Free Motion to Continue - District Court of California - California

Case 3:08-cv-00433-H-BLM

Document 10

Filed 08/01/2008

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anderson dt hotmail.com 2I1DEREKT.ANDE SON, ATTORNEY AT LAW 1850 Fifth Avenue

Derek T. AnderSOn SBN 208141)

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3 II SanDiego,California92101 Telephone:(619) 237-0099
FacsImile: (619) 237-0199 5 Attorney for Plaintiff, ABRAM RODRIGUEZ 6 7 8 9
UNITED STATES DISTRICT COURT SOUTHERN DISlRICT OF CALIFORNIA

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ABRAM RODRIGUEZ,
Plaintiff,

)

Case No. 08-CV -0433-H-BLM

v.
29. INTERNATIONAL

INTERNATIONAL LONGSHORE 14 AND WAREHOUSE UNION LOCAL 15 LONGSHORE AND WAREHOUSE UNION, 16
Defendants.

STIPULATION TO VACATE AND RESCHDULE EARLY NEUTRAL CASE EVALUATION CONFERENCE AND RELATED DEADLINES; ORDER Complaint Filed: March 7,2008

17 18 19 20 21 22 23 24 25 26 27 28 WAREHOUSE UNION to allege employment and labor violations which plaintiff believes he was subjected to since the filing of the complaint in this matter but the parties have been unable to confer on the matter for the reasons listed below; III III WHEREAS plaintiff ABRAM RODRIGUEZ intends to amend the complaint filed against defendants INTERNATIONAL LONGSHORE AND WAREHOUSE UNION LOCAL 29 and INTERNATIONAL LONGSHORE AND

Case 3:08-cv-00433-H-BLM

Document 10

Filed 08/01/2008

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WHEREAS counsel for the parties have been limited in their ability to coordinate case-related matters, including the filing of an amended complaint, due
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to negotiations between counsel for the ILWU on a new collective bargaining agreement between the union and various employer signatories to it for which a clock negotiations; WHEREAS it was discussed between counsel that the amendment of the

5 II tentative contract was reached on July 29, 2008, after several weeks of round-the
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complaint would make it currently impractical to adequately identify, among other

9 II things, the bases of plaintiff s claims and defendants' defenses, potential witnesses, 10 II a proposed discovery plan, expert disclosures, a motion schedule, and potential 11 settlement until the amended complaint is filed; 12 WHEREAS since defendants do not yet know the particulars of the proposed 13 amended complaint, defendants reserve the right to oppose its filing; 14 WHEREAS counsel for plaintiff will also be unavailable for the currently

15 II scheduledEarlyNeutralEvaluationcurrentlyscheduledfor August 11,2008,due 16 II to a previouslyscheduledfamilyvacationwith his parentsand siblings;
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IT IS HEREBY STIPULATED BY ALL OF THE PARTIES TO THE

18 WITHINACTIONthat goodcauseexiststo vacatethe EarlyNeutralEvaluation 19 conferenceand relateddeadlinesandreschedulethe EarlyNeutralEvaluation 20 conferenceand relateddeadlinesin approximately days. 60 21 22
23 TTORNEY AT

DATED:July 30, 2008
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By

PfW7ERSO

Attorney for Plaintiff, ABRAM RODRIGUEZ

D~

Anderson

Ju1.

31. Case 2008

3:08-cv-00433-H-BLM Document 10 4:02PM HOLGUIN & GARFiElD, APLC

No. Page P. of 3 Filed 08/01/2008 2470 3 2

HOLGUIN, GARFIELD & MARTINEZ

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DATED: July 31, 2008
B Y. JJI' J,
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JOhn KUn

Attomejls for Defendant, INfERNA TIONAL LONGSHORE & WAREHOUSE UNION LOCAL 29 LEONARD CARDER, LLP

6 DATED:July 31,2008 7 8 9 10 11 12
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By,

-obert ~. Kernar Attome.ysfor Defendant, INTERNATIONAL LONGSHORE& WAREHOUSE UNION ORDER IT IS HEREBY ORDERED that the Early Neutral Evaluation conference in this action currently scheduled for August 11,2008 and related deadlines are vacated and will be rescheduled in approximatel 60 days. y

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17I1DAlED: 1811 19 20 21 22 23 24 25 26 27 28 UNITED STATES DISTRICT JUDGE