Jesse v. Study Group U.S.A., Inc

Filing 16

ORDER CONTINUING INITIAL CASE MANAGEMENT CONFERENCE AND EXTENDING THE DEADLINE FOR COMPLETION OF PRIVATE ADR. The Initial Case Management Conference is continued from December 21, 2012 to March 22, 2013. The parties shall submit a Joint Report no later than 7 days prior to the conference. The parties shall complete private ADR no later than 60 days from the date of the conference. Signed by Judge Maxine M. Chesney on December 13, 2012. (mmclc1, COURT STAFF) (Filed on 12/13/2012)

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RUKIN HYLAND DORIA & TINDALL LLP
John F. Hyland (State Bar No. 178875)
[e-mail]
Rosha Jones (State Bar No. 279143)
[e-mail]
100 Pine Street, Suite 2150
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
Andrea Jesse

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MORGAN, LEWIS & BOCKIUS LLP
L. Julius M. Turman (State Bar No. 226126)
[e-mail]
Shannon Nakabayashi (State Bar No. 215469)
[e-mail]
One Market Street, Spear Street Tower
San Francisco, California 94105-1126
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant
Study Group U.S.A., d.b.a. Embassy Center for
English Studies

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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CASE NO.: 12-CV-04874-MMC

ANDREA JESSE,
Plaintiff,

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vs.

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STUDY GROUP USA, Inc., a Delaware
Corporation, and DOES 1 through 25
inclusive,

STIPULATION AND PROPOSED ORDER
CONTINUING INITIAL CASE
MANAGEMENT CONFERENCE AND
EXTENDING THE DEADLINE FOR
COMPLETION OF PRIVATE ADR

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Defendants.
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Date: December 21, 2012
Time: 10:30 A.M.
Place: Courtroom 7, 19th Floor
Judge: Hon. Maxine M. Chesney

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STIPULATION AND ORDER CONTINUING INITIAL CASE MANAGEMENT CONFERENCE
AND EXTENDING ADR DEADLINE

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STIPULATION FOR CONTINUANCE OF INITIAL CASE MANAGEMENT CONFERENCE

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AND EXTENDING DEADLINE FOR COMPLETION OF PRIVATE ADR
Plaintiff Andrea Jesse and Defendant Study Group USA, by and through their counsel of

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record, hereby stipulate and agree as follows:
WHEREAS, the Court scheduled the Initial Case Management Conference for December

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21, 2012; and
WHEREAS, the Court on December 3, 2012 entered its order referring this matter to

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private ADR and setting a deadline to complete the ADR within ninety (90) days from the date of

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WHEREAS,

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hn F. Hyland, Rosha

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Jones, and Rukin Hyland Doria & Tindall LLP, intend to file a motion to withdraw as counsel in

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this case; and

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WHEREAS, the parties believe it would best serve the interests of the Court and the

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parties to conduct the Initial Case Management Conference after the Court has ruled on the

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motion to withdraw and Plaintiff Jesse has retained new counsel to represent her in this matter;
WHEREAS, the parties believe they can most effectively and efficiently conduct private

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ADR after the Court has ruled on the motion to withdraw and Plaintiff Jesse has retained new

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counsel to represent her in this matter and in the ADR process; and
WHEREAS, the parties do not believe that continuance of the Initial Case Management

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Conference or extension of the deadline to complete ADR will cause undue prejudice to any

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party;

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IT IS HEREBY STIPULATED AND AGREED that the Court should continue the Initial

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Case Management Conference for ninety (9

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counsel of record in this case to file its motion to withdraw as counsel, for the Court to consider

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and rule on the motion, for Plaintiff Jesse to retain new counsel to represent her in this matter, and

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for such new counsel to familiarize himself or herself such that he or she can meaningfully

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participate in the Initial Case Management Conference. The parties further STIPULATE AND

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STIPULATION AND ORDER CONTINUING INITIAL CASE MANAGEMENT CONFERENCE
AND EXTENDING ADR DEADLINE

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AGREE that the Court should extend the deadline for completion of the private ADR to which

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the Court ordered this matter until a date no earlier than sixty (60) days from the continued date

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of the Case Management Conference.

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Dated: December 12, 2012

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By: ____________/s/____________________
John F. Hyland (State Bar No. 178875)
[e-mail]
Rosha Jones (State Bar No.279143)
[e-mail]

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RUKIN HYLAND DORIA & TINDALL LLP

Dated: December 12, 2012

MORGAN, LEWIS & BOCKIUS LLP

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By:____________/s/____________________
L. Julius M. Turman (State Bar No. 226126)
[e-mail]
Shannon Nakabayashi (State Bar No. 215469)
[e-mail]

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STIPULATION AND ORDER CONTINUING INITIAL CASE MANAGEMENT CONFERENCE
AND EXTENDING ADR DEADLINE

ORDER

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The Court, having considered the Stipulation of the parties and having concluded that the

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constitutes good cause for the continuance of the Initial Case Management Conference and

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extension of the deadline by which the parties must complete private ADR, hereby continues the

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March 22
Conference until ______________, 2013. The Parties shall submit a Joint Report no later than

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seven (7) days prior to the Conference. The Parties shall complete private ADR no later than

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sixty (60) days from the date of the Conference.

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IT IS SO ORDERED.

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Dated: December 13 2012
__,

___________________________________________
The Honorable Maxine M. Chesney
Judge of the United States District Court
Northern District of California

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STIPULATION AND ORDER CONTINUING INITIAL CASE MANAGEMENT CONFERENCE
AND EXTENDING ADR DEADLINE