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)

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Case 2:22-cv-01531-TLN-KJN Document 13 Filed 01/18/23 Page 1 of 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 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 (213) 488-6555 (213) 488-6554s facsimile William L. Marder (SBN 170131) bill@polarislawgroup.com POLARIS LAW GROUP 501 San Benito Street, Suite 200 Hollister, CA 95023 Telephone: (831) 531-4214 Facsimile: (831) 634-0333 Attorneys for Plaintiff CHRISTINA TORREZ Amy L. Lessa (SBN 202872) E-Mail: alessa@fisherphillips.com Lauren Bushman (SBN 314865) E-Mail: lbushman@fisherphillips.com FISHER & PHILLIPS LLP 4747 Executive Drive, Suite 1000 San Diego, California 92121 Telephone: (858) 597-9600 Facsimile: (858) 597-9601 Attorneys for Defendant TEEMA, INC. 17 UNITED STATES DISTRICT COURT 18 EASTERN DISTRICT OF CALIFORNIA 19 CHRISTINA TORREZ, 20 Plaintiff, 21 22 23 24 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, 25 26 Defendants. 27 28 1 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 1 TO THE HONORABLE COURT: 2 Plaintiff Christina Torrez and Defendant TEEMA, Inc., by and through their 3 undersigned counsel, hereby jointly move this Court for an order continuing the 4 Voluntary Dispute Resolution Program (“VDRP”) mediation completion deadline, 5 as set forth below, for the following reasons: 6 1. This case was removed from state court on August 31, 2022. 7 2. On December 28, 2022, the Parties prepared and filed a Joint 8 Scheduling Report which set forth their agreement to submit the matter to mediation. 9 The Court and the VDRP Administrator appointed Robert Chalfant as the VDRP 10 11 12 13 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 14 the depositions of Plaintiff and Defendant in advance of the VDRP mediation 15 deadline, which is currently set for February 22, 2023. 16 5. The Parties have met and conferred and now request an additional forty- 17 five (45) days from the current deadline of February 22, 2023 to complete 18 depositions and the VDRP mediation. The continued deadline to complete the VDRP 19 mediation would be on or about April 10, 2023. 20 21 6. Based on the foregoing, the Parties respectfully submit that good cause exists and request that the court grant this joint request. 22 23 DATED: January 17, 2023 DIVERSITY LAW GROUP, P.C. 24 25 26 27 By: /s/ Kristen M. Agnew Larry W. Lee Kristen M. Agnew Nicholas Rosenthal 28 2 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 1 2 3 4 5 DATED: January 17, 2023 FISHER & PHILLIPS LLP By: /s/ Amy L. Lessa Amy L. Lessa Lauren Bushman Attorneys for Defendant TEEMA, Inc. 6 7 8 ATTESTATION REGARDING ELECTRONIC SIGNATURES 9 I, Amy Lessa, attest that all other signatories to this document, on whose 10 behalf this filing is submitted, concur in the filing’s content and have authorized this 11 filing. I declare under penalty of perjury, under the laws of the United States of 12 America and the State of California, that the foregoing is true and correct. 13 14 /s/ Amy L. Lessa Amy L. Lessa 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 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 1 2 3 4 5 6 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. 7 8 DATED: January 17, 2023 9 Troy L. Nunley United States District Judge 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4 JOINT STIP AND ORDER TO CONT MEDIATION COMPLETION DEADLINE

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