The opinion of the court was delivered by: Charles R. Breyer R United States District Court Judge
[Complaint Filed March 2, 2012]
[Amended Complaint Filed May 10, 2012]
JOINT STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; SMRH:407678588.1 JOINT STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE
COME NOW counsel for Plaintiff and Defendant to jointly request that the Court continue 2 the date for the Case Management Conference ("CMC") from January 25, 2013 to February 8, 3 2013 at 8:30 a.m. 4
On December 4, 2012, the Court issued an order setting the CMC for January 18, 2013.
Defendant's counsel has a previously set site inspection in another case which has been required 6 by Court order. The parties jointly agreed, and the Court ordered, the CMC continued to January 25th. Subsequently, Plaintiff's counsel had a motion hearing in another matter set for the 25th at 8 9:00 a.m. in San Jose. 9
Plaintiff's counsel conferred with Defense counsel, Hayley Grunvald, and Ms. Grunvald is 10 agreeable to moving the CMC to February 8, 2013. 11 Plaintiff's counsel confirmed with the Clerk of this Court that February 8th is available to 12 set the CMC. 13
The parties agree that moving the CMC to February 8th will not cause any delay in the 14 progress of this case because they are working cooperatively to exchange information in 15 preparation for settlement negotiations.
The parties jointly request that the January 25, 2013, CMC be held on February 8, 2013.
Dated: January 10, 2013 18 LAW OFFICES OF PAUL L. REIN 17 19 20 By /s/ Celia McGuinness PAUL L. REIN 21 CELIA McGUINNESS CATHERINE M. CABALO 22 Attorneys for Plaintiff 23 FRANCISCA MORALEZ 24 25 26 27 28
Dated: January 10, 2013 2 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP By /s/ Hayley S. Grunvald RICHARD J. SIMMONS DEREK R. HAVEL HAYLEY S. GRUNVALD Attorneys for Defendant BOND CC OAKLAND, LLC
PURSUANT TO STIPULATION AND FOR GOOD CAUSE ...