 52115 JORDAN LAW GROUP 1010 “B” Street, Suite 320 San Rafael, California 94901 Telephone: (415) 459-9865 Fax: (415) 459-9871 E-Mail: PWJ@PJORDANLAW.COM 12 -AND- 13 WILLIAM GREEN, Bar No. 129816 KAILYN J. SHARP, Bar No. 311140 DELFINO GREEN & GREEN 1010 B Street, Suite 320 San Rafael, CA 94901 Telephone: (415) 442-4646 Facsimile: (415) 442-4802 E-Mail: bill@dgglaw.com kailyn@dgglaw.com Attorneys for Plaintiff 2 3 4 5 9 10 14 15 16 17 18 UNITED STATES DISTRICT COURT 19 NORTHERN DISTRICT OF CALIFORNIA 20 OAKLAND DIVISION 21 22 23 24 25 No. 18-cv-01851-HSG PREMIER FLOOR CARE, STIPULATION AND ORDER REGARDING REQUEST FOR EXTENSION OF TIME TO COMPLETE REPLY BRIEFING ON DEFENDANT’S MOTION FOR SUMMARY JUDGMENT Plaintiff, v. SERVICE EMPLOYEES INTERNATIONAL UNION, UNITED SERVICE WORKERS WEST, and DOES 1 THROUGH 10, 26 27 Judge: Haywood S. Gilliam, Jr. Hearing Date: June 13, 2019 Hearing Time: 2:00 p.m. Hearing Location: Courtroom 2 at 1301 Clay St., Oakland, CA 94612 Defendant. 28 WEINBERG, ROGER & ROSENFELD A Professional Corporation 1001 Marina Village Parkway, Suite 200 Alameda, California 94501 (510) 337-1001 1 STIPULATION AND ORDER REGARDING REQUEST FOR EXTENSION OF TIME TO COMPLETE REPLY BRIEFING ON DEFENDANT’S MOTION FOR SUMMARY JUDGMENT Case No. 18-cv-01851-HSG 1 PLEASE TAKE NOTICE that Plaintiff and Defendant, by and through their counsel, 2 and subject to this Court’s approval, have jointly stipulated to extend the Defendant’s deadline to 3 file its Reply brief in support of the Motion for Summary Judgment from Tuesday, May 28 to 4 Thursday, May 30 to accommodate counsel’s scheduling constraints. This stipulation follows 5 Plaintiff’s May 13, 2019 request for an extension of time to file its Response brief opposing 6 Defendant’s motion for summary judgment due to its calendaring error. In an effort to try to 7 address scheduling issues posed by the May 14th modification of Defendant’s Reply briefing 8 deadline without resort to the Court, the parties have met and conferred to determine whether 9 Plaintiff may be able to submit its brief on May 17 or May 19, in advance of its May 20, 2019 10 deadline. As the conclusion of these efforts, Plaintiff offered to stipulate to extend the 11 Defendant’s Reply deadline to accommodate Defendant’s counsel’s scheduling constraints as an 12 alternative means to resolving the parties’ scheduling issues. 13 Dated: May 16, 2019 JORDAN LAW GROUP 14 15 By: 16 17 Attorneys for Plaintiff PREMIER FLOOR CARE INC. Dated: May 16, 2019 DELFINO GREEN & GREEN 18 By: 19 20 /S/ WILLIAM GREEN WILLIAM GREEN KAILYN SHARP Attorneys for Plaintiff PREMIER FLOOR CARE INC. 21 22 /S/ PATRICK W. JORDAN PATRICK W. JORDAN Dated: May 16, 2019 WEINBERG, ROGER & ROSENFELD A Professional Corporation 23 24 By: 25 Attorneys for Defendant SERVICE EMPLOYEES INTERNATIONAL UNION, UNITED SERVICE WORKERS WEST 26 27 28 WEINBERG, ROGER & ROSENFELD A Professional Corporation 1001 Marina Village Parkway, Suite 200 Alameda, California 94501 (510) 337-1001 /S/ CAROLINE N. COHEN ANTONIO RUIZ CAROLINE N. COHEN 145100\1026449 2 STIPULATION AND ORDER REGARDING REQUEST FOR EXTENSION OF TIME TO COMPLETE REPLY BRIEFING ON DEFENDANT’S MOTION FOR SUMMARY JUDGMENT CASE NO. 18-CV-01851-HSG 1 2 3 ORDER After fully considering the Joint Stipulation of the Parties to the extension of the Defendant’s Reply brief filing cut-off; and good cause appearing, 4 IT IS HEREBY ORDERED that: 5 1. The Defendant’s Reply brief deadline, currently scheduled as May 28, 2019 is hereby 6 7 8 9 set for May 30, 2019. IT IS SO ORDERED. DATED: May 17, 2019 HONORABLE HAYWOOD S. GILLIAM, JR. JUDGE OF THE DISTRICT COURT 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 WEINBERG, ROGER & ROSENFELD A Professional Corporation 1001 Marina Village Parkway, Suite 200 Alameda, California 94501 (510) 337-1001 3 STIPULATION AND ORDER REGARDING REQUEST FOR EXTENSION OF TIME TO COMPLETE REPLY BRIEFING ON DEFENDANT’S MOTION FOR SUMMARY JUDGMENT CASE NO. 18-CV-01851-HSG

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