Lahham et al v. Serra Medical Transportation Company, Inc. et al

Filing 26

STIPULATION AND ORDER re 25 STIPULATION WITH PROPOSED ORDER REQUESTING EXTENSION OF MEDIATION DEADLINE filed by Laith Abuhejleh, Ahmad Kiwan, Mohamed Algahim, Shadi Al Lahham, Nazmi Kastiro. Signed by Chief Judge James Ware on August 16, 2012. (wsn, COURT STAFF) (Filed on 8/16/2012)

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1 Michael S. Sorgen (SBN 43107)
[e-mail]
2 Ryan L. Hicks (SBN 260284)
[e-mail]
3 LAW OFFICES OF MICHAEL S. SORGEN
Richard A. Hoyer (SBN 151931)
4 [e-mail]
HOYER & ASSOCIATES
5 240 Stockton Street, 9th Floor
San Francisco, CA 94108
6 T: [phone]
F: [phone]
7
Attorneys for Plaintiffs
8
Leila Narvid, Bar No. 229402
9 [e-mail]
Emily J. Schultz, Bar No. 202815
10 [e-mail]
PAYNE & FEARS LLP
11 Attorneys at Law
One Embarcadero Center, Suite 2300
12 San Francisco, California 94111
Telephone: [phone]
13 Facsimile: [phone]

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14 Attorneys for Defendants
SERRA MEDICAL TRANSPORTATION
15 COMPANY, INC., SERRA YELLOW CAB
OF DALY CITY, INC., and TALIB SALAMIN
16
UNITED STATES DISTRICT COURT
17
NORTHERN DISTRICT OF CALIFORNIA
18
SHADI AL LAHHAM, LAITH ABUHEJLEH, Case No. 3:12-cv-00355-JW
19 NAZMI KASTIRO, AHMAD KIWAN and
MOHAMED ALGAHIM, on behalf of
CLASS ACTION
20 themselves and all others similarly
situated,
STIPULATION REQUESTING
21
EXTENSION OF MEDIATION DEADLINE
Plaintiffs,
AND [PROPOSED] ORDER THEREON
22
vs.
[N.D. Cal. ADR Local Rule 6-5]
23
SERRA MEDICAL TRANSPORTATION
The Hon. James Ware
24 COMPANY, INC., SERRA YELLOW CAB
OF DALY CITY, INC., TALIB SALAMIN
25 and DOES 1-25,
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Defendants.

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TO THE CLERK OF COURT AND TO ALL PARTIES AND COUNSEL OF RECORD:
STIPULATION REQUESTING EXTENSION OF MEDIATION DEADLINE
Pursuant to ADR Local Rule 6-5, all parties hereby stipulate to request extension of

4 the mediation deadline from September 10, 2012 to January 31, 2013.
5

CONSIDERATIONS SUPPORTING THE REQUEST

6

The mediation is currently scheduled for September 6, 2011. The parties are

7 currently engaged in formal discovery and also the informal exchange of information for the
8 purposes of mediation. Further information must be exchanged and the parties must be
9 deposed in order for the mediation to be meaningful. Furthermore, as plaintiffs bring
10 putative class claims, Fair Labor Standards Act claims, and collective claims under the
11 California Private Attorneys General Act, plaintiffs must conduct sufficient discovery and
12 investigation such that the Court can approve a settlement in the event that the mediation is
13 successful. As such, the parties hereby request that the mediation deadline be extended
14 until January 31, 2013, so that they may reschedule the mediation without any further
15 continuances. All parties and the mediator concur in the request to extend the deadline.
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IT IS SO STIPULATED.

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DATED: August 10, 2012
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By
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Michael S. Sorgen
Ryan L. Hicks
LAW OFFICES OF MICHAEL S. SORGEN
Richard A. Hoyer
HOYER & ASSOCIATES
Attorneys for Plaintiffs

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STIPLATION REQUESTING EXTENSION OF MEDIATION DEADLINE

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DATED: August 10, 2012
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By /s/ Leila Narvid
Leila Narvid
PAYNE & FEARS LLP

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Attorneys for Defendants

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[PROPOSED] ORDER
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Per the parties’ stipulation, and good cause having been shown, the mediation
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deadline is hereby extended to January 31, 2011. November 19, 2012.

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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DATED: August __, 2012

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By:

United States District Judge
Honorable James Ware

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STIPLATION REQUESTING EXTENSION OF MEDIATION DEADLINE

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