Pringle v. Western Dental Services, Inc.

Filing 18

STIPULATION and ORDER signed by Senior Judge Morrison C. England, Jr. on 9/14/2020 STAYING all discovery in this action pending mediation. The Parties shall mediate this matter on 10/16/2020, with mediator, Jill Sperber. (Huang, H)

1 Wyeth E. Burrows (State Bar No. 203851)

[e-mail]

2 Zhasmina Y. Kolarova (State Bar No. 328751)

[e-mail]

3 WOOD, SMITH, HENNING & BERMAN LLP

501 West Broadway, Suite 1200

4 San Diego, California 92101

[e-mail]

5 Phone: [phone] ♦ Fax: [phone]
6 Attorneys for Defendant, WESTERN DENTAL SERVICES, INC.
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION

Plaintiff,

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Attorneys at Law
501 WEST BROADWAY, SUITE 1200
SAN DIEGO, CALIFORNIA 92101
TELEPHONE [phone] ♦ FAX [phone]

WOOD, SMITH, HENNING & BERMAN LLP

10 KIMBERLEE PRINGLE,

v.

12

13 WESTERN DENTAL SERVICES,
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INC.,

Defendant.
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Case No. 2:19-cv-02190-MCE-DB
STIPULATION AND ORDER TO
STAY LITIGATION UNTIL
COMPLETION OF MEDIATION
Hon. District Judge Morrison C.
England, Jr.
Hon. Magistrate Judge Deborah Barnes
Trial Date:

None Set

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This Stipulation is entered into by and between Plaintiff KIMBERLEE
PRINGLE (hereinafter "Plaintiff") and Defendant WESTERN DENTAL SERVICES,
INC. (hereinafter "Defendant") (Plaintiff and Defendant are collectively referred to
herein as the "Parties" or singularly as the "Party"), by and through their respective
counsel, with reference to the following facts:
1.

The Parties have a mediation scheduled for October 16, 2020.

2.

The Parties wish to stay all discovery and any pending litigation due

dates in the instant action until after October 16, 2020.
3.

If the Parties do not settle the case in mediation on October 16, 2020, the

Parties will only have 40 days left until the fact discovery cut off deadline.
4.

If all discovery and any pending litigation is not stayed, the Parties will

not have adequate time to conduct discovery and retain experts. Thus, good cause
15457212.1:10218-0032

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STIPULATION AND ORDER FOR EXTENSION TO STAY DISCOVERY

1 exists to stay all discovery and any due dates in the pending litigation until the
2 completion of mediation on October 16, 2020.
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5.

For the reasons discussed herein, the parties have agreed to stay

4 discovery and this action until after October 16, 2020.
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6.

Following compliance, the parties will advise the Court and take all

6 necessary steps to bring this action to a close, as appropriate.
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Based on the foregoing, the Parties, by and through their respective counsel of

8 record, hereby STIPULATE and AGREE as follows:

1.

All discovery in this action shall be stayed pending mediation; and

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2.

The Parties shall mediate this matter on October 16, 2020, with mediator,

11 Jill Sperber.
Attorneys at Law
501 WEST BROADWAY, SUITE 1200
SAN DIEGO, CALIFORNIA 92101
TELEPHONE [phone] ♦ FAX [phone]

WOOD, SMITH, HENNING & BERMAN LLP

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Dated: September 9, 2020

MARTIN & BONTRAGER, APC

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By: _/s/ Nicholas J. Bontrager__
Nicholas J. Bontrager
Attorneys for Plaintiff,
KIMBERLEE PRINGLE

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DATED: September 9, 2020

WOOD, SMITH, HENNING & BERMAN LLP

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/s/ Zhasmina Y. Kolarova
WYETH E. BURROWS
ZHASMINA Y. KOLAROVA
Attorneys for Defendant, WESTERN DENTAL
SERVICES, INC.
By:

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15457212.1:10218-0032

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STIPULATION AND ORDER FOR EXTENSION TO STAY DISCOVERY

Signature Attestation

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2

Pursuant to Civil Local Rule 5-4.3.4(i), I hereby attest that all other

3 signatories listed, whose signatures are indicated by a conformed signature (“/s/”),
4 and on whose behalf the filing is submitted, concur in the filing’s content and have
5 authorized the filing.
6
7 DATED: Spetember 9, 2020

WOOD, SMITH, HENNING & BERMAN LLP

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WYETH E. BURROWS
ZHASMINA KOLAROVA
Attorneys for Defendant, WESTERN DENTAL
SERVICES, INC.

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Attorneys at Law
501 WEST BROADWAY, SUITE 1200
SAN DIEGO, CALIFORNIA 92101
TELEPHONE [phone] ♦ FAX [phone]

WOOD, SMITH, HENNING & BERMAN LLP

/s/ Zhasmina Y. Kolarova

By:

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ORDER
IT IS SO ORDERED.
Dated: September 14, 2020

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15457212.1:10218-0032

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STIPULATION AND ORDER FOR EXTENSION TO STAY DISCOVERY