Filed: Feb. 15, 2013
Latest Update: Feb. 15, 2013
Summary: STIPULATION AND JOINT REQUEST TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE AND EXTEND INITIAL DEADLINES MARIA-ELENA JAMES>, Magistrate Judge. Plaintiff LIBORIO HERNANDEZ and ROGELIO RODRIGUEZ-PEREZ and Defendant NOR-CAL MOVING SERVICES, making a special appearance for purposes of this stipulation, through their attorneys' of record, hereby stipulate as follows: WHEREAS, an initial Case Management Conference is currently scheduled for February 21, 2013 at 10:00 a.m. WHEREAS, Defendant recen
Summary: STIPULATION AND JOINT REQUEST TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE AND EXTEND INITIAL DEADLINES MARIA-ELENA JAMES>, Magistrate Judge. Plaintiff LIBORIO HERNANDEZ and ROGELIO RODRIGUEZ-PEREZ and Defendant NOR-CAL MOVING SERVICES, making a special appearance for purposes of this stipulation, through their attorneys' of record, hereby stipulate as follows: WHEREAS, an initial Case Management Conference is currently scheduled for February 21, 2013 at 10:00 a.m. WHEREAS, Defendant recent..
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STIPULATION AND JOINT REQUEST TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE AND EXTEND INITIAL DEADLINES
MARIA-ELENA JAMES>, Magistrate Judge.
Plaintiff LIBORIO HERNANDEZ and ROGELIO RODRIGUEZ-PEREZ and Defendant NOR-CAL MOVING SERVICES, making a special appearance for purposes of this stipulation, through their attorneys' of record, hereby stipulate as follows:
WHEREAS, an initial Case Management Conference is currently scheduled for February 21, 2013 at 10:00 a.m.
WHEREAS, Defendant recently retained Jackson Lewis LLP as counsel in this matter, who promptly contacted Plaintiff's counsel to address deficiencies in Plaintiff's attempted service of the summons and complaint.
WHEREAS, Jackson Lewis LLP agreed to accept service of process by mail, including notice and acknowledgement of receipt, pursuant to applicable statutory requirements.
WHEREAS, Plaintiff intends to initiate service of process by mail concurrent with the filing of this stipulation and request for continuance.
WHEREAS, to allow the parties sufficient time to meaningfully meet and confer on all topics required by Federal Rules of Civil Procedure Rule 26, the Civil Local Rules, the Court's standing order, and to promote judicial economy, the parties believe it is appropriate to continue the initial case management conference to a date following the statutory period for Defendant to answer or otherwise respond to the complaint following valid service of process.
THEREFORE, IT IS HEREBY STIPULATED between the parties, through their respective counsel of record, a joint request for continuance of the initial case management conference to April 25, 2013, or such other date available to the Court, and if the case management conference is continued, all other deadlines set forth in the Court's Order Setting Initial Case Management Conference and ADR Deadlines will be continued accordingly.
ORDER
BASED ON THE PARTIES' STIPULATION, THE COURT'S FILE, AND GOOD CAUSE SHOWN, THE COURT ORDERS AS FOLLOWS:
The initial Case Management Conference and Rule 26 deadlines are continued as follows:
• Last Day to Meet and Confer Regarding Initial Discloses, ADR process election and discovery plan.
• Last Day to file ADR Certificate signed by Parties and Counsel.
• Last Day to either file a stipulation to ADR Process or Notice of Need for ADR Phone Conference.
• Last Day to File Rule 26(f) Report, complete initial disclosures and file Joint Case Management Statement.
• Last Day to File Magistrate Consent Form.
April 25, 2013
• Initial Case Management Conference in Courtroom B, 15th Floor, San Francisco Courthouse at 10:00 a.m.
IT IS SO ORDERED.
