Lim v. Zep Inc

Filing 29

STIPULATION AND ORDER EXTENDING ADR DEADLINE re 28 STIPULATION WITH PROPOSED ORDER Extending ADR Deadline filed by Zep Inc. Signed by Judge James Ware on August 29, 2012. (wsn, COURT STAFF) (Filed on 8/29/2012)

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Hunton & Williams LLP

550 South Hope Street, Suite 2000
Los Angeles, California 90071-2627

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REESE RICHMAN LLP
Michael R. Reese (SBN 206773)
[e-mail]
875 Avenue of the Americas, 18th Floor
New York, New York, 10001
Telephone: [phone]
Facsimile: [phone]

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Judge Ja

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Attorneys for Defendant,
ZEP INC.

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es Ware

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HUNTON & WILLIAMS LLP
Belynda Reck (SBN 163561)
[e-mail]
Diana F. Biason (SBN 247274)
[e-mail]
550 South Hope Street, Suite 2000
Los Angeles, California 90071-2627
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff MEE YONG LIM,
on behalf of herself and all others similarly situated

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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MEE YONG LIM, individually and on
behalf of others similarly situated,

CLASS ACTION

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CASE NO. CV-12-00601 JW

Plaintiffs,
[Hon. James Ware]

v.

STIPULATION AND [PROPOSED]
ORDER EXTENDING ADR DEADLINE

ZEP INC.,
Defendant.

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STIPULATION AND [PROPOSED] ORDER EXTENDING ADR DEADLINE
Case No. CV 12-00601 JW

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Plaintiff Mee Yong Lim (“Plaintiff”) and Defendant Zep Inc. (“Zep”)

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(collectively, “the parties”), if permitted by the Court, hereby stipulate to extend the

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Hunton & Williams LLP

550 South Hope Street, Suite 2000
Los Angeles, California 90071-2627

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deadline to hold an ADR session that is currently set for October 19, 2012 to
November 30, 2012. In support of this stipulation to extend the ADR session
deadline, the parties declare as follows:
1.

Pursuant to the stipulation of the parties, on May 5, 2012 , the Court

ordered the October 19, 2012 deadline to conduct private ADR in this matter.
2.

The parties have been cooperating to select a mediator that is mutually

acceptable to the parties and have selected Judge Edward Infante from JAMS in San
Francisco.
3.

The parties believe that Judge Infante will serve as the appropriate

mediator due to his experience mediating complex cases and because of his
experience as former Chief Magistrate Judge for the Northern District of California.
Judge Infante also has extensive experience mediating class action disputes, including
consumer class action disputes.
4.

The instant matter involves a consumer class-action complaint, which

involves claims under the California Consumers Legal Remedies Act, False
Advertising Law, and Unfair Competition Law. Plaintiff’s Amended Complaint also
seeks injunctive relief.
5.

Due to the nature of the claims, the parties believe that Judge Infante will

serve as the appropriate mediator who can best facilitate a meaningful ADR session.
6.

The parties have been advised by JAMS that Judge Infante does not have

an open mediation appointment prior to the current mediation deadline of October 19,
2012. The parties have been informed, however, that Judge Infante has availability in
November.

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STIPULATION AND [PROPOSED] ORDER EXTENDING ADR DEADLINE
Case No. CV 12-00601 JW

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deadline of October 19, 2012 to November 30, 2012 so that they may schedule and
confirm a mediation appointment with Judge Infante.

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The parties, therefore, necessitate a brief extension to the current ADR

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There have been no previous modifications of time in this case. This

deadline extension will not affect other deadlines, such as the close of discovery, the
last day for hearing dispositive motions, and the date of the preliminary pretrial
conference, set by the Court.

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Hunton & Williams LLP

550 South Hope Street, Suite 2000
Los Angeles, California 90071-2627

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The parties respectfully request that the Court enter the Proposed Order for the
reasons set forth above.

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Respectfully Submitted,

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DATED: August 28, 2012

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HUNTON & WILLIAMS LLP
By: /s/ Belynda B. Reck
Belynda B. Reck
Attorney for Defendant
ZEP INC.

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DATED: August 28, 2012

By: /s/ Michael R. Reese
Michael R. Reese
Attorney for Plaintiff MEE YONG
LIM and Proposed Class

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REESE RICHMAN, LLP

*Filer attests that concurrence in the filing has been obtained from Mr. Reese.
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STIPULATION AND [PROPOSED] ORDER EXTENDING ADR DEADLINE
Case No. CV 12-00601 JW

ORDER

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Having read the stipulation of the parties, and good cause appearing therefore,
the deadline to hold an ADR session is continued from October 19, 2012 to November
30, 2012.

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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DATED: August 29, 2012

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_____________________________
Hon. James Ware
United States District Court Chief Judge

Hunton & Williams LLP

550 South Hope Street, Suite 2000
Los Angeles, California 90071-2627

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78681.206003 EMF_US 41736429v2

STIPULATION AND [PROPOSED] ORDER EXTENDING ADR DEADLINE
Case No. CV 12-00601 JW