Cooper v. United Parcel Service of America, Inc.
Filing
39
ORDER to reschedule CMC re 36 Stipulation filed by United Parcel Service of America, Inc. Further Case Management Conference set for 2/10/2012 08:30 AM in Courtroom 6, 17th Floor, San Francisco.. Signed by Judge Charles R. Breyer on 11/18/2011. (beS, COURT STAFF) (Filed on 11/21/2011)
Case3:10-cv-04764-CRB Document36
Filed11/15/11 Page1 of 4
1 WAUKEEN Q. McCOY, ESQ. (SBN: 168228)
LAW OFFICES OF WAUKEEN Q. McCOY
2 703 Market Street, Suite 1407
San Francisco, California 94103
3 Telephone (415) 675-7705
Facsimile (415) 675-2530
4
5 SHYAMALA T. RAJENDER, ESQ. (SBN: 69806)
RAJENDER LAW OFFICES
6 4115 Blackhawk Plaza Circle
Suite 100
7 Danville, CA 94506
Telephone (925) 648-2028
8 Facsimile (925) 648-2035
9 Attorneys for Plaintiff
REBECCA COOPER
10
11 VILLARREAL HUTNER & TODD PC
LARA VILLARREAL HUTNER, ESQ., Cal. Bar No. 178639
12 E-Mail: lhutner@vhtattorneys.com
JESSICA N. LEAL, ESQ., Cal Bar No. 267232
13 E-Mail: jleal@vhtattorneys.com
575 Market Street, Suite 300
14 San Francisco, California 94105
Telephone: 415.543.4200
15 Facsimile: 415.512.7674
16 Attorneys for Defendant
UNITED PARCEL SERVICE, INC.,
17 an Ohio Corporation
(erroneously named as "UNITED PARCEL
18 SERVICE OF AMERICA, INC.")
19
UNITED STATES DISTRICT COURT
20
NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION
21
22 REBECCA COOPER, an individual,
Plaintiff,
23
24
v.
25 UNITED PARCEL SERVICE OF AMERICA,
INC., and DOES 1-50,
26
Defendants.
27
Case No. CV 10-04764 CRB
JOINT STIPULATION AND [PROPOSED]
ORDER TO RESCHEDULE
CASE MANAGEMENT CONFERENCE
Date: December 2, 2011
Time: 8:30 a.m.
Judge: Hon. Charles R. Breyer
28
CASE NO. CV 10-04764 CRB
JOINT STIPULATION AND [PROPOSED] ORDER TO
RESCHEDULE CASE MANAGEMENT CONFERENCE
Case3:10-cv-04764-CRB Document36
1
Filed11/15/11 Page2 of 4
Plaintiff Rebecca Cooper (hereinafter "Plaintiff"), through her counsel Law Offices of
2 Waukeen Q. McCoy and Rajender Law Offices, and Defendant United Parcel Service, Inc.
3 (erroneously named as United Parcel Service of America, Inc., hereinafter "UPS"), through its
4 counsel Villarreal Hutner & Todd PC, (collectively "the Parties") do hereby agree and stipulate to
5 reschedule the December 2, 2011 case management conference for good cause for the reasons set
6 forth below, and as supported by the Declarations of Waukeen Q. McCoy and Lara Villarreal
7 Hutner.
8
1.
On August 26, 2011, Plaintiff's counsel, Waukeen Q. McCoy, noticed the
9 deposition of Plaintiff's former manager Victor Neals for November 2, 2011. This date was
10 selected based on the Parties' availability in advance of the settlement conference initially
11 scheduled with Magistrate Judge Maria Elena James for November 15, 2011.
12
2.
On October 31, 2011, Mr. McCoy notified UPS that he had to cancel Mr. Neals's
13 November 2nd deposition due to a conflict.
14
3.
As the Parties were unavailable to reschedule Mr. Neals's deposition prior to the
15 November 15th settlement conference with Magistrate Judge James, the Parties stipulated to
16 reschedule the settlement conference. Counsel for the Parties each believed that a settlement
17 conference would be most meaningful after the completion of Mr. Neals's deposition.
18
4.
Given the holiday period from Thanksgiving to New Years is UPS's busiest season,
19 the Parties have agreed to reschedule Mr. Neals's deposition to January 10, 2012, which is a time
20 less disruptive to the company's peak season and when all parties and Mr. Neals are available.
21
5.
The next date following Mr. Neals's deposition that the Parties and Magistrate
22 Judge James were available for a settlement conference is February 1, 2012. The Parties
23 submitted a joint request that the Court reschedule the settlement conference to February 1, 2012.
24 The Court granted this request on November 4, 2011.
25
6.
A case management conference is currently on calendar for December 2, 2011.
26 This conference initially was set to occur after the originally scheduled settlement conference if
27 the Parties were unable to resolve the case on November 15, 2011. Now that the settlement
28
-1CASE NO. CV 10-04764 CRB
JOINT STIPULATION AND [PROPOSED] ORDER TO
RESCHEDULE CASE MANAGEMENT CONFERENCE
Case3:10-cv-04764-CRB Document36
Filed11/15/11 Page3 of 4
1 conference has been rescheduled for February 1, 2012, the Parties respectfully submit this joint
2 request that the Court reschedule the case management conference to a date after February 1,
3 2012.
4
7.
Counsel for the Parties each believe that a case management conference will be
5 most meaningful after the completion of the February 1, 2012 settlement conference with
6 Magistrate Judge James. As a result, the request to reschedule the December 2, 2011 case
7 management conference is being made jointly, for good cause, and by stipulation.
8
9 SO STIPULATED:
10 Dated: November 15, 2011
LAW OFFICES OF WAUKEEN Q. McCOY, and
RAJENDER LAW OFFICES
11
12
/s/ Waukeen Q. McCoy
WAUKEEN Q. McCOY
SHYAMALA T. RAJENDER
By
13
14
15
Attorneys for Plaintiff
REBECCA COOPER
16
17
18 Dated: November 15, 2011
VILLARREAL HUTNER & TODD PC
19
20
By
/s/ Lara Villarreal Hunter
LARA VILLARREAL HUTNER
JESSICA N. LEAL
21
22
Attorneys for Defendant
UNITED PARCEL SERVICE, INC.,
an Ohio Corporation (erroneously named as "UNITED
PARCEL SERVICE OF AMERICA, INC.")
23
24
25
26
27
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JOINT STIPULATION AND [PROPOSED] ORDER TO
RESCHEDULE CASE MANAGEMENT CONFERENCE
Case3:10-cv-04764-CRB Document36
Filed11/15/11 Page4 of 4
1 IT IS SO ORDERED that:
2
1.
The December 2, 2011 case management conference is taken off calendar.
3
2.
The Parties' next case management conference will be rescheduled after the
4 February 1, 2012 settlement conference with Magistrate Judge James, on
February 10
5 _____________________, 2012.at 8:30 a.m.
6
7
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November 18
8 Dated: _________________, 2011
S DISTRICT
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By _____________________________________
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Honorable Judge Charles R. Breyer
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JOINT STIPULATION AND [PROPOSED] ORDER TO
RESCHEDULE CASE MANAGEMENT CONFERENCE
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