Torrez v. Teema, Inc.

Filing 13

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 01/17/23 CONTINUING the VDRP Mediation Completion deadline to 04/10/23.(Licea Chavez, V)

Case 2:22-cv-01531-TLN-KJN Document 13 Filed 01/18/23 Page 1 of 4

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Larry W. Lee (State Bar No. 228175)
Kristen M. Agnew (State Bar No. 247656)
Nicholas Rosenthal (State Bar No. 268297)
DIVERSITY LAW GROUP, P.C.
515 S. Figueroa Street, Suite 1250
Los Angeles, CA 90071
[phone]
[phone]s facsimile
William L. Marder (SBN 170131)
[e-mail]
POLARIS LAW GROUP
501 San Benito Street, Suite 200
Hollister, CA 95023
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff CHRISTINA TORREZ
Amy L. Lessa (SBN 202872)
E-Mail: [e-mail]
Lauren Bushman (SBN 314865)
E-Mail: [e-mail]
FISHER & PHILLIPS LLP
4747 Executive Drive, Suite 1000
San Diego, California 92121
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant TEEMA, INC.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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CHRISTINA TORREZ,

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Plaintiff,

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vs.

Case No.: 2:22−CV−01531−TLN−KJN
JOINT STIPULATION TO CONTINUE
VDRP MEDIATION COMPLETION
DEADLINE; ORDER

TEEMA, INC., a Delaware
corporation; and DOES 1 through
50, inclusive,

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Defendants.

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JOINT STIP AND ORDER TO CONT MEDIATION COMPLETION DEADLINE

Case 2:22-cv-01531-TLN-KJN Document 13 Filed 01/18/23 Page 2 of 4

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TO THE HONORABLE COURT:

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Plaintiff Christina Torrez and Defendant TEEMA, Inc., by and through their

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undersigned counsel, hereby jointly move this Court for an order continuing the

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Voluntary Dispute Resolution Program (“VDRP”) mediation completion deadline,

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as set forth below, for the following reasons:

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1.

This case was removed from state court on August 31, 2022.

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2.

On December 28, 2022, the Parties prepared and filed a Joint

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Scheduling Report which set forth their agreement to submit the matter to mediation.

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The Court and the VDRP Administrator appointed Robert Chalfant as the VDRP

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neutral attorney on November 23, 2022.
3.

The Parties spent December exchanging written discovery and serving

subpoenas on third parties.
4.

The Parties require additional time to complete depositions, including

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the depositions of Plaintiff and Defendant in advance of the VDRP mediation

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deadline, which is currently set for February 22, 2023.

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5.

The Parties have met and conferred and now request an additional forty-

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five (45) days from the current deadline of February 22, 2023 to complete

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depositions and the VDRP mediation. The continued deadline to complete the VDRP

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mediation would be on or about April 10, 2023.

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6.

Based on the foregoing, the Parties respectfully submit that good cause

exists and request that the court grant this joint request.

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DATED: January 17, 2023

DIVERSITY LAW GROUP, P.C.

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By: /s/ Kristen M. Agnew
Larry W. Lee
Kristen M. Agnew
Nicholas Rosenthal

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JOINT STIP AND ORDER TO CONT MEDIATION COMPLETION DEADLINE

Case 2:22-cv-01531-TLN-KJN Document 13 Filed 01/18/23 Page 3 of 4

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DATED: January 17, 2023

FISHER & PHILLIPS LLP
By: /s/ Amy L. Lessa
Amy L. Lessa
Lauren Bushman
Attorneys for Defendant TEEMA, Inc.

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ATTESTATION REGARDING ELECTRONIC SIGNATURES

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I, Amy Lessa, attest that all other signatories to this document, on whose

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behalf this filing is submitted, concur in the filing’s content and have authorized this

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filing. I declare under penalty of perjury, under the laws of the United States of

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America and the State of California, that the foregoing is true and correct.

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/s/ Amy L. Lessa
Amy L. Lessa

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JOINT STIP AND ORDER TO CONT MEDIATION COMPLETION DEADLINE

Case 2:22-cv-01531-TLN-KJN Document 13 Filed 01/18/23 Page 4 of 4

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ORDER
Good cause appearing, the Joint Stipulation to Continue the VDRP Mediation
Completion Deadline is granted, and IT IS HEREBY ORDERED that the VDRP
Mediation Completion Deadline be continued to April 10, 2023.
IT IS SO ORDERED.

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DATED: January 17, 2023

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Troy L. Nunley
United States District Judge

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JOINT STIP AND ORDER TO CONT MEDIATION COMPLETION DEADLINE