Free Motion to Continue - District Court of California - California

Case 3:08-cv-01257-H-WMC

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Filed 09/05/2008

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B URKE , W ILLIAMS & S ORENS EN , LLP
ATTO RNEY S AT LAW LOS A NG EL ES

John P. Stennett, (SBN 72815) E-mail: [email protected] STENNETT & STENNETT 17600 N. Perimeter Drive Scottsdale, AZ 85255 Tel.: (619) 544-6887/Fax: (619) 233-3796 Attorneys for Plaintiff Ann Santilli Edith Sanchez Shea, (SBN 177578) E-mail: [email protected] BURKE, WILLIAMS & SORENSEN, LLP 444 South Flower Street, Suite 2400 Los Angeles, CA 90071-2953 Tel: 213.236.0600/Fax: 213.236.2700 Attorneys for Defendants First National Bank Holding Company Employee Benefit Plan and First National Bank Holding Company

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA ANN SANTILLI, Plaintiff, v. FIRST NATIONAL BANK HOLDING COMPANY EMPLOYEE; BENEFIT PLAN; FIRST NATIONAL BANK HOLDING COMPANY, Defendants. Case No. 08 CV 1257 H WMc JOINT STIPULATION TO CONTINUE DATE FOR EARLY NEUTRAL EVALUATION CONFERENCE CURRENT DATE: DATE: September 18, 2008 TIME: 2:00 p.m. CRTRM.: "C"

Plaintiff Ann Santilli and Defendants First National Bank Holding Company Employee Benefit Plan and First National Bank Holding Company, by and through their respective counsel, hereby stipulate and agree as follows. /// ///
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CASE NO. 08 CV 1257 H WMC
JNT. STIP. TO CONT. DATE FOR ENE CONF.

Case 3:08-cv-01257-H-WMC

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B URKE , W ILLIAMS & S ORENS EN , LLP
ATTO RNEY S AT LAW LOS A NG EL ES

The Court set an ENE Conference for September 18, 2008. The parties request a continuance of that ENE Conference date from September 18, 2008 to October 9, 2008. Good cause exists for this continuance, because the client representative who is scheduled to travel from Connecticut to attend the conference on Defendants' behalf will be out of the country during the week of September 18, 2008. Further, the undersigned counsel for Defendants was recently retained and requires additional time to obtain and review the relevant documents and prepare for the conference.

The parties request that the conference be continued for three weeks to October 9, 2008, because that is the next date when all parties and counsel are available. /// /// /// /// /// /// /// /// /// /// /// /// /// /// /// ///
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CASE NO. 08 CV 1257 H WMC
JNT. STIP. TO CONT. DATE FOR ENE CONF.

Case 3:08-cv-01257-H-WMC

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Filed 09/05/2008

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B URKE , W ILLIAMS & S ORENS EN , LLP
ATTO RNEY S AT LAW LOS A NG EL ES

Wherefore, the parties respectfully request that the hearing in this matter be continued for three weeks to October 9, 2008.

Dated:

September 5, 2008

STENNET & STENNETT JOHN P. STENNETT

By: /s/ John P. Stennett [authorized on September 5, 2008] John P. Stennett Attorneys for Plaintiff Ann Santilli E-mail: [email protected]

Dated: September 5, 2008

BURKE, WILLIAMS & SORENSEN, LLP EDITH S. SHEA

By:/s/ Edith S. Shea Edith Sanchez Shea Attorneys for Defendants First National Bank Holding Company Employee Benefit Plan and First National Bank Holding Company E-mail: [email protected]

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CASE NO. 08 CV 1257 H WMC
JNT. STIP. TO CONT. DATE FOR ENE CONF.

Case 3:08-cv-01257-H-WMC

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B URKE , W ILLIAMS & S ORENS EN , LLP
ATTO RNEY S AT LAW LOS A NG EL ES

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA ANN SANTILLI, Plaintiff, v. FIRST NATIONAL BANK HOLDING COMPANY EMPLOYEE; BENEFIT PLAN; FIRST NATIONAL BANK HOLDING COMPANY, Defendants. Having reviewed the parties' stipulation regarding the ENE conference date date in this matter, it is hereby Case No. 08 CV 1257 H WMc [PROPOSED] ORDER RE JOINT STIPULATION TO CONTINUE DATE FOR EARLY NEUTRAL EVALUATION CONFERENCE

ORDERED that the ENE Conference date in this matter is continued from September 18, 2008 to _____________________ at ____ _.m.

DATED: _____________

________________________________________ JUDGE, UNITED STATES DISTRICT COURT

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CASE NO. 08 CV 1257 H WMC
[PROPOSED] ORDER RE JNT. STIP. TO CONT. DATE FOR ENE CONF.

Case 3:08-cv-01257-H-WMC

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PROOF OF SERVICE

2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES I am employed in the County of Los Angeles, State of California. I am over the age of 18 years and not a party to the within action; my business address is 444 4 So. Flower Street, Suite 2400, Los Angeles, California 90071-2953. 3 On September 5, 2008, I served the following document(s) described as JOINT STIPULATION TO CONTINUE DATE FOR EARLY NEUTRAL 6 EVALUATION CONFERENCE and [PROPOSED] ORDER RE JOINT STIPULATION TO CONTINUE DATE FOR EARLY NEUTRAL 7 EVALUATION CONFERENCE on the interested party(ies) in this action as follows: 8 by placing true copies thereof enclosed in a sealed envelope addressed stated on the attached service list. 9 5 10 XX 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
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BY MAIL: I am "readily familiar" with the firm's practice of collecting and processing correspondence for mailing with the United States Postal Service. Under that practice, it would be deposited with the United States Postal Service that same day in the ordinary course of business. Such envelope was placed for collection and mailing with postage thereon fully prepaid at Los Angeles, California, on that same day following ordinary business practices. BY FACSIMILE: At approximately _____, I caused said document(s) to be transmitted by facsimile. The telephone number of the sending facsimile machine was (213) 629-0037. The name(s) and facsimile machine telephone number(s) of the person(s) served are set forth in the service list. The document was transmitted by facsimile transmission, and the sending facsimile machine properly issued a transmission report confirming that the transmission was complete and without error. BY OVERNIGHT DELIVERY: I deposited such document(s) in a box or other facility regularly maintained by the overnight service carrier, or delivered such document(s) to a courier or driver authorized by to receive documents, in an envelope or package designated by the overnight service carrier with delivery fees paid or provided for, addressed to the person(s) served hereunder. BY PERSONAL SERVICE: I personally delivered such envelope(s) to the addressee(s).

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BY ELECTRONIC SERVICE of the document(s) through the Court's transmission facilities.

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I declare under penalty of perjury under the laws of the United States of America and the State of California that the above is true and correct. I declare that 2 I am employed in the office of a member of the bar of this court at whose direction the service was made; served the above document(s) at the direction of 3 a member of the bar of this court. 1 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
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Executed on September 5, 2008, at Los Angeles, California. /s/ Sandra Bird SANDRA BIRD E-Mail: [email protected]

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SERVICE LIST Santilli v. First National Bank Holding Company Employee; et al. Case No.: 08 CV 1257 H WMc

5 John P. Stennett STENNETT & STENNETT 6 17600 N. Perimeter Drive Scottsdale, AZ 85255 7 Tel.: (619) 544-6887 Fax: (619) 233-3796 8 Attorneys for Plaintiff Ann Santilli 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
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