Houghtailing v. Frito-Lay North America, Inc. et al

Filing 29

STIPULATION AND ORDER to Continue Deadline for Private ADR session. Signed by Judge Thelton E. Henderson on 11/05/2012. (tmi, COURT STAFF) (Filed on 11/5/2012)

1 DuCHARME & COHEN
JAMES A. DuCHARME, ESQ., SBN 61002
2 E-MAIL: [e-mail]
450 Taraval Street, P.M.B. 317
3 San Francisco, CA 94116-2530
Telephone: [phone]
4 Facsimile: 888.668.4170
5 Attorneys for Plaintiff
JESSE HOUGHTAILING
6
VILLARREAL HUTNER & TODD PC
7 TRACY S. TODD, ESQ., SBN 172884
E-Mail: [e-mail]
8 JULIE WONG, ESQ., SBN 247342
E-Mail: [e-mail]
9 575 Market Street, Suite 300
San Francisco, California 94105
10 Telephone: [phone]
Facsimile: 415.512.7674
11
Attorneys for Defendants
12 FRITO-LAY NORTH AMERICA, INC. and
PEPSICO, INC.
13
14

UNITED STATES DISTRICT COURT

15

NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION

16
17 JESSE HOUGHTAILING,
18
19

CASE NO. 3:11-cv-05062-TEH
Judge: Hon. Thelton E. Henderson

Plaintiff,
v.

20 FRITO-LAY NORTH AMERICA, INC., and
PEPSICO, INC., AND DOES 1 TO 100,
21 inclusive,
22

STIPULATION AND REQUEST TO
CONTINUE DEADLINE FOR ADR
SESSION; [PROPOSED] ORDER
GRANTING CONTINUANCE

Action Filed: August 24, 2011
Removal Filed: October 14, 2011
Trial Date: None Set

23

Defendants.

24
25
26
27
28
{100038462}

CASE NO. 3:11-cv-05062-TEH

STIPULATION TO CONTINUE DEADLINE FOR ADR SESSION

1

TO THIS HONORABLE COURT:

2

Plaintiff Jesse Houghtailing (hereinafter "Plaintiff"), by and through his counsel, and

3 Defendants Frito-Lay North America, Inc. and Pepsico, Inc. ("Defendants"), by and through their
4 counsel, do hereby agree, stipulate, and respectfully request as follows:
5

1.

WHEREAS, the Court ordered the Parties to complete their private ADR session

6 by October 31, 2012;
7

2.

WHEREAS, the Parties are engaging in informal resolution efforts;

8

3.

WHEREAS, the Parties have scheduled the completion of Plaintiff's deposition to

9 occur on November 12, 2012 and November 13, 2012 based on the Parties' informal resolution
10 efforts, scheduling conflicts, and Plaintiff's inability to sit for long periods of time;
11

4.

WHEREAS, the Parties have agreed to continue the deadline to complete their

12 private ADR session;
13

8.

THE PARTIES HEREBY STIPULATE to continue the currently scheduled

14 deadline to complete their private ADR session from October 31, 2012 to December 31, 2012.
15

IT IS SO STIPULATED.

16 Dated: October 25, 2012
17

DuCHARME & COHEN
By

18

/s/ James A. Du Charme
JAMES A. DuCHARME

19

Attorneys for Plaintiff
JESSE HOUGHTAILING

20
21 Dated: October 25, 2012

VILLARREAL HUTNER & TODD PC

22
/s/ Julie Wong
TRACY S. TODD
JULIE WONG

By

23
24
25

Attorneys for Defendants
FRITO-LAY NORTH AMERICA, INC.
and PEPSICO, INC.

26
27
28
{100038462}

CASE NO. 3:11-cv-05062-TEH

-1STIPULATION TO CONTINUE DEADLINE FOR ADR SESSION

1

ATTESTMENT OF CONCURRENCE PER GENERAL ORDER 45 FOR FILING:

2

I attest that concurrence in the filing of this document by the signatory James A.

3 Du Charme, has been obtained, and that a record of the concurrence shall be maintained by
4 Villarreal Hutner & Todd PC.
5

I declare under penalty of perjury pursuant to the laws of the United States of

6 America that the foregoing is true and correct.
7

Executed at San Francisco, California this 25th day of October, 2012.

8
9
10

/s/ Julie Wong

11

JULIE WONG

12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
{100038462}

CASE NO. 3:11-cv-05062-TEH

-2STIPULATION TO CONTINUE DEADLINE FOR ADR SESSION

1

[PROPOSED] ORDER

2

31, 2012.
IT IS SO ORDERED.

7

11/05
Dated: _________________, 2012

RT
U
O

10

___________________________________
HON. THELTON E. HENDERSON

11

NO

12

RT

13

helton
Judge T

H

ER

erson

E. Hend

14
15

R NIA

9

S DISTRICT
TE
C
TA

UNIT
ED

8

FO

6

v. Frito-Lay North America, Inc., et al., case number 3:11-cv-05062-TEH, continued to December

LI

5

deadline for the Parties to complete their private ADR session in the instant matter, Houghtailing

A

4

Having considered the foregoing stipulation of the parties, the Court orders the

S

3

N

F
D IS T IC T O
R

C

16
17
18
19
20
21
22
23
24
25
26
27
28
{100038462}

CASE NO. 3:11-cv-05062-TEH

-3STIPULATION TO CONTINUE DEADLINE FOR ADR SESSION