Lounibos v. Keypoint Government Solutions Inc

Filing 17

STIPULATION AND ORDER EXTENDING MEDIATION DEADLINE TO 9/15/12 AND RESETTING FURTHER CMC TO 10/26/12 at 10:30 a.m. re 15 STIPULATION WITH PROPOSED ORDER CONTINUING ADR DEADLINE AND CONTINUING CASE MANAGEMENT CONFERENCE filed by Keypoint Government Solutions Inc Case Management Statement due by 10/19/2012. Further Case Management Conference set for 10/26/2012 10:30 AM in Courtroom 5, 17th Floor, San Francisco.. Signed by Judge Edward M. Chen on 7/24/12. (bpf, COURT STAFF) (Filed on 7/24/2012)

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STEVEN L. HAMMOND (SBN 220521)
ANDREW M. KLIMENKO (SBN 124612)
Hammond Law Group, P.C.
One Embarcadero Center, Suite 2360
San Francisco, California 94111
Telephone: [phone]
DAVID HARRIS (SBN 215224)
North Bay Law Group
116 E Blithedale Avenue, Suite 2
Mill Valley, CA 94941
Telephone: [phone]
FRANCIS SHEHADEH (SBN 251130)
Law Office of Francis J. Shehadeh
819 Eddy Street
San Francisco, CA 94109
Telephone: [phone]
Attorneys for Plaintiff
DONALD LOUNIBOS
MICHELLE B. HEVERLY (SBN 178660)
KARIN M. COGBILL (SBN 244606)
LITTLER MENDELSON, P.C.
50 W. San Fernando, 15th Floor
San Jose, CA 95113.2303
Telephone: [phone]
Attorneys for Defendant
KEYPOINT GOVERNMENT SOLUTIONS, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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DONALD LOUNIBOS, individually and
on behalf of all others similarly situated,
Plaintiff,

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v.

Case No. 12-CV-0636 (EMC)
STIPULATION AND [PROPOSED]
ORDER CONTINUING ADR DEADLINE
AND CONTINUING CASE
MANAGEMENT CONFERENCE

KEYPOINT GOVERNMENT
SOLUTIONS, INC., a Delaware
Corporation, and Does 1-10, inclusive,
Defendants.

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1.
STIPULATION AND [PROPOSED] ORDER CONTINUING ADR DEADLINE
AND CASE MANAGEMENT CONFERENCE

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The parties hereby stipulate as follows:

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WHERAS, the instant matter was referred to panel mediation through the ADR Department

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of the Northern District of California. The parties were assigned to mediate this matter with the

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Honorable David A. Garcia (Ret.) through JAMS in San Francisco, California. To this end, the

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parties’ current deadline to complete mediation is September 1, 2012. In light of Judge Garcia’s

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schedule, however, the first available date the parties could schedule the mediation is September 6,

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2012;

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WHEREAS, a Further Case Management Conference is currently scheduled to take place on
September 14, 2012 at 10:30 a.m. in Courtroom 5, before the Honorable Edward M. Chen; and
WHEREAS, the parties respectfully request that the Court grant a 15-day continuance of the

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parties’ mediation deadline so that the parties can take part in the mediation with Judge Garcia on

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September 6, 2012;

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IT IS THEREFORE STIPULATED AND AGREED that the parties shall complete

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mediation on or before September 15, 2012. The parties further stipulate to continue the Further Case

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Management Conference until October 12, 2012 at 10:30 a.m. in Courtroom 5, if that is convenient to

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the Court. The parties shall file a Joint Case Management Statement at least one week prior to the Case

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Management Conference.

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IT IS SO STIPULATED.
DATED: July 18, 2012

NORTH BAY LAW GROUP
___________/s/___________________
David S. Harris
Attorney For Plaintiff
DONALD LOUNIBOS

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DATED: July 18, 2012

LITTLER MENDELSON
____________/s/__________________
Michelle Heverly
Attorneys for Defendant
KEYPOINT GOVERNMENT SOLUTIONS

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2.
STIPULATION AND [PROPOSED] ORDER CONTINUING ADR DEADLINE
AND CASE MANAGEMENT CONFERENCE

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IT IS HEREBY ORDERED AS FOLLOWS:

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The parties shall complete mediation on or before September 15, 2012. The Further Case
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Management Conference is continued to October 12, 2012 at 10:30 a.m. in Courtroom 5. The

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parties shall file a Joint Case Management Statement at least one week prior to the Conference.

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Firmwide: 113238284.1 063273.1017

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Honorable Edward M. Chen
United States District Court Judge
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DATED: July __, 2012

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3.
STIPULATION AND [PROPOSED] ORDER CONTINUING ADR DEADLINE
AND CASE MANAGEMENT CONFERENCE