Lovgren et al v. Enloe Medical Center

Filing 15

STIPULATION and ORDER signed by Senior District Judge William B. Shubb on 06/03/2024 VACATING the 08/12/2024 Scheduling Conference and CONTINUING the #13 Motion to Remand Hearing to 3/31/2025 at 01:30 PM in Courtroom 5 (WBS) before Senior District Judge William B. Shubb. Defendant's opposition due by 02/04/2025 and Plaintiffs' reply due by 02/11/2025. (Murphy, J) Modified on 6/5/2024 (Murphy, J).

1
2
3
4
5
6
7
8
9
10
11

BLUMENTHAL NORDREHAUG BHOWMIK DE BLOUW LLP
Norman B. Blumenthal (State Bar # 068687)
[e-mail]
Kyle R. Nordrehaug (State Bar #205975)
[e-mail]
Aparajit Bhowmik (State Bar #248066)
[e-mail]
Jeffrey S. Herman (State Bar #280058)
[e-mail]
Sergio J. Puche (State Bar #289437)
[e-mail]
Trevor G. Moran (State Bar #330394)
[e-mail]
2255 Calle Clara
La Jolla, CA 92037
Telephone: [phone]
Facsimile: [phone]
Firm Website: http://www.bamlawca.com
Attorneys for Plaintiffs
[Additional Counsel on Following Page]

12
13

UNITED STATES DISTRICT COURT

14

EASTERN DISTRICT OF CALIFORNIA

15
16

CHRISTIAN LOVGREN and GINA
CUNEO, on behalf of the State of
California, as private attorneys general,

17

Plaintiffs,

18

v.

19

ENLOE MEDICAL CENTER, a
California; and Does 1 through 50,
Inclusive,

20
21

Case No. 2:24-cv-01133-WBS-DMC
JOINT STIPULATION TO SET
BRIEFING SCHEDULE ON
PLAINTIFFS’ MOTION TO
REMAND CASE TO STATE COURT
AND TO STAY CASE PENDING
MEDIATION
Judge:
Hon. William B. Shubb
Courtroom: 5, 14th Floor

Defendants.

22
23
24
25
26
27
1

28

JOINT STIPULATION TO SET BRIEFING SCHEDULE ON PLAINTIFFS’ MOTION TO REMAND CASE
TO STATE COURT AND TO STAY CASE PENDING MEDIATION
4857-5172-2436.1 / 054681-1067

1

7

Barbara A. Blackburn, Bar No. 253731
[e-mail]
Douglas L. Ropel. Bar No. 300486
[e-mail]
Lauren J. Orozco, Bar No. 332880
[e-mail]
LITTLER MENDELSON, P.C.
500 Capitol Mall, Suite 2000
Sacramento, California 95814
Telephone: [phone]
Fax No.: 916.561.0828

8

Attorneys for Defendant

2
3
4
5
6

9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
2

28

JOINT STIPULATION TO SET BRIEFING SCHEDULE ON PLAINTIFFS’ MOTION TO REMAND CASE
TO STATE COURT AND TO STAY CASE PENDING MEDIATION
4857-5172-2436.1 / 054681-1067

1

Plaintiffs CHRISTIAN LOVGREN and GINA CUNEO (“Plaintiffs”) and

2

Defendant ENLOE MEDICAL CENTER (“Defendant”) (collectively the “Parties”),

3

by and through their respective counsel of record, hereby stipulate and agree as

4

follows:

5

WHEREAS, on May 16, 2024, Plaintiffs filed and served their Notice of

6

Motion and Motion to Remand Case to State Court, which is set for hearing on June

7

24, 2024 (Dkt. 13);

8

WHEREAS, the Parties have agreed to participate in private mediation on

9

January 21, 2025, with experienced wage and hour mediator Steven Serratore,

10

which was his first available date that was mutually agreeable for the Parties;

11

WHEREAS, to prevent the Parties from incurring further, potentially

12

unnecessary litigation expenses, and in the interests of judicial economy and the

13

conservation of Party resources, the Parties agree that good cause exists to stay this

14

action until after the mediation set for January 21, 2025;

15

WHEREAS, if mediation is cancelled by one or more Parties, the Parties will

16

promptly notify the Court of the cancellation, the stay shall be lifted, and

17

Defendant’s Opposition to Plaintiffs’ Motion to Remand Case to State Court will be

18

due thirty (30) days after cancellation, with Plaintiffs’ Reply to Defendant’s

19

Opposition due two (2) weeks thereafter; and

20

WHEREAS, the Parties met and conferred regarding the setting of a briefing

21

schedule for Plaintiffs’ Motion to Remand Case to State Court, and the Parties have

22

agreed on the following briefing schedule:

23
24

• The hearing on Plaintiffs’ Motion to Remand Case to State Court to be
continued from June 24, 2024, to March 24, 2025;

25

• Defendant’s opposition deadline to be continued to February 4, 2025; and

26

• Plaintiffs’ reply deadline to be continued to February 11, 2025.

