Free Order - District Court of California - California

Case 5:07-cv-04808-JF

Document 36

Filed 05/21/2008 **E-filed 5/21/08** Page 1 of 6

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KURT OSENBAUGH (State Bar No. 106132) DEBORAH YOON JONES (State Bar No. 118127) SA Y AK KARIT ANI (State Bar No. 240122) WESTON, BENSHOOF, ROCHEFORT, RUBALCAVA & MacCUISH LLP 333 South H012e Street, Sixteenth Floor Los Angeles, California 90071
Facsimile: (2.13) 576-1100 kosenbaughrrwbcounsel.com
dj ones~wbcounsel.com

Telephone: (213) 576-1000

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skaritann(iwbcounsel.com

Attorneys for Plaintiffs and Counter-Defendants BP WEST COAST PRODUCTS LLC and ATLANTIC RICHFIELD COMPANY

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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA
BP WEST COAST PRODUCTS LLC, a Case No.: C07 04808 JF Delaware Limited Liability Company; and ----------------ATLANTIC RICHFIELD COMPANY, a STIPULATION; AND rPROPOSED)
Delaware Corporation,

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Plaintiffs,
v.

ORDER TO CONTINUE MEDIATION CUT-OFF AND POSTMEDIATION STATUS CONFERENCE DATES

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ENTERPRISE, LLC, a California limited liability company,
Defendants.

Coo))oration~ NAZIM F A8UIRY AN, an individual; ~A YED FAQl IRY AN, an individual; and MAGHUL FAQUIRY AN, an individual; and A V A GLOBAL

STTN ENTERPRISES, INC., a California

Crtm: 4

Honorable Jeremy Fogel

Filing Date:

September 17, 2007

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AND RELATED COUNTERCLAIM.

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STIPULATION; AND (PROPOSED) ORDER TO CONTINUE MEDIATION CUT-OFF AND POST MEDIATION STATUS CONFERENCE DATES

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Case 5:07-cv-04808-JF

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Filed 05/21/2008

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STIPULATION

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WHEREAS, the mediation cut-off date and the post-mediation
conference are presently scheduled for June 13, 2008;

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WHEREAS, Plaintiff and Counter-defendant BP West Coast Products
LLC ("BPWCP") has taken the depositions of Sayed Faquiryan and Nazim Faquiryan
but were required to wait until Sayed Faquiryan returned from Afghanistan;

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WHEREAS, BPWCP has notified Defendants STTN Enterprises, Inc.,
Sayed Faquiryan, Nazim Faquiryan, Maghul Faquiryan, and AVA Global Enterprises,

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LLC (collectively referred to as "STTN") that it intends to file a Motion for Summary
Judgment, or In the Alternative, Partial Summary Judgment ("Motion");

WHEREAS, BPWCP is required to set the Motion for hearing on August
8, 2008 because of

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the Court's and STTN's counsel's schedules, and because STTN's

counsel also indicated that he wil object to an earlier hearing date unless he is able to
take BPWCP depositions before BPWCP files its Motion;
WHEREAS, the parties have met and conferred and have agreed to a

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deposition schedule in May and June 2008 of certain BPWCP witnesses necessary for
the mediation;

WHEREAS, the parties have agreed to participate in mediation before

the Honorable Charles A. Legge (Ret.) of JAMS on August 11, 2008. As such, the
parties need to extend the date for the mediation cut-off date accordingly. Counsel

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have met and conferred and have agreed upon the mediation cut-off date set of August

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22,2008. The parties request that the post mediation conference presently set for June

13, 2008 be continued to August 22, 2008 at 10:30 a.m., or such other date and time
after August 22, 2008 as the court shall determine;

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WHEREAS, this is the first request by the parties to continue the dates in
this matter and the parties seek an extension of only the mediation cut-off date and the
post-mediation conference; and
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11822191

STIPULATION; AND (PROPOSED) ORDER TO CONTINUE MEDIATION CUT-OFF AND POST MEDIATION STATUS CONFERENCE DATES

MAY-16-2008 FRI 10:21 AM BAKER MANOCK JENSEN

Case 5:07-cv-04808-JF

Document 36

FAX NO, 559 4325620 Filed 05/21/2008 Page 3 of 6

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WHEREAS, the parties stil request that the Court go forward with the

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Case Management Conference presently set for June 13, 2008 in order to set pretrial
and trial dates.

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NOW THEREFORE, BPWCP and STTN, by and through their
respective attorneys of record herein) hereby agree and stipulate to the following:
1. That the mediation cut-off datei:: continued :tom June 13, 2008 to

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August 22, 2008;
2.
That the post mediation confemnce is continued from June 13,

2008 to August 22, 2008 at 10:00 a.m.; and

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3. That the Case Management Con ference presently set for June 13,
2008 at 10:3,0 a.m. will go forward so pretrial and tri::l dates may be set.

