Lounibos v. Keypoint Government Solutions Inc

Filing 21

STIPULATION AND ORDER re 19 MOTION to Continue ADR deadline to 10/15/12 [STIPULATION AND [PROPOSED] ORDER CONTINUING ADR DEADLINE] filed by Keypoint Government Solutions Inc. Signed by Judge Edward M. Chen on 8/16/12. (bpf, COURT STAFF) (Filed on 8/16/2012)

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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,

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

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

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STIPULATION AND [PROPOSED] ORDER CONTINUING ADR DEADLINE

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The parties hereby stipulate as follows:

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

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

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

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requested a continued deadline to complete mediation by September 15, 2012. (Dkt No. 17);

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WHEREAS, the parties are engaged in preliminary discovery in advance of the mediation, but as

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a result of scheduling conflicts, the parties will not be able to complete the necessary depositions prior

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to the current ADR deadline;

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WHEREAS, the parties have continued their mediation with Judge Garcia to September 26,
2012;

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WHEREAS, the parties respectfully request that the Court grant a 30-day continuance of the

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parties’ mediation deadline. The next Case Management Conference is scheduled for October 26, 2012,

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and thus the parties’ do not anticipate that a further continuance of the ADR deadline will impact the

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current case schedule;

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IT IS THEREFORE STIPULATED AND AGREED that the parties shall complete mediation on
or before October 15, 2012.

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IT IS SO STIPULATED.

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DATED: August 15, 2012

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/s/ David S. Harris
David S. Harris
Attorney For Plaintiff
DONALD LOUNIBOS

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NORTH BAY LAW GROUP

DATED: August 15, 2012

LITTLER MENDELSON
/s/ Karin M. Cogbill
Karin M. Cogbill
Attorneys for Defendant
KEYPOINT GOVERNMENT SOLUTIONS,
INC.

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STIPULATION AND [PROPOSED] ORDER CONTINUING ADR DEADLINE

The parties shall complete mediation on or before October 15, 2012.

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hen

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Judge E

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Firmwide:113806375.1 063273.1017

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__________________________________
Honorable Edward M.ERED
Chen
United States SO ORCourt Judge
District D
IS

UNIT
ED

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DATED: August____, 2012

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IT IS HEREBY ORDERED AS FOLLOWS:

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D IS T IC T O
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STIPULATION AND [PROPOSED] ORDER CONTINUING ADR DEADLINE