Khanna v. Inter-Con Security Systems, Inc. et al
Filing
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STIPULATION and ORDER for Continued Date for Filing Request for Approval of Settlement Agreement and Dismissal signed by District Judge Kimberly J. Mueller on 6/2/11 ORDERING filing date of 6/3/11 for the Request for Approval and Dismissal continued to June 17, 2011. (Meuleman, A)
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DAVID P. MASTAGNI, ESQ. (SBN 57721)
DAVID E. MASTAGNI, ESQ. (SBN 204244)
JAMES B. CARR, ESQ. (SBN 53274)
ISAAC S. STEVENS, ESQ. (SBN 251245)
JEFFREY R. A. EDWARDS, ESQ. (SBN 265597)
MASTAGNI, HOLSTEDT, AMICK,
MILLER & JOHNSEN
A Professional Corporation
1912 “I” Street
Sacramento, California 95811-3151
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Telephone: (916) 446-4692
Facsimile: (916) 447-4614
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Attorneys for Plaintiffs
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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SHASHI KHANNA, suing individually and as )
Successor in Interest of Amankumar Khanna, )
deceased, by and on behalf of Amankumar )
Khanna, all others similarly situated, and the )
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general public,
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Plaintiffs
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v.
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INTER-CON SECURITY SYSTEMS, INC., a )
California Corporation D/B/A/ )
HEALTHCARE SECURITY SERVICES )
GROUP, a putative independent entity; )
ENRIQUE HERNANDEZ, JR., an individual; )
NEIL MARTAU, an individual; LANCE )
MUELLER, an individual; ROLAND A. )
HERNANDEZ, an individual; PAUL R. )
MILLER, an individual; MICHAEL P. )
MACHARG, an individual; JEANNE GERVIN, )
an individual; MICHAEL SUTKAYTIS, an )
individual; JANA FANNING, an individual; )
BRITTANY MOORE, an individual; )
CATHERINE ROSS, an individual; LINDA )
SAYAD, an individual; MARK )
CHAMBERLAIN, an individual; and JAMES )
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LATHAM, an individual,
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Defendants.
CASE NO.
2:09-cv-02214-KJM-GGH
[CLASS ACTION & COLLECTIVE
ACTION]
STIPULATION TO CONTINUE
DATE FOR FILING REQUEST FOR
APPROVAL OF SETTLEMENT
AGREEMENT AND DISMISSAL;
AND ORDER
Date:
Ctrm:
Judge:
June 3, 2011
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Kimberly J. Mueller
Proposed
New Date:
June 17, 2011
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///
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///
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REQUEST FOR CONTINUANCE AND
ORDER
KHANNA v. INTER-CON SECURITY
Case No. 2:09-cv-02214-KJM-GGH
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STIPULATION
The parties are unable to prepare and file the Request for Approval and Dismissal by the date
of June 3, 2011, previously ordered by the Court.
The parties respectfully request a short continuance to June 17, 2011, to file the Request for
Approval and Dismissal.
The documents and papers cannot be filed in a timely manner due to press of business of both
Plaintiffs’ and Defendants’ respective counsel.
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Both Plaintiffs and Defendants are agreeable to this short continuance. The parties have filed
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previously a Notice of Settlement and have settled the case. [Ct. Doc. No. 48, May 3, 2011] They have
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also entered in to a Letter Agreement following a successful mediation on March 8, 2011, and they are
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preparing a formal Settlement Agreement to be filed with the Request for Approval.
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This slight delay is fair and reasonable and will not prejudice either the Plaintiffs or the
Defendants. This request for a brief continuance is respectfully submitted.
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MASTAGNI, HOLSTEDT, AMICK,
MILLER & JOHNSEN, P.C.
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Dated: June 1, 2011
By:
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/s/ JEFFREY R.A. EDWARDS
JEFFREY R.A. EDWARDS
Attorneys for Plaintiffs
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PAUL, HASTINGS, JANOFSKY &
WALKER, LLP
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Dated: June 1, 2011
By:
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/s/ JENNIFER OH
JENNIFER Y. OH
Attorneys for Defendants
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REQUEST FOR CONTINUANCE AND
ORDER
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KHANNA v. INTER-CON SECURITY
Case No. 2:09-cv-02214-KJM-GGH
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ORDER
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GOOD CAUSING APPEARING herein,
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IT IS HEREBY ORDERED that the original filing date of June 3, 2011, for the Request for
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Approval and Dismissal is continued to June 17, 2011.
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DATED: June 2, 2011.
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UNITED STATES DISTRICT JUDGE
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REQUEST FOR CONTINUANCE AND
ORDER
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KHANNA v. INTER-CON SECURITY
Case No. 2:09-cv-02214-KJM-GGH
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