Free Stipulation and Order - District Court of California - California

Case 3:08-cv-00146-BZ

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Filed 08/28/2008

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HENRY E. FARBER (CA State Bar No. 110553) 1 DAVIS WRIGHT TREMAINE LLP 777 108th Avenue NE 2 Bellevue, Washington 98004-5149 Telephone: (425) 646-6100 3 Facsimile: (425) 646-6199 [email protected] 4 AARON ROBLAN (CA State Bar No. 244308) 5 DAVIS WRIGHT TREMAINE LLP 505 Montgomery Street, Suite 800 6 San Francisco, California 94111-6533 Telephone: (415) 276-6500 7 Facsimile: (415) 276-6599 [email protected] 8 Attorneys for Defendants 9 MATHESON POSTAL SERVICES, INC. and MARCO BARRAGAN 10 11

DAVIS WRIGHT TREMAINE LLP

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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION JORGE ANGULO, an individual, ) ) Plaintiff, ) ) v. ) ) MATHESON POSTAL SERVICES, a California ) Corporation, MARCOS BARRAGAN, and ) DOES 1-25 inclusive, ) ) Defendants. ) ) 0 0 ) ) Case No. C08-00146 BZ STIPULATION TO CONTINUE THE DEADLINES FOR NON-EXPERT DISCOVERY AND DISPOSITIVE MOTIONS Date: Time: August 26, 2008 2:00 p.m.

Hon. Bernard Zimmerman

Pursuant to Civil L.R. 7-12, the parties, through their undersigned counsel, stipulate as follows: 1. By Order of the court, dated April 29, 2008, the Parties to this action were required

to complete Non-expert Discovery by August 29, 2008. Furthermore, that same order set the deadline for hearing Dispositive Motions as October 22, 2008. Due to scheduling conflicts and attempts to resolve this matter without the need for further litigation, the Parties require additional
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1 time to complete discovery in this matter. 2 2. The Parties Stipulate and Agree that an extension of the deadline for Non-Expert

3 Discovery to October 1, 2008 and an extension of the deadline for Dispositive Motions to 4 November 25, 2008 will permit them the appropriate time to attempt complete discovery and seek 5 resolution of this matter without the need for trial. 6 3. Accordingly, the Parties jointly request the Court enter an Order setting the

7 following deadlines: 8 9 10 11 Completion of Non-expert Discover by October 1, 2008 Last day for hearing Dispositive Motions, November 25, 2008.

DAVIS WRIGHT TREMAINE LLP

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Respectfully submitted, DAVIS WRIGHT TREMAINE LLP By: /s/ Aaron Roblan Aaron Roblan

Attorneys for Defendants MARCO BARRAGAN and MATHESON POSTAL SERVICES, INC. TENAX LAW GROUP By: Christopher Arras Attorneys for the Plaintiff JORGE ANGULO

PURSUANT TO STIPULATION, IT IS SO ORDERED: that the deadline for non-expert discovery is extended to October 1, 2008. All other August 28, 2008 Date: _____________________ deadlines remain the same.
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Proof of Service

I, Christina Karo, declare under penalty of perjury under the laws of the State of California 3 that the following is true and correct: 4 I am employed in the City and County of San Francisco, State of California, in the office of a member of the bar of this court, at whose direction the service was made. I am over the age of 5 eighteen (18) years, and not a party to or interested in the within-entitled action. I am an employee of DAVIS WRIGHT TREMAINE LLP, and my business address is 505 Montgomery Street, Suite 6 800, San Francisco, California 94111-6533. 7 8 9 10 11 I caused to be served the following document: STIPULATION TO CONTINUE THE DEADLINES FOR NON-EXPERT DISCOVERY AND DISPOSITIVE MOTIONS I caused the above document to be served on each person on the attached list by the following means: I enclosed a true and correct copy of said document in an envelope and placed it for collection and mailing with the United States Post Office on August 27, 2008 following the ordinary business practice. (Indicated on the attached address list by an [M] next to the address.) I enclosed a true and correct copy of said document in an envelope, and placed it for collection and mailing via Federal Express on [ ], for guaranteed delivery on [ ], following the ordinary business practice. (Indicated on the attached address list by an [FD] next to the address.) I consigned a true and correct copy of said document for facsimile transmission on _____________. (Indicated on the attached address list by an [F] next to the address.) I enclosed a true and correct copy of said document in an envelope, and consigned it for hand delivery by messenger on (Indicated on the attached address list by an [H] next to the address.)

DAVIS WRIGHT TREMAINE LLP

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I am readily familiar with my firm's practice for collection and processing of 21 correspondence for delivery in the manner indicated above, to wit, that correspondence will be deposited for collection in the above-described manner this same day in the ordinary course of 22 business. 23 24 25 26 27 28
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Executed on August 27, 2008, at San Francisco, California. /s/ Christina Karo Christina Karo

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Key: [M] Delivery by Mail [F] Delivery by Facsimile

Service List
[FD] Delivery by Federal Express [FM] Delivery by Facsimile and Mail [H] Delivery by Hand

3 4 5 6 7 8 9 10 11 [M]

Attorneys for John W. Schilt Christopher Arras Tenax Law Group LLP 145 Park Place, Suite A Point Richmond, CA 94801 Plaintiff

DAVIS WRIGHT TREMAINE LLP

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