Feske et al v. MHC Thousand Trails Limited Partnership et al

Filing 10

STIPULATION AND ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE re 9 Stipulation filed by MHC Operating Limited Partnership, MHC Thousand Trails Limited Partnership, Thousand Trails Management Services, Inc. Signed by Judge Paul S. Grewal on September 1, 2011. (psglc1, COURT STAFF) (Filed on 9/1/2011)

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JENNER & BLOCK LLP
David J. Bradford (pro hac vice application pending)
353 N. Clark St.

Chicago, Ilinois 60654
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Telephone: [phone]

4 Jean M. Dohert (CaL. Bar No. 264308)

633 West 5th Street, Suite 3500

5 Los Angeles, California 90071

6 Telephone: [phone]

COUNSEL FOR DEFENDANTS

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SHENKMAN & HUGHES

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Kevin 1. Shenkan (CaL. Bar No. 223315)

8905 Wight Road

9 Malibu, California 90265

Telephone: [phone]
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R. REX P ARRS LAW FIRM
R. Rex Paris (CaL. Bar No. 96567)

12 2220 10th St. West, Suite 109
Lancaster, California 93534
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Telephone: [phone]

COUNSEL FOR PLAINTIFFS
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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA (SAN JOSE DIVISION)

18 DAVID FESKE and TERI FESKE, individually )

Case No. 11-04124 (PSG)

19 and on behalf of Class Members, ~
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Plaintiffs,

) STIPULATION AND (PROPOSED) ORDER

TO CONTINUE CASE MANAGEMENT
) CONFERENCE
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v.

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)
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LIFESTYLE PROPERTIES, INC., a Marland )
24 corporation; THOUSAND TRAILS
)
MANAGEMENT SERVICES, INC., a Nevada )
25 corporation, and Does 1-100, inclusive,
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Defendants.
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22 MHC THOUSAND TRAILS LIMITED
PARTNERSHIP, MHC OPERATING
23 LIMITED PARTNERSHIP, EQUITY

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Stipulation And (Proposed) Order to Continue Case Management Conference

1 Stipulation to Continue Case Management Conference
2 Pursuant to Local Rules 6-2 and 7-12, Plaintiffs David and Ted Feske and Defendants MHC

3 Thousand Trails Limited Parership, MHC Operating Limited Parership, Equity Lifestyle
4 Properties, Inc., and Thousand Trails Management Services, Inc., (together ''te Paries"), hereby
5 stipulate that the Case Management Conference curently scheduled for September 13,2011, be

6 continued to September 27,2011. The Paries base their stipulation on the following grounds:
7 1. Defendants removed this case to this Cour on August 27, 2011;

8 2. The case management statement is curently due on September 6, 2011;
9 3. Counsel have conferred and believe that additional time would be helpful in preparing a

10 productive case management order;
11 4. Lead counsel for defendants is generally unavailable between now and September 6,2011,

12 due to an absence from the office for the wedding of his son;

13 5. No previous time modifications have been sought in this case, either by stipulation or Cour

14 order; and
15 6. The two-week modification requested wil not negatively impact the schedule for the case,

16 given that no Case Management Conference has yet been held, no motions have been filed and the
1 7 Paries are in the process of meeting-and-conferring in order to prepare their Joint Case Management
18 Statement.

19 In light of the foregoing, the Paries respectfully request that the Cour enter the Paries'
20 Stipulation and continue the Case Management Conference until September 27,2011.

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22 Respectfully Submitted,
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JENNER & BLOCK LLP

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26 DATE: 8/31/20 I ,
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Je M. Dohert

One of the Attorneys for Defendants

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Stipulation and (Proposed) Order to Continue Case Management Conference

SHENKMAN & HUGHES

Kt(\~.~~
Kevin 1. Shenkan
One of the Attorneys for Plaintiffs

The parties are reminded to file their consent or declination to magistrate judge jurisdiction no later than 9/6/2011.

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10 DATE:

September 1, 2011

The Honorable Paul S. Grewal

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Stipulation and (Proposed) Order to Continue Case Management Conference

PROOF OF SERVICE

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I, Diana Valdez, declare I am employed in the County of Los Angeles, State of California. I
am over the age of 18 and not a pary to the within action. My business address is Jenner & Block
LLP, 633 West 5th Street, Suite 3500, Los Angeles, California 90071.

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On August 31,2011, I served the documents described below:
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STIPULATION AND (PROPOSED) ORDER TO
CONTINUE CASE MANAGEMENT CONFERENCE

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on the interested parties in this action as follows:

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Kevin 1. Shenkan
Mary R. Hughes
Shenkan & Hughes

28905 Wight Road
Malibu, CA 90265

R. Rex Parris
Alexander R. Wheeler
Kitty K. Szeto
R. Rex Paris Law Firm
42220 10th St West, Suite 109

Lancaster, CA 93534

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It BY U.S. MAIL: By placing the document(s) listed above in a sealed envelope with postage
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thereon fully prepaid, in the United States mail at Los Angeles, California, addressed as set forth
below. I am familar with the firm's practice of collection and processing corresponden~e for
mailng. Under that practice, it would be deposited in the United States Postal Service on that same
day with postage thereon fully prepaid in the ordinary course of business.

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o BY ELECTRONIC MAIL: In addition to service by overnight delivery, I transmitted a

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below

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copy of

the foregoing document(s) on this date via electronic mail to the e-mail addresses shown

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o BY OVERNIGHT DELIVERY: I caused such envelope to be placed for collection and

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delivery on this date in accordance with standard overnight delivery procedures.

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o BY PERSONAL SERVICE: I caused such envelope to be delivered by hand to the person(s)

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listed above.
o (State) I declare under penalty of perjury under the laws of the State of California that the

foregoing is true and correct.

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It (Federal) I declare under penalty of

perjury that the foregoing is true and correct

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I declare under penalty of perjury under the laws of the State of Californa that the foregoing
is true and correct.

Executed on August 31,2011, at Los An eles, California.

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PROOF OF SERVICE