Hale v. Ensign United States Drilling Inc.

          Stephen Hale, Plaintiff, represented by Christopher J Kupka, Levi & Korsinsky, pro hac vice & Jeff S. Westerman, Westerman Law Corp.

          O'Brian Rangel, Plaintiff, represented by Christopher J Kupka, Levi & Korsinsky, pro hac vice & Jeff S. Westerman, Westerman Law Corp.

          Ensign 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.

          Ensign United States Drilling Inc, Defendant, represented by David J Cooper, Klein, Denatale, Goldner, Cooper, Rosenlieb & Kimball, LLP & Olivia Vanessa Franco Chavez, Klein DeNatale Goldner.

          STIPULATION AND PROPOSED ORDER TO CONTINUE STATUS CONFERENCE; [PROPOSED] ORDER (Doc. 41)

          JENNIFER L. THURSTON, Magistrate Judge.

         This 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:

         1. On 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. § 2101 et seq. and California Labor Code § 1400 et seq. ("Cal-WARN Act");

         2. Defendants Ensign United States Drilling, Inc. and Ensign United States Drilling (California), Inc. answered the Complaint on September 2, 2015;

         3. On January 14, 2016, Plaintiffs served Defendant Ensign United States Drilling (California), Inc. with Plaintiffs' First Request for Production of Documents;

         4. On April 18, 2016, the Parties filed a Stipulation to dismiss Defendant Ensign Energy Services, Inc. without prejudice;

         5. On April 21, 2016, the Court issued a Scheduling Order following the Initial Scheduling Conference on April 20, 2016, in which the Court:

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 facts;

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 ...