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Rafael Munoz, Lidia Cruz, Yanet Hernandez, Santos R. v. Giumarra Vineyards Corportion

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA FRESNO DIVISION


July 16, 2012

RAFAEL MUNOZ, LIDIA CRUZ, YANET HERNANDEZ, SANTOS R. VALENZUELA, TRINIDAD RUIZ, MARTA A. RINCON DE DIAZ, RAMON CERVANTES PERALES AND HUGO PEREZ RIOS ON BEHALF OF THEMSELVES, AND ALL CURRENT AND FORMER EMPLOYEES, AND ON BEHALF OF A CLASS OF SIMILARLY SITUATED EMPLOYEES, PLAINTIFFS,
v.
GIUMARRA VINEYARDS CORPORTION, A CALIFORNIA CORPORATION, AND DOES 1-20,
DEFENDANTS.

STIPULATION TO EXTEND TIME TO FILE OBJECTIONS TO PROPOSED FINDINGS AND RECOMMENDATIONS REGARDING CLASS CERTIFICATION

Defendant Giumarra Vineyards Corporation ("Giumarra") and Plaintiffs stipulate and agree to the following:

WHEREAS, Magistrate Judge Thurston issued findings and recommendations granting in part and denying in part plaintiffs' motion for class certification on July 5, 2012;

WHEREAS, Defendants' counsel Joseph E. Herman is seriously ill and has been advised by his doctor not to work for the next two weeks;

WHEREAS, Defendants' counsel Joseph C. Markowitz is in the process of moving his office. The move is scheduled for July 22, 2012, and the office will be disrupted in preparation for the move.

WHEREAS, in light of these severe time constraints, and the complexity of the issues raised by the voluminous record on the class certification, the parties need additional time to complete their papers.

WHEREAS, the parties agree that they will continue to pursue merits-related discovery with Defendant continuing to make documents available to Plaintiffs and arranging for Plaintiffs to scan and/or copy documents beginning July 24, 2012.

THEREFORE, IT IS HEREBY STIPULATED AND AGREED AND THE COURT IS REQESTED TO ORDER THE FOLLOWING:

Pursuant to 28 U.S.C. §636(b) (1)(B) and (c) and Local Rule 304(b), the time to file objections to the findings and recommendations of Magistrate Judge Thurston dated July 5, 2012 is extended to and including August 2, 2012.

Dated: July 12, 2012 LAW OFFICES OF JOSEPH E. HERMAN By: /s/ Joseph E. Herman Joseph E. Herman Dated: July 12, 2012 LAW OFFICES OF JOSEPH C. MARKOWITZ By: /s/ Joseph C. Markowitz Joseph C. Markowitz Attorneys for Defendant, Giumarra Vineyards Corporation Dated: July 12, 2012 MALLISON & MARTINEZ By: /s/ Stan S. Mallison Stan S. Mallison Attorney for Plaintiffs,

ORDER

IT IS SO ORDERED.

CHIEF UNITED STATES DISTRICT JUDGE

20120716

© 1992-2012 VersusLaw Inc.



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