Balarezo v. NTH Connect Telecom Inc., et al

Filing 173

STIPULATION AND ORDER CONTINUING CASE MANAGEMENT CONFERENCE re 172 Further Case Management Conference set for 8/19/2011 10:30 AM in Courtroom 3, 5th Floor, San Jose. Signed by Judge Jeremy Fogel on 8/4/11. (dlm, COURT STAFF) (Filed on 8/4/2011)

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Brad Yamauchi, SBN 73245
Kevin R. Allen, SBN 237994
MINAMI TAMAKI, LLP
360 Post Street, 8th Floor
San Francisco, CA 94108
Tel. [phone]
Fax [phone]
[e-mail]
[e-mail]
Attorneys for Defendants
NTH CONNECT TELECOM, INC.
and STEVEN CHEN
Adam Wang, SBN 201233
LAW OFFICES OF ADAM WANG
12 South First Street, Suite 613
San Jose, CA 95113
Tel. [phone]
Fax. [phone]
[e-mail]
Tomas E. Margain, SBN 193555
LAW OFFICES OF TOMAS E. MARGAIN
1550 Bryant Street, Suite 725
San Francisco, CA 94103
Tel. [phone]
Fax. [phone]
[e-mail]
Attorneys for Plaintiffs
VLADIMIR BALAREZO and OSMIN AVILA

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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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VLADIMIR A. BALAREZO, individually and )
on behalf of others similarly situated,
)
)
Plaintiff,
)
)
vs.
)
)
NTH CONNECT TELECOM, INC., AND
)
STEVEN CHEN,
)
)
Defendants.
)
)
______________________________________ )

Case No.: C 07-05243 JF (PSG)
STIPULATION AND ------------------[PROPOSED]
ORDER TO CONTINUE CASE
MANAGEMENT CONFERENCE

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE

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Pursuant to Local Rule 6-2, the parties, by and through their respective attorneys, hereby

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stipulate and respectfully request this Court continue the Case Management Conference scheduled

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for August 5, 2011.

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1. Lead trial counsel for the Defendant has a pre-existing scheduling conflict that he was

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unable to move and therefore desires a continuance of the August 5, 2011 Case

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Management Conference for two weeks so that he may participate in the conference.

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2. Plaintiffs’ counsel has no objection to the continuance;

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3. The parties request that the Case Management Conference be continued until 10:30 a.m. on

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Friday, August 19, 2011;
4. The parties further request that the date by which to file a Joint Case Management
Statement be continued to August 12, 2011, one week prior.

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IT IS SO STIPULATED:

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DATED: August 2, 2011

Respectfully submitted,
MINAMI TAMAKI LLP

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By:
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DATED: August 2, 2011

/s/ Kevin R. Allen
Brad Yamauchi
Kevin R. Allen
Attorneys for Defendants NTH CONNECT
TELECOM, INC. and STEVEN CHEN
Respectfully submitted,

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LAW OFFICES OF ADAM WANG

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By:

/s/ Adam Wang
Adam Wang
Tomas E. Margain
Attorneys for Plaintiffs VLADIMIR
BALAREZO and OSMIN AVILA

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE

------------------- ORDER
[PROPOSED]

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PURSUANT TO STIPULATION, IT IS ORDERED THAT:
The Case Management Conference that is currently set for August 5, 2011 at 10:30 a.m. is

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hereby continued to August 19, 2011 at 10:30 a.m. and a Joint Case Management Conference

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Statement is due filed one week prior, on August 12, 2011.

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IT IS SO ORDERED:

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8/4
DATED: __________, 2011
HONORABLE JEREMY FOGEL
UNITED STATES DISTRICT JUDGE

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE