Torres et al v. Peninsula Household Services Inc., et al

Filing 40

ORDER Approving 39 Stipulation as Modified by the Court. Signed by Judge Paul S. Grewal on April 11, 2011. (psglc2, COURT STAFF) (Filed on 4/11/2011)

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ADAM WANG, Bar. No. 201233
LAW OFFICES OF ADAM WANG
12 South First Street, Suite 708
San Jose, CA 95113
Tel: [phone]
Fax: [phone]
[e-mail]
Attorney for Plaintiff
GUILLERMO VEGA
MICHAEL JAY JONES
GALLAGHER, REEDY & JONES
19A North Santa Cruz Avenue
Los Gatos, CA 95030
408-354-1388
Fax: [phone]
Email: [e-mail]
Attorney for Defendant,
PENINSULA HOUSEHOLD SERVICES, INC.
MICHAEL H. GOFF

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UNITED STATES DISTRICT COURT

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FOR DISTRICT OF NORTHERN CALIFORNIA
Case No.: C09-6057 PSG

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TORRES, et. al.,

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Plaintiffs,

STIPULATION TO CONTINUE
DEADLINE TO FILE DISMISSAL

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vs.
PENINSULA HOUSEHOLD SERVICES, et al.,
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Defendants

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Parties, through their respective counsel, stipulate as follows:

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1.

On March 4, 2011, this Court issued an order to show cause why Plaintiff's
counsel should not be sanctioned for his failure to comply with this Court's order.

2.

In reply, on March 11, 2011, Plaintiff's filed with the Court a response and notice
that the parties reached a settlement agreement in this matter as of March 9, 2011.

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xxxxxxxxxx
STIPULATION AND [PROPOSED] ORDER
Vega v. Peninsula Household Services Inc., et al.
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Case No. C09-6057 PSG

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3.

In the Plaintiff's filing of March 11, 2011, Plaintiff informed the Court that,

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having reached an agreement on settlement, Parties were preparing a final written

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agreement.

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4.

Parties to file a stipulated dismissal no later than April 8, 2011.

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5.

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6.

Agreement at this time has been completed, and no further changes are
anticipated.

7.

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Parties were unable to both finalize and execute the agreement in the time
allotted.

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Therefore, the court issued a standby order to show cause re: dismissal, ordering

Counsel for parties are in the process of arranging for the execution of the
agreement by their respective clients.

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Schedule of counsel and of clients precludes this from occurring by the

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established deadline, but counsel anticipate the agreement will be executed within

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the next 7 to 10 days.

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9.

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As such, parties hereby stipulate to a two extension of time to execute the
agreement and file a dismissal.

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Therefore, based on this stipulation the parties respectfully request a two (2) week

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extension of time to file the dismissal as ordered by the Court, with the dismissal

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to be filed no later than 4/22/2011, and the corresponding standby order to show

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cause be moved to 4/26/2011.

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Dated: April 8, 2011

By: /s/ Adam Pedersen
Adam Pedersen
Attorney for Plaintiff

Dated: April 8, 2011

By: /s/ Michael J. Jones
Michael J. Jones
Attorney for Defendants

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.

.

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STIPULATION AND xxxxxxxxxx ORDER
[PROPOSED]
Vega v. Peninsula Household Services Inc., et al.
2

Case No. C09-6057 PSG

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xxxxxxxxxx ORDER
[PROPOSED]

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GOOD CAUSE APPEARING, pursuant to parties’ stipulation, IT IS SO ORDERED.IN PART
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Parties shall file the stipulation for dismissal no later than April 22, 2011. If no dismissal
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is filed this Court the parties shall appear on April XX 2011 and show cause why the
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matter should not be dismissed. No further continuances or extensions
will be granted.
xxxxxxxxx
Dated: April 8, 2011
April 11, 2011

By:

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____________________________
Paul S. Grewal
United States Magistrate Judge

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xxxxxxxxxx
STIPULATION AND [PROPOSED] ORDER
Vega v. Peninsula Household Services Inc., et al.
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Case No. C09-6057 PSG