Lounibos v. Keypoint Government Solutions Inc

Filing 25

STIPULATION AND ORDER RE 24 CONTINUING ADR DEADLINE AND CONTINUING CASE MANAGEMENT CONFERENCE. Case Management Statement due by 11/23/2012. Case Management Conference set for 11/30/2012 10:30 AM in Courtroom 5, 17th Floor, San Francisco. Signed by Judge Edward M. Chen on 10/15/12. (cl, COURT STAFF) (Filed on 10/15/2012)

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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, on behalf of
himself and all others similarly situated,
Plaintiff,
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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LITTLER MENDELSON, P.C.
50 W. San Fernando, 15th Floor
San Jose, CA 95113.2303
408.998.4150

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

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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

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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 October 15, 2012. A Further Case Management

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Conference is currently scheduled to take place on October 26, 2012 at 10:30 a.m. in Courtroom 5,

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before the Honorable Edward M. Chen;

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WHEREAS, the parties have exchanged documentation and taken the deposition of the

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Plaintiff Donald Lounibos, as well as taken the depositions of two employees at Defendant KeyPoint

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Government Solutions, Inc. During the depositions, the parties acknowledged the need for an

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additional exchange of documentation in order to ensure a productive mediation. As a result, the

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mediation with Judge David A. Garcia (Ret.) was rescheduled to take place at JAMS in

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San Francisco on November 2, 2012, the first mutually-agreeable date for all parties;

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

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November 2, 2012;

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IT IS THEREFORE STIPULATED AND AGREED that the parties shall complete all

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

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Management Conference until November 30, 2012, at 10:30 a.m. in Courtroom 5, if that date is

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

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prior to the Case Management Conference.

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IT IS SO STIPULATED.

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DATED: October 10, 2012
NORTH BAY LAW GROUP

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

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LITTLER MENDELSON, P.C.
50 W. San Fernando, 15th Floor
San Jose, CA 95113.2303
408.998.4150

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

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DATED: October 10, 2012
LITTLER MENDELSON

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____________/s/______________________
Michelle Heverly
Attorneys for Defendant
KEYPOINT GOVERNMENT SOLUTIONS

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IT IS HEREBY ORDERED AS FOLLOWS:
The parties shall engage in mediation with Hon. David A. Garcia at JAMS in San Francisco
on November 2, 2012, and all mediation efforts shall be completed on or before November 15, 2012.

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The Case Management Conference is continued to November 30, 2012, at 10:30 a.m. in

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Courtroom 5. The parties shall file a Joint Case Management Statement at least one week prior to

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the Conference.

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DATED: October __, 2012

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__________________________________
Honorable Edward M. Chen
United States District Court Judge

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Firmwide:115081196.1 063273.1017

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LITTLER MENDELSON, P.C.
50 W. San Fernando, 15th Floor
San Jose, CA 95113.2303
408.998.4150

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