Shannon v. Sacramento Job Corps Center, et al.,

Filing 10

STIPULATION and ORDER signed by Chief District Judge Kimberly J. Mueller on 4/26/21 ORDERING that the Parties are granted an extension of two (2) months during which the Parties are directed to exhaust private mediation and notify the Court no later than June 16, 2021 if they were unable to settle the case and why the Court should not schedule a settlement conference before a Magistrate Judge of this Court. (Kaminski, H).

1
2
3
4
5
6

MARK P. VELEZ, ESQ. (SBN 163484)
NATALYA V. GRUNWALD, ESQ. (SBN 265084)
THE VELEZ LAW FIRM
3010 Lava Ridge Court, Suite 120
Roseville, CA 95661
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Plaintiff ERIKA SHANNON

7
8
9
10
11
12
13
14
15
16

MICHAEL G. PEDHIRNEY, Bar No. 233164
LITTLER MENDELSON, P.C.
333 Bush Street, 34th Floor
San Francisco, CA 94104
Telephone:
415.433.1940
[e-mail]
JOHN H. ADAMS, JR., Bar No. 253341
LITTLER MENDELSON, P.C.
500 Capitol Mall
Suite 2000
Sacramento, CA 95814
Telephone:
916.830.7200
[e-mail]
Attorneys for Defendant
ADAMS AND ASSOCIATES, INC.

17
18

UNITED STATES DISTRICT COURT

19

EASTERN DISTRICT OF CALIFORNIA

20
21

ERIKA SHANNON,
Plaintiff,

22
23
24
25

Case No. 2:20-CV-01080-KJM-AC
STIPULATION AND ORDER TO EXTEND
TIME PREVIOUSLY ALLOWED BY
COURT FOR THE PARTIES TO
EXPLORE PRIVATE MEDIATION

v.
SACRAMENTO JOB CORPS CENTER, ADAMS
& ASSOCIATES, INC., and DOES 1 – 50
inclusive,
Defendants.

26
27
28
CASE NO. 2:20-CV-01080-KJM-AC
STIPULATION AND ORDER TO EXTEND TIME

1

1

Plaintiff ERIKA SHANNON (“Plaintiff”) and Defendant ADAMS AND ASSOCIATES, INC.

2

(“Defendant”) by and through their respective counsel of record, stipulate and agree as follows, and

3

request that the Court enter an order upon this stipulation:

4

WHEREAS, on or about October 22, 2020 this Court issued MINUTES for Scheduling

5

Conference, issuing an Order for the Parties to “exhaust private mediation and notify the court no later

6

than 4/16/2021 if they were unable to settle the case and why the court should not schedule a May 2021

7

settlement conference before a Magistrate Judge of this Court.”

8

WHEREAS, the Parties have been diligently involved in the discovery process.

9

WHEREAS, the Parties are seeking an extension of time to exhaust private mediation.

10
11

WHEREAS, the Parties stipulate that good cause exists for this Court to allow the Parties an
additional two months in order to have sufficient time to exhaust private mediation.

12

WHEREAS, the Parties respectfully request that the Court enter an Order granting the Parties an

13

extension of two months to submit a written notice to the Court regarding the Parties’ exhaustion of

14

private mediation.

15

IT IS SO STIPULATED.

16
17
18

Dated: April 21, 2021

19

THE VELEZ LAW FIRM, P.C.
By:

20
21

/s/ Natalya V. Grunwald as authorized on
April 21, 2021
Mark P. Velez
Natalya V. Grunwald
Attorneys for Plaintiff ERIKA SHANNON

22
23
24
25

Dated: April 21, 2021

LITTLER MENDELSON, P.C.
By:

26
27

/s/ Michael G. Pedhirney
Michael G. Pedhirney
John H. Adams
Attorneys for Defendant
ADAMS AND ASSOCIATES, INC.

28
CASE NO. 2:20-CV-01080-KJM-AC
STIPULATION AND ORDER TO EXTEND TIME

2

1
2

ORDER
PURSUANT TO THE ABOVE STIPULATION, the Parties are granted an extension of two

3

(2) months during which the Parties are directed to exhaust private mediation and notify the Court no

4

later than June 16, 2021 if they were unable to settle the case and why the Court should not schedule a

5

settlement conference before a Magistrate Judge of this Court.

6
7

IT IS SO ORDERED.
DATED: April 26, 2021.

8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
CASE NO. 2:20-CV-01080-KJM-AC
STIPULATION AND ORDER TO EXTEND TIME

3