27

NOW, THEREFORE, based upon the foregoing, the Parties, by and through
3

28

JOINT STIPULATION TO SET BRIEFING SCHEDULE ON PLAINTIFFS’ MOTION TO REMAND CASE
TO STATE COURT AND TO STAY CASE PENDING MEDIATION
4857-5172-2436.1 / 054681-1067

1

their respective undersigned counsel of record, hereby stipulate and agree as

2

follows:

3

1.

4

this stipulation;

5

2.

6
7

The above recitals are an integral part of and provide the foundation for

This matter is stayed, including all deadlines associated therewith, until

after the completion of the mediation in this case;
3.

If mediation is cancelled by one or more Parties, the Parties will

8

promptly notify the Court of the cancellation, the stay shall be lifted, and

9

Defendant’s Opposition to Plaintiffs’ Motion to Remand Case to State Court will be

10

due thirty (30) days after cancellation, with Plaintiffs’ Reply to Defendant’s

11

Opposition due two (2) weeks thereafter; and

12
13
14
15
16
17
18

4.

The briefing schedule for Plaintiffs’ Motion to Remand Case to State

Court is as follows:
a. The hearing on Plaintiffs’ Motion to Remand Case to State Court to be
continued from June 24, 2024, to March 24, 2025;
b. Defendant’s opposition deadline to be continued to February 4, 2025;
and
c. Plaintiffs’ reply deadline to be continued to February 11, 2025.

19

IT IS SO STIPULATED.

20

[Signatures of Following Page]

21
22
23
24
25
26
27
4

28

JOINT STIPULATION TO SET BRIEFING SCHEDULE ON PLAINTIFFS’ MOTION TO REMAND CASE
TO STATE COURT AND TO STAY CASE PENDING MEDIATION
4857-5172-2436.1 / 054681-1067

1
2
3

LITTLER MENDELSON, P.C.
Dated: May 30, 2024

4
5
6

By: /s/ Douglas L. Ropel
Barbara Blackburn
Douglas L. Ropel
Attorney for Defendant
ENLOE MEDICAL CENTER

7
8
9

Dated: May 31, 2024

BLUMENTHAL NORDREHAUG BHOWMIK
DE BLOUW LLP

10
By: /s/ Jeffrey S. Herman (Authorized on 5/31/2024)
Jeffrey S. Herman
Sergio Julian Puche
Trevor G. Moran

11
12
13
14

Attorney for Plaintiffs
CHRISTIAN LOVGREN and GINA CUNEO

15
16
17
18
19
20
21
22
23
24
25
26
27

5

28

JOINT STIPULATION TO SET BRIEFING SCHEDULE ON PLAINTIFFS’ MOTION TO REMAND CASE
TO STATE COURT AND TO STAY CASE PENDING MEDIATION
4857-5172-2436.1 / 054681-1067

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

ORDER
By stipulation of the Parties, and for good cause shown, the Court hereby
Orders as follows:
1.

This above-captioned action is stayed, including all deadlines

associated therewith, until after the completion of the mediation in this case;
2.

This matter is stayed, including all deadlines associated therewith, until

after the completion of the mediation in this case;
3.

The August 12, 2024 Scheduling Conference is vacated;

4.

If mediation is cancelled by one or more Parties, the Parties will

promptly notify the Court of the cancellation, the stay shall be lifted, and
Defendant’s Opposition to Plaintiffs’ Motion to Remand Case to State Court will be
due thirty (30) days after cancellation, with Plaintiffs’ Reply to Defendant’s
Opposition due two (2) weeks thereafter; and
5.

The briefing schedule for Plaintiffs’ Motion to Remand Case to State

Court is as follows:
a. The hearing on Plaintiffs’ Motion to Remand Case to State Court to be
continued from June 24, 2024, to March 31, 2025 at 1:30pm;
b. Defendant’s opposition deadline to be continued to February 4, 2025;
and
c. Plaintiffs’ reply deadline to be continued to February 11, 2025.

IT IS SO ORDERED.
Dated: June 3, 2024

26
27
6

28

JOINT STIPULATION TO SET BRIEFING SCHEDULE ON PLAINTIFFS’ MOTION TO REMAND CASE
TO STATE COURT AND TO STAY CASE PENDING MEDIATION
4857-5172-2436.1 / 054681-1067