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David Rey v. C&H Sugar Company

November 27, 2012

DAVID REY,
PLAINTIFF,
v.
C&H SUGAR COMPANY, INC., A DELAWARE CORPORATION, AMERICAN SUGAR REFINING, INC., A DELAWARE CORPORATION, AND DOES 1-100, INCLUSIVE, DEFENDANT.



STIPULATION AND [PROPOSED] ORDER TO CONTINUE PRE-TRIAL CONFERENCE

The parties hereby stipulate and agree as follows:

WHEREAS; at the hearing on Defendants' motion for summary judgment on October 5, 6653779v1 Stipulation and Proposed Order Re: Pretrial Conference 2012, the Court continued the trial date in this matter to January 22, 2013, the same date as the 2 trial date currently set in the matter of Leatherbury v. C&H Sugar, et al., C-10-01969 SI, and 3 informed the parties that they should choose which of the two cases would go to trial on January 4 22, 2013; 5

WHEREAS; the parties have jointly agreed that the Rey mattershouldproceedtotrial 6 on January 22, 2012; 7

WHEREAS; the parties are awaiting a ruling on Defendants' summary judgment motion 8 in this matter, and wish as much as possible to avoid unnecessary trial preparation in the event 9 Defendants' motion for summary judgment is granted; 10

WHEREAS; the parties do not at this time wish to continue the trial date of January 22, 2013; 12

THE PARTIES HEREBY AGREE AND REQUEST a continuance of the Pretrial Conference and related dates as follows: 14 x Joint Pretrial Conference Statement due: December 18, 2012; x Pretrial Conference date: January 1, 2013;

6653779v1 Stipulation and Proposed Order Re: Pretrial Conference

DATED: November 26, 2012 GEONETTA & FRUCHT, LLP 2 By: /s/ Kenneth N. Frucht 3 Kenneth N. Frucht, Esq. Frederick J. Geonetta, Esq. 4 Attorneys for Plaintiffs DAVID REY 5 6 DATED: November 26, 2012 EPSTEIN BECKER & GREEN, P.C. 7 By: /s/ Matthew A. Goodin Steven R. Blackburn 8 Matthew A. Goodin 9 Attorneys for Defendants, C&H SUGAR COMPANY, INC. and 10 AMERICAN SUGAR REFINING, INC.

[PROPOSED] ORDER

IT IS HEREBY ORDERED that the pre-trial dates are continued as follows: 13 14

x Joint Pretrial Conference Statement due: December 18, 2012; 13 at 3:30 p.,m. x Pretrial Conference date: January 1, 2013; January 15,2013 at 3:30 p.m.

PURSUANT TO THE STIPULATION, IT IS SO ORDERED.

JUDGE OF THE ...


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