United States District Court, E.D. California, Fresno Division
STEPHEN HALE and O'BRIAN RANGEL Individually, on Behalf of Themselves, and All Others Similarly Situated, Plaintiffs,
ENSIGN UNITED STATES DRILLING (CALIFORNIA) INC. and ENSIGN UNITED STATES DRILLING, INC., Defendants.
Stephen Hale, Plaintiff, represented by Christopher J Kupka,
Levi & Korsinsky, pro hac vice & Jeff S. Westerman, Westerman
O'Brian Rangel, Plaintiff, represented by Christopher J
Kupka, Levi & Korsinsky, pro hac vice & Jeff S. Westerman,
Westerman Law Corp.
United States Drilling (California) Inc., Defendant,
represented by David J Cooper, Klein, Denatale, Goldner,
Cooper, Rosenlieb & Kimball, LLP & Olivia Vanessa Franco
Chavez, Klein DeNatale Goldner.
United States Drilling Inc, Defendant, represented by David J
Cooper, Klein, Denatale, Goldner, Cooper, Rosenlieb &
Kimball, LLP & Olivia Vanessa Franco Chavez, Klein DeNatale
STIPULATION AND PROPOSED ORDER TO CONTINUE STATUS
CONFERENCE; [PROPOSED] ORDER (Doc. 41)
JENNIFER L. THURSTON, Magistrate Judge.
Stipulation is made by and between Plaintiffs STEPHEN HALE
and O'BRIAN RANGEL ("Plaintiffs") and
Defendants ENSIGN UNITED STATES DRILLING (CALIFORNIA), INC.
and ENSIGN UNITED STATES DRILLING, INC. (collectively
"Defendants") through their attorneys of record in
this case, with reference to the following facts:
July 7, 2015, Plaintiffs filed this putative class action
alleging violations of the Worker Adjustment and Retraining
Notification Act ("WARN Act"), codified at 29
U.S.C. Â§ 2101 et seq. and California Labor Code Â§
1400 et seq. ("Cal-WARN Act");
Defendants Ensign United States Drilling, Inc. and Ensign
United States Drilling (California), Inc. answered the
Complaint on September 2, 2015;
January 14, 2016, Plaintiffs served Defendant Ensign United
States Drilling (California), Inc. with Plaintiffs' First
Request for Production of Documents;
April 18, 2016, the Parties filed a Stipulation to dismiss
Defendant Ensign Energy Services, Inc. without prejudice;
April 21, 2016, the Court issued a Scheduling Order following
the Initial Scheduling Conference on April 20, 2016, in which
a. Ordered Defendants to file the motion for summary judgment
discussed at the Initial Scheduling Conference no later than
May 13, 2016, along with a joint statement of undisputed
b. Set two status conferences on July 7, 2016 and on January
13, 2017 and ordered the parties to file a joint status
conference report one week before each conference;
c. Specified that the joint statement shall outline the
discovery that has been completed and that which needs to be
completed related to the motion for summary judgment as well
as any impediments to complying ...