Cardenas v. Concentra Health Services, Inc.

Filing 40

STIPULATION AND ORDER re 39 STIPULATION WITH PROPOSED ORDER STIPULATION AND [PROPOSED] ORDER CONTINUING SETTLEMENT COMPLIANCE HEARING filed by Concentra Health Services, Inc. Settlement Compliance Hearing set for 5/28/2014 at 2:00 PM in Courtroom 9, 19th Floor, San Francisco before Hon. Jon S. Tigar. Signed by Judge Jon S. Tigar on May 13, 2014. (wsn, COURT STAFF) (Filed on 5/13/2014)

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CHARLES L. THOMPSON, IV, State Bar No. 139927
[e-mail]
BECKI D. GRAHAM, State Bar No. 238010
[e-mail]
OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.
Steuart Tower, Suite 1300
One Market Plaza
San Francisco, CA 94105
Telephone:
415.442.4810
Facsimile:
415.442.4870
Attorneys for Defendant
CONCENTRA HEALTH SERVICES, INC.
Claudia Center, State Bar No. 158255
Jinny Kim, State Bar No. 208953
Rachael Langston, State Bar No. 257950
Gina Gemello, State Bar No. 282964
The LEGAL AID SOCIETY –
EMPLOYMENT LAW CENTER
180 Montgomery Street, Suite 600
San Francisco, CA 94104
Telephone:
[phone]
Facsimile:
[phone]
Emails:
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Plaintiff
PATRICIA CARDENAS

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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PATRICIA CARDENAS,
Plaintiff,

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v.

Case No. 3:13-cv-01299 JST
STIPULATION AND [PROPOSED] ORDER
CONTINUING SETTLEMENT
COMPLIANCE HEARING

CONCENTRA HEALTH SERVICES, INC.,
Defendant.

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Case No. 3:13-cv-01299 JST
STIPULATION AND [PROPOSED] ORDER CONTINUING SETTLEMENT COMPLIANCE HEARING

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WHEREAS, on February 28, 2014, the Court issued an Order to File Stipulation of

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Dismissal in which it additionally ordered a Settlement Compliance Hearing on April 30, 2014

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(Docket No. 35);

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WHEREAS, on April 14, 2014, Plaintiff Patricia Cardenas and Defendant Concentra Health

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Services, Inc. submitted a Joint Case Management Statement in which they reported that the Parties

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had resolved the matter at mediation and were finalizing the settlement agreement (Docket No. 36);

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WHEREAS, the Court thereafter continued the previously set April 30, 2014 Settlement
Compliance Hearing to May 7, 2014 (Docket No. 37);

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WHEREAS, the Court thereafter continued the p Settlement Compliance Hearing to May
14, 2014 (Docket No. 38);

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WHEREAS, the parties have executed a settlement agreement, which preconditions

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Plaintiff’s filing of a dismissal on Defendant fulfilling certain obligations under the settlement

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agreement;

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WHEREAS, Defendant anticipates that on or about Wednesday, May 13, 2014, it will have

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fulfilled its obligations under the settlement agreement that precondition Plaintiff’s filing of a

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dismissal;

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WHEREAS, Plaintiff anticipates filing a dismissal of this action on or before May 20,
2014;

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THEREFORE, the parties request that the Settlement Compliance Hearing be continued to

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a date on or after May 20, 2014.

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IT IS SO STIPULATED.

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Case No. 3:13-cv-01299 JST
STIPULATION AND [PROPOSED] ORDER CONTINUING SETTLEMENT COMPLIANCE HEARING

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DATED: May 13, 2014
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OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.

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By: /s/Becki Graham
Charles L. Thompson, IV
Becki D. Graham
Attorneys for Defendant
CONCENTRA HEALTH SERVICES, INC.

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DATED: May 13, 2014

THE LEGAL AID SOCIETY – EMPLOYMENT
LAW CENTER

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By: /s/ Gina Gemello
Claudia Center
Jinny Kim
Rachael Langston
Gina Gemello

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Attorneys for Plaintiff
PATRICIA CARDENAS

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ECF CERTIFICATION

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Pursuant to General Order No. 45 X(B), I attest that concurrence in the filing of this

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document has been obtained from Plaintiff’s counsel.

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DATED: May 14, 2014

OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.

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By: /s/ Becki Graham
Charles L. Thompson, IV
Becki D. Graham
Attorneys for Defendant
CONCENTRA HEALTH SERVICES, INC.

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Case No. 3:13-cv-01299 JST
STIPULATION AND [PROPOSED] ORDER CONTINUING SETTLEMENT COMPLIANCE HEARING

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The Settlement Compliance Hearing for May 13, 2014, shall be continued to
May 28
________________, 2014.

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S
Dated: May ___, 2014
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By:

UNIT
ED

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RT
U
O

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S DISTRICT
TE
C
TA

ED

The HonorableRDERTigar
O O Jon S.
IT IS S
United States District Judge

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ER

Ti ga r

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n S.
J u d ge J o

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RT

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NO

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R NIA

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Good cause appearing, IT IS SO ORDERED.

FO

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ORDER

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D IS T IC T
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OF

C

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Case No. 3:13-cv-01299 JST
STIPULATION AND [PROPOSED] ORDER CONTINUING SETTLEMENT COMPLIANCE HEARING