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

Filing 28

STIPULATION AND ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE re 26 Stipulation filed by MHC Operating Limited Partnership, MHC Thousand Trails Limited Partnership, Thousand Trails Management Services, Inc. Signed by Judge Paul S. Grewal on October 13, 2011. (psglc1, COURT STAFF) (Filed on 10/13/2011)

1 JENNER & BLOCK LLP
David J. Bradford (Pro Hac Vice)
2 Michael T. Brody (Pro Hac Vice)

353 North Clark Street
3 Chicago, Ilinois 60654

Telephone: [phone]

4

Jean M. Doherty (CaL. Bar No. 264308)

5 633 West 5th Street, Suite 3500
Los Angeles, California 90071
6 Telephone: (213) DEFENDANTS
COUNSEL FOR 239-5100

HUGHES

7 SHENKMAN &

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

8 8905 Wight Road

Malibu, California 90265
9 Telephone: [phone]

10 R. REX PARRS LA W FIRM
R. Rex Paris (CaL. Bar No. 965567)
Alexander R. Wheeler (CaL. Bar No 239541)
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2220 10th Street West, Suite 109

12 Lancaster, California 93534
Telephone: [phone]
COUNSEL FOR PLAINTIFFS
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14 UNITED STATES DISTRICT COURT
15 FOR THE NORTHERN DISTRICT OF CALIFORNIA (SAN JOSE DIVISION)
16 DAVID FESKE and TERI FESKE, individually
and on behalf of Class Members,
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Plaintiffs,
v.

19 MHC THOUSAND TRAILS LIMITED
PARTNERSHIP; MHC OPERATING

20 LIMITED PARTNERSHIP; EQUITY
LIFESTYLE PROPERTIES, INC., a Maryland
21 corporation;; THOUSAND TRAILS
MANAGEMENT SERVICES, INC.; a Nevada
22 corporation; and Does 1-100, inclusive,
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CASE NO. 11-04124 (PSG)

STIPULATION AND (PROPOSED) ORDER
TO CONTINUE CASE MANAGEMENT
CONFERENCE

Defendants.

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26
Stimilation Aiid Prol)osed Order

1 Pursuant to Local Rules 6-2 and 7-12, Plaintiffs David and Teri Feske and Defendants MHC

2 Thousand Trails Limited Parnership, MHC Operating Limited Partnership, Equity Lifestyle Properties,

3 Inc., and Thousand Trails Management Services, Inc., (together "the Parties"), hereby stipulate that the

4 Case Management Conference curently scheduled for October 18,2011, be continued to October 25,
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2011. The Paries base their stipulation on the following grounds:
1. The Case Management Conference was originally scheduled for September 13,2011.
2. The Paries previously requested that that Case Management Conference be continued to

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September 27 in order to give them adequate time to confer and prepare a case
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management statement in advance of the Case Management Conference, and this Court
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granted the Paries' request.

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3. This Cour then sua sponte continued the Case Management Conference from September
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27, 2011 to October 11, 2011, and then again continued the Case Management Conference

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sua sponte from October 11,2011 to October 18,2011 at 2:00 p.m.

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4. Lead counsel for Plaintiffs - from both firms representing Plaintiffs - are required to

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attend a hearing in Los Angeles Superior Court in Case No. BC464796 at 3:30 p.m. on

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October 18, 2011.

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5. The one-week modification requested wil not negatively impact the schedule for the case,

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given that no Case Management Conference has yet been held, and no motions have been

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filed.

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2

Stiimlation And Pnmosed Order

1 In light of

the foregoing, the Parties respectfully request that the Cour enter the Paries'

2 Stipulation and continue the Case Management Conference until October 25,2011.

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Dated: October 12,2011

Respectfully submitted:

SHENKMAN & HUGHES

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KEVIN 1. SHENKMAN

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By: lsI Kevin 1. Shenkan
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Attorneys for Plaintiffs David and Teri Feske,
individually and on behalf of Class Members

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Dated: October 12, 2011

Respectfully submitted:

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JENNER & BLOCK LLP

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DAVID J. BRADFORD
MICHAEL T. BRODY
JEAN M. DOHERTY

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By: lsI Jean M. Doherty
Attorneys for Defendants MHC Thousand Trails
Limited Partnership; MHC Operating Limited
Parnership; Equity Lifestyle Properties, Inc.; and
Thousand Trails Management Services, Inc.

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PURSUANT TO THE STIPULATION, IT IS SO ORDERED.

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DATE: October 13, 2011
The Honorable Paul S. Grewal

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Stipulation And Prol)osed Order

PROOF OF SERVICE

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I, Diana Valdez, declare I am employed in the County of Los Angeles, State of Californa. 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 October 12,2011, 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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II

Kevin 1. Shenkan
Mary R. Hughes
Shenkan & Hughes

28905 Wight Road
Malibu, CA 90265

R. Rex Paris

Alexander R. Wheeler
Kitty K. Szeto
R. Rex Pars 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 familiar with the firm's practice of collection and processing correspondence 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.

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

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

below

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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 (State) I declare under penalty of perjury under the laws of the State of California that the

foregoing is true and correct.

it

(Federal) I declare under penalty of perjury that the foregoing is true and correct

23 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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Executed on October 12,2011, at Lo~, Ca1ifOTQi~

A£Valdez
~
iana

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PROOF OF SERVICE