Gomez et al v. True Leaf Farms, LLC et al

Filing 29

STIPULATION AND ORDER 26 Continuing Case Management Conference and Vacating Other Pending Deadlines. Case Management Conference set for 11/6/2015 10:30 AM in Courtroom 6, 4th Floor, San Jose. Signed by Judge Ronald M. Whyte on 8/11/15. (jgS, COURT STAFF) (Filed on 8/11/2015)

1
2
3
4
5
6
7
8
9
10

Michael C. Saqui, Esq., SBN: 147853
Jennifer Schermerhorn, Esq., SBN: 225070
Helen Braginsky, Esq., SBN: 282359
THE SAQUI LAW GROUP
Counselors to Management
1420 Rocky Ridge Drive, Suite 260
Roseville, California 95661
Telephone: [phone]
Facsimile:
[phone]
[e-mail]
[e-mail]
Attorneys for Defendants
TRUE LEAF FARMS, LLC
TRUE LEAF HOLDINGS, LLC
CHURCH BROTHERS, LLC
TOM CHURCH
STEVE CHURCH
DAVID GILL

11

UNITED STATES DISTRICT COURT

12

NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

13
14
15
16
17

Case No.: 5:15-cv-02928-RMW

RAFAEL GOMEZ, CESAR RUELAS, and
BRENDA ACEVEDO on behalf of themselves
and on behalf of all other similarly situated
individuals.

CLASS ACTION
STIPULATION AND []
ORDER CONTINUING CASE
MANAGEMENT CONFERENCE AND
VACATING OTHER PENDING
DEADLINES

Plaintiffs,
vs.

18
19
20
21
22
23
24

TRUE LEAF FARMS, LLC, a California
Limited Liability Company; TRUE LEAF
HOLDINGS, LLC., a California Limited
Liability Company; CHURCH BROTHERS,
LLC., a California Limited Liability Company;
TOM CHURCH, an individual; STEVE
CHURCH, an individual; DAVID GILL, an
individual; and DOES 1-50, inclusive,
Defendants.

25
26

Pursuant to Local Rule 6-2, Plaintiffs RAFAEL GOMEZ, CESAR RUELAS, and

27

BRENDA ACEVEDO (“Plaintiffs”) and Defendants TRUE LEAF FARMS, LLC, TRUE LEAF

28

HOLDINGS, LLC, CHURCH BROTHERS, LLC, TOM CHURCH, STEVE CHURCH and

1
Gomez, et. al. v. True Leaf Farms LLC, et. al
Case No. 5:15-cv-02928-RMW

Stipulation and [] Order re: Continuance of the
Case Management Conference

1

DAVID GILL (hereinafter “Defendants”) through their respective attorneys of record, stipulate as

2

follows.

3
4

WHEREAS, Plaintiffs filed a complaint in the above-referenced matter in the United States
District Court, Northern District of California on or about June 23, 2015;

5
6

WHEREAS, Defendants filed a Motion to Dismiss pursuant to Federal Rule of Civil
Procedure 12(b) on August 4, 2015 to be heard on or about October 9, 2015;

7
8

WHEREAS, the Case Management Conference is scheduled to occur on September 18,
2015;

9
10

WHEREAS, only one extension of time, for Defendants to file a response to Plaintiffs’
complaint in the above-referenced matter, has been previously requested and obtained;

11

WHEREAS, the parties agree that a 28-day continuance of the Case Management

12

Conference until after Defendants’ motion is heard on October 9, 2015, and all currently pending

13

deadlines, will permit a more efficient case management, will serve the interests of judicial

14

economy, and will conserve party and court resources;

15

///

16

///

17

///

18
19
20
21
22
23
24
25
26
27
28

2
Gomez, et. al. v. True Leaf Farms LLC, et. al
Case No. 5:15-cv-02928-RMW

Stipulation and [Proposed] Order re: Continuance of the
Case Management Conference

1
2

NOW, THEREFORE, pursuant to Civil Local Rule 6-2(a), the parties hereby stipulate and
agree, through their respective counsel, as follows:

3

The September 18, 2015 Case Management Conference and all currently pending deadlines

4

shall be taken off calendar, and rescheduled twenty-eight (28) days after the hearing date on

5

Defendants’ motion, on November 6, 2015, or on another date that is convenient for the Court,

6

November 6, 2015 at 10:30 a.m.
________________________________________.

7
8
9
10
11
12
13
14
15
16

IT IS SO STIPULATED.
DATED: August 5, 2015
THE SAQUI LAW GROUP
Counselors to Management

The Downey Law Firm, LLC

By: /s/ Jennifer M. Schermerhorn
Jennifer M. Schermerhorn
Attorneys for Defendants
TRUE LEAF FARMS, LLC
TRUE LEAF HOLDINGS, LLC
CHURCH BROTHERS, LLC
TOM CHURCH
STEVE CHURCH
DAVID GILL

By: /s/ Eric D. Rouen
Eric D. Rouen
Attorneys for Plaintiffs
RAFAEL GOMEZ, CESAR RUELAS, and
BRENDA ACEVEDO

17
18

PURSUANT TO STIPULATION, IT IS SO ORDERED.

19
20

8/11/15
DATED: ___________________

____________________________________
THE HONORABLE RONALD M. WHYTE
UNITED STATES DISTRICT JUDGE

21
22
23
24
25
26
27
28

3
Gomez, et. al. v. True Leaf Farms LLC, et. al
Case No. 5:15-cv-02928-RMW

Stipulation and [] Order re: Continuance of the
Case Management Conference