Tugas v. Hill-Rom Company, Inc.

Filing 12

STIPULATION and ORDER signed by District Judge John A. Mendez on 2/19/16 ORDERING that the parties shall meet and confer pursuant to Federal Rule of Civil Procedure 26(f) and file their joint status report by 4/18/2016. (Kastilahn, A)

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Counsel listed on the following page

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EASTERN DISTRICT OF CALIFORNIA

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101 California Street
San Francisco, CA 94111-5802

UNITED STATES DISTRICT COURT

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Winston & Strawn LLP

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SACRAMENTO DIVISION

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GERMAN TUGAS, on behalf of himself, all
others similarly situated, and on behalf of the
general public,

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Case No. 2:15-cv-02426-JAM-CKD
Assigned to The Honorable John A. Mendez

Plaintiff,

STIPULATION REGARDING EARLY
MEDIATION AND REQUESTING
EXTENSION OF CURRENT DEADLINE
TO CONDUCT THE PARTIES’ RULE
26(F) CONFERENCE AND TO FILE THE
JOINT STATUS REPORT

v.
HILL-ROM COMPANY, INC., and
DOES 1-100, inclusive,

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Defendants.
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Complaint filed August 24, 2015
First Amended Complaint filed December 21,
2015

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STIPULATION REGARDING EARLY MEDIATION AND REQUESTING EXTENSION TO CONDUCT 26(f) CONFERENCE
AND TO FILE JOINT STATUS REPORT
CASE NO. 2:15-cv-02426-JAM-CKD

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William Turley (SBN: 122408)
[e-mail]
David Mara (SBN: 230498)
[e-mail]
The Turley Law Firm, APLC
7428 Trade Street
San Diego, CA 92121
Telephone: [phone]
Facsimile:
[phone]
Attorneys for Plaintiff
GERMAN TUGAS

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101 California Street
San Francisco, CA 94111-5802

Winston & Strawn LLP

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Joan B. Tucker Fife (SBN: 144572)
[e-mail]
Emily C. Schuman (SBN: 271915)
[e-mail]
WINSTON & STRAWN LLP
101 California Street, Suite 3900
San Francisco, CA 94111
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Defendant
HILL-ROM COMPANY, INC.

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STIPULATION REGARDING EARLY MEDIATION AND REQUESTING EXTENSION TO CONDUCT 26(f) CONFERENCE
AND TO FILE JOINT STATUS REPORT
CASE NO. 2:15-cv-02426-JAM-CKD

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THIS STIPULATION is hereby entered into by and between Plaintiff German Tugas and

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Defendant Hill-Rom Company, Inc. (“Hill-Rom”) pursuant to Eastern District of California Local

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Rule 143(a)(1).

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RECITALS

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WHEREAS, the Court issued an Order on January 15, 2016 requiring the parties to meet and

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confer pursuant to Federal Rule of Civil Procedure 26(f) and to file a joint status report by February

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18, 2016 (dkt. 10);

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WHEREAS, the parties met and conferred and agreed that early mediation may be
productive;

101 California Street
San Francisco, CA 94111-5802

Winston & Strawn LLP

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WHEREAS, the parties have begun the process of finding a mediator and scheduling
mediation to take place within the next few months (based on mediators’ availability);

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WHEREAS, the parties have agreed that a Rule 26(f) conference and joint status report

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would be more targeted and productive if they were completed after early mediation (if the case does

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not settle);

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WHEREAS, the parties do not seek this continuance for purposes of delay, but, rather, to
efficiently and thoroughly manage the case in regards to timelines, substance, and procedure;

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NOW, THEREFORE, the parties hereby stipulate to, and request that the Court order, that

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the parties’ deadline to meet and confer pursuant to Federal Rule of Civil Procedure 26(f) and their

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deadline to file a joint status report shall be extended 60 days to enable time for mediation, to April

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18, 2016.

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IT IS SO STIPULATED.

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STIPULATION REGARDING EARLY MEDIATION AND REQUESTING EXTENSION TO CONDUCT 26(f) CONFERENCE
AND TO FILE JOINT STATUS REPORT
CASE NO. 2:15-cv-02426-JAM-CKD

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Dated: February 18, 2016

THE TURLEY LAW FIRM, APLC

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By:

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/s/ David Mara (as authorized on February 18, 2016)
David Mara

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Dated: February 18, 2016

WINSTON & STRAWN LLP

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By:

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/s/ Emily C. Schuman
Emily C. Schuman

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ORDER

101 California Street
San Francisco, CA 94111-5802

Winston & Strawn LLP

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Having considered the Joint Stipulation submitted by the parties, and for good cause

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appearing therefore, IT IS SO ORDERED that the parties shall meet and confer pursuant to Federal

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Rule of Civil Procedure 26(f) and file their joint status report by April 18, 2016.

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Dated: 2/19/2016

/s/ John A. Mendez________
Honorable John A. Mendez
United States District Court
Eastern District of California

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STIPULATION REGARDING EARLY MEDIATION AND REQUESTING EXTENSION TO CONDUCT 26(f) CONFERENCE
AND TO FILE JOINT STATUS REPORT
CASE NO. 2:15-cv-02426-JAM-CKD