Espinoza et al v. C & C Security Patrol, Inc. et al

Filing 84

STIPULATION AND ORDER Granting One Week Extension to File Pre-Trial Materialsre 82 Stipulation. All pretrial materials due 1/29/2010. The Court will not entertain further requests for extension. Signed by Judge James Ware on 1/22/2010. (ecg, COURT STAFF) (Filed on 1/22/2010)

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ADAM WANG, Bar No. 201233 LAW OFFICES OF ADAM WANG 12 South First Street, Suite 708 San Jose, CA 95113 Telephone: [phone] Facsimile: [phone]

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Attorneys for Plaintiffs

Mark A. Hagopian, Esq., SBN 124819, [e-mail] Sejal Thakkar, Esq., SBN 226778, [e-mail] MANNING & MARDER KASS, ELLROD, RAMIREZ LLP One California Street, Suite 1100 San Francisco, CA 94111 Telephone: [phone] Facsimile: [phone] Attorneys for Defendants

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1/22/2010

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

LEONARDO ESPINOZA, and SERGIO ROQUE, , Plaintiffs, vs. C & C SECURITY PATROL, INC., HERMENEGILDO COUGH, MARCEL LOEPZ, GILBERT MARTINEZ, and DOES 110 Defendants

Case No. C08-01522 JW STIPULATION FOR ONE WEEK EXTENSION TO FILE JOINT PRE0TRIAL CONFERENCE STATEMENT, PROPOSED JURY INSTRUCTIONS AND MOTIONS IN LIMINE & [PROPOSED] ORDER Judge: Honorable James Ware Trial Date: March 10, 2010 Pre-Trial Conference: February 22, 2010

The Parties submit the following stipulation seeking an extension to file Joint Pre-Trial Conference Statement, Proposed Jury Instructions, and Motions in Limine due to the special circumstances described below: 1. 2. The final pre-trial conference in this case is set on February 22, 2010. There are two Plaintiffs in this case. Plaintiff Leonardo Espinoza is currently

incarnated in Oregon. Plaintiff Sergio Rogue is scheduled for a sentencing hearing for a felony charge on February 22, 2010 and it is yet unclear whether jail time will be imposed.
Espinoza, et. al. v. C&C Security STIPULATION FOR EXTENSION

Patrol., et al.

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3.

Given the circumstances, parties are making the last efforts to resolve this matter

by way of settlement. 4. Because of the incarceration of Plaintiff Espinoza, it is difficult to communicate

settlement offers and obtain settlement authorities from Mr. Espinoza. 5. Parties wish to have more time to work out a settlement before spending substantial

amount of time in preparing for the pre-trial filings that are due on January 22, 2010. 6. As such, parties agree and stipulate to seek one week extension to file Joint Pre-

Trial Conference Statement, proposed jury instructions, and motions in limine until January 29, 2010, and all other dates remain unchanged. Respectfully submitted, Dated: January 21, 2010 By: /s/ Adam Wang Adam Wang Attorney for Plaintiffs Dated: January 21, 2010 By: /s/ Sejal Thakkar
Sejal Thakkar

Attorney for Defendants ___________________________________________________________ [PROPOSED] ORDER
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Espinoza, et. al. v. C&C Security STIPULATION FOR EXTENSION

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Pursuant to parties stipulation, good cause shown, IT IS HEREBY ORDERED that parties shall file their Joint Pre-trial Conference Statement, proposed jury instructions, and motions in limine no later than January 29, 2010. All other dates set in this case remain unchanged. IT IS SO ORDERED. The Court will not entertain further requests for extension.
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By: ____________________ JAMES WARE US DISTRICT JUDGE

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