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Urango v. Frozen Food Express Industries Inc.

United States District Court, E.D. California, Sacramento Division

February 13, 2014

ADAM URANGO, individually and on behalf of other persons similarly situated, Plaintiff(s),
v.
FROZEN FOOD EXPRESS INDUSTRIES, INC., a Texas Corporation, and DOES 1 through 10, Defendant(s)

DAVID S. BINDER, ESQ., SIGLAIT SHOGHI, ESQ., THARPE & HOWELL, LLP, Sherman Oaks, California, Attorneys for Defendant, FFE TRANSPORTATION SERVICES, INC. erroneously sued and served as FROZEN FOOD EXPRESS INDUSTRIES, INC.

LAW OFFICES OF ARI MOSS LAW OFFICE KENNETH GOLDMAN LAW OFFICE OF LOWELL STEIGER ARI E. MOSS, Attorney for Plaintiff, ADAM URANGO

STIPULATION AND ORDER TO CONTINUE HEARING OF PLAINTIFF'S MOTION TO AMEND COMPLAINT

TROY L. NUNLEY, District Judge.

Plaintiff ADAM URANGO, on behalf of himself and all others similarly situated, and Defendant FROZEN FOOD EXPRESS INDUSTRIES, INC., hereby stipulate by and through their respective counsel as follows:

WHEREAS, Plaintiff, Adam Urango's Motion for Leave to Amend the Complaint is set for hearing on February 27, 2014 at 2:00 p.m. in Courtroom 2 of the Robert T. Matsui United States Courthouse.

WHEREAS, counsel for Defendant, FFE Transportation Services, Inc. will be unable to appear at the above referenced Hearing due to several pre-existing scheduling conflicts.

WHEREAS one of Defense counsel's conflicts is a Further Status Conference also scheduled for February 27, 2014 at 1:45 p.m. in department 322 of the Los Angeles Superior Court, a true and correct copy of the docket reflecting this scheduling conflict is attached hereto as Exhibit "A."

WHEREAS another of Defense counsel's conflicts is a Hearing on a Motion to Compel Arbitration also scheduled for February 27, 2014 at 1:30 p.m. in department C06 of the Orange County Superior Court, a true and correct copy of the docket reflecting this additional scheduling conflict is attached hereto as Exhibit "B."

WHEREAS the parties to this action agree that Defense counsel's scheduling conflicts constitute good cause to continue the above referenced hearing of Plaintiff's Motion for Leave to Amend the Complaint.

WHEREAS to avoid any prejudice to the Plaintiff, with regard to the third cause of action in the Plaintiff's proposed First Amended Complaint, the Defendant will agree to toll the statute of limitations for the cause of action an equal number of days between the current hearing date and the date that the motion is rescheduled for hearing, which number shall in no way exceed 30 days.

NOW, THEREFORE, IT IS HEREBY AGREED AND STIPULATED by both parties, by and through their respective counsel as follows:

1. The Hearing of Plaintiff's Motion to Amend the Complaint currently scheduled for February 27, 2014 at 2:00 p.m. in Courtroom 2 of the Robert T. Matsui United States Courthouse will be continued two weeks to March 13, 2104 at 2:00 p.m. in Courtroom 2 of the Robert T. Matsui United States Courthouse or such other date as the Court deems proper.
2. With regard to the third cause of action in the Plaintiff's proposed First Amended Complaint, the Defendant will agree to toll the statute of limitations for the cause of action an equal number of days between the current hearing date (February 27, 2014) and the date that the motion is rescheduled for hearing, which number shall in no way exceed 30 days.
3. This stipulation may be signed in counterparts.
4. Facsimile or copies of the parties' signature on this stipulation may be treated as originals for all purposes.

IT IS SO STIPULATED.

ORDER

1. The Hearing of Plaintiff's Motion to Amend the Complaint currently scheduled for February 27, 2014 at 2:00 p.m. will be continued two weeks to March 13, 2014 at 2:00 p.m. in Courtroom 2 of the Robert T. Matsui United States Courthouse.
2. With regard to the third cause of action in the Plaintiff's proposed First Amended Complaint, the Defendant will agree to toll the statute of limitations for the cause of action an equal number of days between the current hearing date (February 27, 2014) and the date that the motion is rescheduled for hearing, which number shall in no way exceed 30 days.

IT IS SO ORDERED.


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