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DATED: May It" 2008

KURT OSENBAUGH ON JONES
DEBORAH YO

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WESTON, BENSHOOF, ROCHEFORT, RUBALCA VA & MacCUISH LLP

SAYAKAKATANI

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Attorneys for Plaintif s and Counter-Defendants BP WEST COAST P:lODUCTS LLC and ATLANTIC RlCHFI3LD COMPANY

~aka Karitai

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DATED: May~, 2008

JOHN G. MICHAL BAKER MANOCK & JENSEN PC

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Attomeys for Defend :mts STTN ENTERPRISES,, INC")SA YED FAQUIRY AN, NAZIM FAOUIRY ANË MAvHUL FAQUIRY AN, AND A V A GLOBAL NTERPRlSES, LLC

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STlPULATIONj AND (PROPOSED! ORDER TO CONTINUE MEDIATION CUT-OFF AND POST MEmATION STATUS CONFERENCE DATES

Case 5:07-cv-04808-JF

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------------------JPROPOSEDl ORDER PURSUANT TO STIPULATION, IT is SO ORDERED

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DATED:

5/21/08
Hon. Jeremy Fogel

United States District Court

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3 STIPULATION; AND (PROPOSED) ORDER TO CONTINUE MEDIATION CUT-OFF AND POST MEDIATION STATUS CONFERENCE DATES

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Case 5:07-cv-04808-JF

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PROOF OF SERVICE
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I, Nora Fernandez, declare:

I am employed in the County of Los Angeles, State of California. I am
over the age of 18 and not a. party to the within action. My business address is

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Weston, Benshoof, Rochefort, Rubalcava & MacCuish LLP, 333 South Hope Street, Sixteenth Floor, Los Angeles, CA 90071. I am over the age of eighteen years and not a party to the action in which this service is made.

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addressed as follows: SEE ATTACHED SERVICE LIST

STIPULATION; AND rPROPOSEDl ORDER TO CONTINùÉ MEDIATION CUT-OFF AND POST-MEDIATION STATUS CONFERENCE DATES on the interested parties in this action by enclosing the document(s) in a sealed envelope
D

On Mi:Y 16, 2008 I served the document( s) described as

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BY MAIL: I am "readily familiar" with this firm's practice for the collection and the processing of correspondence for mailing with the United States Postal
Service. In the ordinary course of business, the correspondence would be

deposited with the United States Postal Service at 333 South Hope Street, Los Angeles, California 90071 with postage thereon fully prepaid the same day on which the correspondence was placed for collection and mailing at the firm.

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Following ordinary business practices, I placed for collection and- mailing with

the Unitea States Postal Service such envelope at Weston, Benshoof, Rocliefort, Rubalcava & MacCuish LLP, 333 South Hope Street, Los Angeles, California 90071.

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BY FEDERA EXPRESS D UPS NEXT DAY AIR D OVERNIGHT
DELIVERY: I d~Qosited such envelo~ in a facility regularly maintained by D

FEDERA EXPRESS D UPS Ð Overnight Delivery r specify name of

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courier or driver of 0 FEDERAL EXPRESS D UPS D OVERNIGHT DELIVERY r specify name of service:) authorized to receive documents at Weston, Benshoof, Rochefort, Rubalcava & MacCuish LLP, 333 South Hope
Street, Los Angeles, California 90071 with delivery fees fully provided for.

service: ) with deliveiy fees fully provided for or delivered the enveloQe to a

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BY FACSIMILE: I telecopied a copy of said document(s) to the following
addressee(s) at the following number(s) in accordance with the written

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confirmation of counsel in this action.
California that the above is true and correct.
correct.
(F ederal)
rState) I declare under penalty of perjury under the laws of the State of

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I declare under penalty of perjury that the foregoing is true and

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Executed on May 16, 2008, at Los Angeles,

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Case 5:07-cv-04808-JF

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BP WEST COAST PRODUCTS LLC v. STTN ENTERPRISES, et al. United States District Court, Northern District
Case No. C07 04808 JF

SERVICE LIST
John G. Michael, Esq.

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Baker Manock & Jensen 5260 North Palm Avenue Fourth Floor Fresno, CA 93704

Attorney for Defendants, STTN ENTERPRISES, INCÄ' NAZIM FAQUIRYAN; and S YED FAQUIRYAN

Tel: (559) 432-5400
Fax: (559) 432-5620

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