Tugas v. Hill-Rom Company, Inc.

Filing 14

STIPULATION and ORDER signed by District Judge John A. Mendez on 4/18/16 ORDERING that the deadline to conduct the parties; Rule 26(F) Conference and to file the Joint Status Report is EXTENDED to 9/15/2016. (Mena-Sanchez, L)

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Counsel listed on the following page

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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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 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.

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

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CERTIFICATE OF SERVICE

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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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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CERTIFICATE OF SERVICE

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 Febreuary 19, 2016 requiring the parties to meet

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

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18, 2016 (dkt. 12);

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

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WHEREAS, the parties scheduled a mediation with Mark Rudy, a highly respected wage
and hour class action mediator;

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WHEREAS, the mediation is scheduled to take place on August 16, 2016, which was the
mediator’s earliest available mediation date;

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WHEREAS, the parties agree to update the Court within 30 days after the completion of the

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August 16, 2016 mediation and, if settlement is not achieved, the parties agree to file a Rule 26(f)

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Report by September 15, 2016;

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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 until 30 days after the scheduled August 16,

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2016 mediation, to September 15, 2016.

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IT IS SO STIPULATED.

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CERTIFICATE OF SERVICE

CASE NO. 2:15-cv-02426-JAM-CKD

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Dated: April 18, 2016

THE TURLEY LAW FIRM, APLC

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By:

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/s/ William Turley
William Turley

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Dated: April 18, 2016

WINSTON & STRAWN LLP

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By:

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/s/ Joan Tucker Fife (as authorized on April 18, 2016)
Joan Tucker Fife

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[PROPOSED] ORDER
Having considered the Joint Stipulation submitted by the parties, and for good cause
appearing therefore, IT IS SO ORDERED that the parties shall update the court regarding the
results of the mediation or meet and confer pursuant to Federal Rule of Civil Procedure 26(f) and file
their joint status report by September 15, 2016.

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Dated: 4/18/2016

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

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CERTIFICATE OF SERVICE

CASE NO. 2:15-cv-02426-JAM-CKD