Phan v. Grand Bahama Cruise Line, LLC et al

Filing 30

ORDER GRANTING 29 STIPULATION REGARDING BRIEFING SCHEDULE AND CASE MANAGEMENT CONFERENCE. Case Management Conference set for 4/7/2016 11:00 AM.Signed by Judge Beth Labson Freeman on 1/4/2016. (blflc2S, COURT STAFF) (Filed on 1/4/2016)

1 GLANCY PRONGAY & MURRAY LLP
Lionel Z. Glancy (#134180)
2 Marc L. Godino (#182689)
Mark S. Greenstone (#199606)
3 1925 Century Park East, Suite 2100
Los Angeles, California 90067
4 Telephone: [phone]
Facsimile: [phone]
5 Email:
[e-mail]
[e-mail]
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[e-mail]
[e-mail]
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JAURIGUE LAW GROUP
8 Michael J. Jaurigue (#208123)
Abigail A. Zelenski (#228610)
9 David Zelenski (#231768)
114 North Brand Boulevard, Suite 200
10 Glendale, California 91203
Telephone: [phone]
11 Facsimile: [phone]
Email:
[e-mail]
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[e-mail]
[e-mail]
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Attorneys for Plaintiff An Phan
14 [Additional Counsel Listed on Signature Page]
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION

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AN PHAN, Individually and on Behalf of All
18 Others Similarly Situated,
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Plaintiff,
v.

21 GRAND BAHAMA CRUISE LINE, LLC, a
limited-liability company; BAHAMAS
22 PARADISE CRUISE LINE, LLC, a limitedliability company; CRUISE OPERATOR,
23 INC., d/b/a BAHAMAS PARADISE CRUISE
LINE, a corporation; and Does 1 through 50,
24 inclusive,
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Case No. 15-cv-05019-BLF
STIPULATION AND [PROPOSED]
ORDER TO SET BRIEFING SCHEDULE
FOR MOTION TO DISMISS AND TO
RESCHEDULE CASE MANAGEMENT
CONFERENCE

Defendants.

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321891.1

STIPULATION AND [PROPOSED] ORDER
Case No. 15-cv-05019-BLF

Plaintiffs An Phan and Taylor Bartlett (“Plaintiffs”), and Defendants Bahamas Paradise Cruise

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2 Line, LLC and Cruise Operator, Inc. (“Defendants”),1 hereby submit the following Stipulation and
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[Proposed] Order to Set Briefing Schedule for Motion to Dismiss and to Reschedule Case
Management Conference:
WHEREAS Plaintiffs’ Opposition to Defendants’ Motion To Dismiss Or, In The Alternative,

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Stay The Action (“Motion”) is currently due on January 11, 2016, and Defendants’ Reply is due on

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WHEREAS the Case Management Conference in this matter is currently scheduled for

10 January 28, 2016;
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WHEREAS Plaintiffs’ counsel have multiple depositions and dispositive motions in other
cases either scheduled, or to be scheduled, for the month of January, 2016; and
WHEREAS the hearing on Defendants’ Motion to Dismiss is currently set for April 7, 2016;

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NOW THEREFORE, in the interest of efficiency and judicial economy, it is hereby stipulated

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16 and agreed, subject to the Court’s approval, that:
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1.

Plaintiffs’ Opposition to Defendants’ Motion shall be due on February 19, 2016;

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2.

Defendants’ Reply in support of its Motion shall be due on March 17, 2016; and

3.

The Case Management Conference shall be vacated and rescheduled for April 7, 2016

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or a date thereafter as determined by the Court.

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321891.1

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1 Defendant Grand Bahama Cruise Line, LLC has not appeared in this action.
STIPULATION AND [PROPOSED] ORDER
Case No. 15-cv-05019-BLF
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1 DATED: January 4, 2016

Respectfully submitted,

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GLANCY PRONGAY & MURRAY LLP

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By: s/ Mark S. Greenstone
Lionel Z. Glancy
Marc L. Godino
Mark S. Greenstone
1925 Century Park East, Suite 2100
Los Angeles, California 90067
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
[e-mail]

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JAURIGUE LAW GROUP
Michael J. Jaurigue
Abigail A. Zelenski
David Zelenski
114 North Brand Boulevard, Suite 200
Glendale, California 91203
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]

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Attorneys for Plaintiff An Phan

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21 Dated: January 4, 2016
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321891.1

GREENSPOON MARDER, P.A.
By: s/ Jeffrey A. Backman
Richard W. Epstein
Jeffrey A. Backman
Roy Taub
200 East Broward Blvd., Suite 1800
Fort Lauderdale, FL 33301
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
STIPULATION AND [PROPOSED] ORDER
Case No. 15-cv-05019-BLF
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LAW OFFICES OF ROBERT S. BOULTER
Robert S. Boulter (SBN 153549)
1101 Fifth Avenue, Suite 235
San Rafael, California 94901-1828
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Defendants Bahamas Paradise
Cruise Line, LLC and Cruise Operator, Inc.

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321891.1

STIPULATION AND [PROPOSED] ORDER
Case No. 15-cv-05019-BLF
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[PROPOSED] ORDER
Having reviewed the parties’ Stipulation and [Proposed] Order to Set Briefing Schedule for
Motion to Dismiss (“Motion”) and to Reschedule Case Management Conference, and good cause
appearing, IT IS HEREBY ORDERED THAT:
1.

Plaintiffs’ Opposition to Defendants’ Motion shall be due on February 19, 2016;

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2.

Defendants’ Reply in support of its Motion shall be due on March 17, 2016; and

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3.

The Case Management Conference shall be vacated and rescheduled for April 7, 2016

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10 or a date thereafter as determined by the Court.
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Dated: January 4, 2016

_________________________________
The Honorable Beth Labson Freeman
United States District Judge

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321891.1

STIPULATION AND [PROPOSED] ORDER
Case No. 15-cv-05019-BLF
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PROOF OF SERVICE VIA ELECTRONIC POSTING PURSUANT TO NORTHERN
DISTRICT OF CALIFORNIA LOCAL RULES AND LOCAL CIVIL RULE 5-1
I, the undersigned, say:
I am a citizen of the United States and am employed in the office of a member of the Bar of
this Court. I am over the age of 18 and not a party to the within action. My business address is
1925 Century Park East, Suite 2100, Los Angeles, California 90067.
On January 4, 2016, I caused to be served the following document:
STIPULATION AND [PROPOSED] ORDER TO SET BRIEFING SCHEDULE
FOR MOTION TO DISMISS AND TO RESCHEDULE CASE MANAGEMENT
CONFERENCE
By posting the document to the ECF Website of the United States District Court for the
Northern District of California, for receipt electronically by the parties as reflected on the attached
Court’s Service List.
I certify under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct. Executed on January 4, 2016, at Los Angeles, California.

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s/ Mark S. Greenstone
Mark S. Greenstone

CAND-ECF-

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Jeffrey Aaron Backman
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Robert Samuel Boulter
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Richard Wayne Epstein
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Lionel Z. Glancy
[e-mail],[e-mail],[e-mail]
Marc Lawrence Godino
[e-mail],[e-mail]
Mark Samuel Greenstone
[e-mail]
Michael Joe Jaurigue
[e-mail]
Roy Taub
[e-mail]
Abigail Ameri Zelenski
[e-mail]
David Zelenski
[e-mail]

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1/4/2016 9:25 AM