Villa v. United Site Services of California, Inc
Filing
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ORDER by Judge Lucy H. Koh granting 40 Stipulation (lhklc2, COURT STAFF) (Filed on 8/23/2012)
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Case5:12-cv-00318-LHK Document40 Filed08/21/12 Page1 of 2
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SUSAN E. BISHOP, CA STATE BAR NO. 187253
BERLINER COHEN
TEN ALMADEN BOULEVARD
ELEVENTH FLOOR
SAN JOSE, CALIFORNIA 95113 2233
TELEPHONE: (408) 286 5800
FACSIMILE: (408) 998 5388
susan.bishop@berliner.com
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ATTORNEYS FOR DEFENDANT
UNITED SITE SERVICES OF CALIFORNIA, INC.
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN JOSE DIVISION
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NELSON GONZALEZ VILLA, on behalf of
himself and all others similarly situated,
CASE NO. CV 12 00318 LHK
STIPULATION AND PROPOSED ORDER
TO EXTEND TIME TO RESPOND TO
MOTION FOR CONDITIONAL
CERTIFICATION
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Plaintiffs,
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v.
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UNITED SITE SERVICES OF
CALIFORNIA, INC.,
Defendant.
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STIPULATION AND [PROPOSED] ORDER
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Plaintiff Nelson Gonzalez Villa ("Plaintiff") and defendant United Site Services of
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California, Inc. ("Defendant") through their undersigned attorneys, stipulate and respectfully
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request that this Court approve an extension of time for Defendant to file an opposition to the
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motion for conditional certification filed on July 10, 2012. As grounds for this extension of time,
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the parties hereto state as follows:
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1.
The hearing on the motion has been scheduled for November 8, 2012. Counsel
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for Defendant has only started its preliminary analysis of the potential class. Further, Defense
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counsel changed firms effective August 8, 2012, causing a slight delay. Plaintiff graciously
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granted an extension of time, until August 23, 2012, for defendant to submit its opposition.
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Plaintiff’s reply brief would be filed by September 10, 2012.
CASE NO. CV 12 00318 LHK
\SBISHOP\1059781.1
081712 20864004
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STIPULATION AND PROPOSED ORDER TO EXTEND TIME TO RESPOND TO MOTION FOR CONDITIONAL
CERTIFICATION
Case5:12-cv-00318-LHK Document40 Filed08/21/12 Page2 of 2
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2.
There have been no other time modifications in this case.
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3.
The parties believe this time modification will have no impact on the schedule for
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this case given its early stage and given that the hearing date will remain the same.
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NOW, THEREFORE, based upon the foregoing, the parties, through their undersigned
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attorneys, stipulate to extend the time to file and serve an opposition to the motion for
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conditional class certification to August 23, 2012 and the reply to September 10, 2012.
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IT IS SO STIPULATED between the parties.
Dated: August 17, 2012
BERLINER COHEN
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By:____/s/ Susan E. Bishop_____
Susan E. Bishop
Attorneys for Defendant UNITED SITE
SERVICES OF CALIFORNIA, INC.
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Dated: August 17, 2012
LAW OFFICES OF MITCH ALLEN
By:_____/s/ Mitch Allen_______
Mitch Allen
Attorneys for Plaintiff
NELSON GONZALEZ VILLA
ECF ATTESTATION
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I, Susan E. Bishop, am the ECF User whose ID and password are being used to file the
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following: STIPULATION AND PROPOSED ORDER TO EXTEND TIME TO RESPOND TO
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MOTION FOR CONDITIONAL CERTIFICATION. In compliance with Civil L.R. 5 1(i)(3), I
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hereby attest that Mitch Allen has concurred in this filing.
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Dated: August 20, 2012
BERLINER COHEN
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By:____/s/ Susan E. Bishop_____
Susan E. Bishop
Attorneys for Defendant UNITED SITE
SERVICES OF CALIFORNIA, INC.
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ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.
August 23
Dated: ____________, 2012
__________________________________
United States District Court
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CASE NO. CV 12 00318 LHK
\SBISHOP\1059781.1
081712 20864004
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STIPULATION AND PROPOSED ORDER TO EXTEND TIME TO RESPOND TO MOTION FOR CONDITIONAL
CERTIFICATION
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