EVA FORRESTER, CHRISTOPHER M. FORRESTER, BRYAN THOMAS FORRESTER, AND STEPHANIE FORRESTER, Plaintiffs,
ORKIN, INC. and DOES 1 Through 20, inclusive, Defendants.
RIMAC MARTIN, P.C., ANNA M. MARTIN, San Francisco, CA.
DANIEL J. GERBER, RUMBERGER KIRK & CALDWELL, (admitted Pro Hac Vice), Orlando, FL, Attorneys for Defendants, ORKIN SERVICES OF CALIFORNIA, INC.;, (also improperly sued and served herein as ORKIN, INC., & ORKIN EXTERMINATING COMPANY, INC.).
SCOTT H.Z. SUMNER, KHORRAMI, LLP, Oakland, CA, Attorneys for Plaintiffs, EVA FORRESTER, CHRISTOPHER M. FORRESTER, BRYAN THOMAS FORRESTER, and STEPHANIE FORRESTER.
STIPULATION TO EXPEDITE HEARING DATE FOR PLAINTIFFS' MOTION TO REMAND TO STATE COURT AND MOTION TO ADD PARTY; [PROPOSED] ORDER
JON S. TIGAR, District Judge.
IT IS HEREBY STIPULATED by and between the Plaintiff EVA FORRESTER, and Defendant ORKIN SERVICES OF CALIFORNIA, INC., by and through their counsel of record herein, that the hearing date of June 27, 2013 at 2:00 p.m. for Plaintiffs' Motion to Add Party and Motion to Remand to State Court, filed on May 8, 2013, be expedited and rescheduled to be heard on an earlier date on Thursday, May 23, 2013 at 2:00 p.m. in Courtroom 9. To facilitate the Court's ability to hear this matter on an expedited basis, the parties have agreed to an expedited briefing schedule as well. On Monday, May 13, 2013, defendant Orkin filed its opposition to plaintiff's motions, and plaintiff will file her response brief on or before Friday, May 17, 2013.
Good cause exists for this request. On May 8, 2013, the Case Management Conference was held before the Honorable Jon S. Tigar. During the Conference, Mr. Sumner advised that he intended to file a motion to add a non-diverse defendant and a motion for remand to State court. The Court and the parties agreed that plaintiff's motions should be heard on an expedited basis as there are several impending deadlines which will require the parties to expend attorney fees and costs to comply with those deadlines. In the interests of the Court and the parties, plaintiff's Motion To Add A Party and To Remand To State Court and Motion should be heard on an expedited basis.
Plaintiffs' Motion to Remand to State Court and Motion to Add Party is expedited and rescheduled to be heard on Thursday, May ...