Moralez v. Whole Foods Market Inc. et al

Filing 78

ORDER granting 77 STIPULATION WITH PROPOSED ORDER Joint Stipulation to Continue Case Management Conference filed by Bond CC Oakland LLC. Case Management Conference reset for 3/29/2013 08:30 AM in Courtroom 6, 17th Floor, San Francisco. Signed by Judge Charles R. Breyer on 2/5/2013. (beS, COURT STAFF) (Filed on 2/5/2013)

Case3:12-cv-01072-CRB Document77 Filed02/04/13 Page1 of 3

1 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
A Limited Liability Partnership
2
Including Professional Corporations
RICHARD J. SIMMONS, Cal. Bar No. 72666
3 [e-mail]
DEREK R. HAVEL, Cal. Bar No. 193464
4 [e-mail]
333 South Hope Street, 43rd Floor
5 Los Angeles, California 90071-1422
Telephone:
213-620-1780
6 Facsimile:
213-620-1398
7 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
A Limited Liability Partnership
8
Including Professional Corporations
HAYLEY S. GRUNVALD, Cal. Bar No. 227909
9 [e-mail]
501 West Broadway, 19th Floor
10 San Diego, California 92101
Telephone:
619-338-6500
11 Facsimile:
619-234-3815
12 Attorneys for Defendant BOND CC OAKLAND LLC
13 LAW OFFICES OF PAUL L. REIN
PAUL L. REIN, Cal Bar No. 43053
14 [e-mail]
CELIA McGUINNESS, Cal Bar No. 159420
15 [e-mail]
CATHERINE M. CABALO, Cal Bar No. 248198
16 [e-mail]
200 Lakeside Drive, Suite A
17 Oakland, California 94612
Telephone:
510-832-5001
18 Facsimile:
510-832-4787
19 Attorneys for Plaintiff FRANCISCA MORALEZ
20

UNITED STATES DISTRICT COURT

21

NORTHERN DISTRICT OF CALIFORNIA

22 FRANCISCA MORALEZ,
23
24

Plaintiff,
v.

25 WHOLE FOODS MARKET
CALIFORNIA, INC.; BOND CC
26 OAKLAND LLC; and DOES 1-10,
Inclusive
27
Defendants.
28
SMRH:407978361.1

Case No. 3:12-cv-01072-CRB
[Complaint Filed March 2, 2012]
[Amended Complaint Filed May 10, 2012]
JOINT STIPULATION TO CONTINUE
CASE MANAGEMENT CONFERENCE;
ORDER

Case No. 3:12-cv-01072-CRB
JOINT STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE

Case3:12-cv-01072-CRB Document77 Filed02/04/13 Page2 of 3

1

COMES NOW counsel for Plaintiff and Defendant to jointly request the Court continue

2 the date for the Case Management Conference ("CMC") from February 8, 2013 to a date following
3 the mediation conference the parties have requested be set on March 20, 2013.
4

On December 4, 2012, the Court issued an order setting the CMC for January 18, 2013.

5 The parties jointly agreed, and the Court ordered, the CMC be continued to January 25, 2013.
6 Subsequently, Plaintiff's counsel had a motion hearing in another matter set for January 25 at 9:00
7 a.m. in San Jose, so the parties jointly agreed, and the Court ordered, the CMC continued to
8 February 8, 2013. On January 30, 2013, Plaintiff’s counsel filed on both parties' behalf a notice of
9 need for mediation conference requesting a mediation conference be set for March 20, 2013. Both
10 parties are optimistic that this matter can be resolved at this mediation conference.
11

On January 30, 2013, counsel for the parties conferred to discuss whether it made sense to

12 jointly request the Court move the CMC set for February 8, 2013, due to the parties' agreement to
13 conduct a mediation on March 20, 2013. Both parties agreed that the most economical approach,
14 and the one which would avoid wasting the Court's time and resources, would be to make this
15 joint request.
16

The parties agreed that, following the mediation conference, they would file a notice with

17 the Court advising of the outcome of the conference and whether a follow-up CMC was necessary.
18

Accordingly, the parties jointly seek that the February 8, 2013 CMC be taken off calendar

19 until after the mediation conference is held. and continued for March 29, 2013 at 8:30 a.m.
20 Dated: February 4, 2013
21

LAW OFFICES OF PAUL L. REIN

22
By

23
24
25
26

/s/ Celia McGuinness
PAUL L. REIN
CELIA McGUINNESS
CATHERINE M. CABALO
Attorneys for Plaintiff
FRANCISCA MORALEZ

27
28
SMRH:407978361.1

Case No. 3:12-cv-01072-CRB
-1JOINT STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE

Case3:12-cv-01072-CRB Document77 Filed02/04/13 Page3 of 3

1 Dated: February 4, 2013
2

SHEPPARD, MULLIN, RICHTER & HAMPTON LLP

3
By

4
5
6

/s/ Hayley S. Grunvald
RICHARD J. SIMMONS
DEREK R. HAVEL
HAYLEY S. GRUNVALD
Attorneys for Defendant BOND CC OAKLAND, LLC

7
SIGNATURE CERTIFICATION

8
9
10
11
12
13

Pursuant to Section 2(f)(4) of the Electronic Case Filing Administrative Policies and
Procedures Manual, I hereby certify that the content of this document is acceptable to Celia
McGuinness, counsel for Plaintiff Francisca Moralez, and that I have obtained Ms. McGuinness'
authorization to affix her electronic signature to this document.
Dated: February 4, 2013
SHEPPARD, MULLIN, RICHTER & HAMPTON LLP

14
15

By
16
17
18

/s/ Hayley S. Grunvald
RICHARD J. SIMMONS
DEREK R. HAVEL
HAYLEY S. GRUNVALD
Attorneys for Defendant BOND CC OAKLAND, LLC

19
20

PURSUANT TO STIPULATION, IT IS SO ORDERED.

23

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26

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Breyer

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Judge C

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25

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JUDGE, UNITED STATES DISTRICT COURT
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24

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February 5, 2013
Dated: ________________________________

S

22

ORDER

UNIT
ED

21

N

F
D IS T IC T O
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SMRH:407978361.1

Case No. 3:12-cv-01072-CRB
-2JOINT STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE