Rubio-Delgado v. Aerotek, Inc.
Filing
39
STIPULATION AND ORDER Regarding Discovery and Joint Status Report. Signed by Judge Samuel Conti on 08/04/2014. (tmi, COURT STAFF) (Filed on 8/5/2014)
1
SEE COUNSEL LIST ON NEXT PAGE
2
3
4
5
6
7
8
UNITED STATES DISTRICT COURT
9
NORTHERN DISTRICT OF CALIFORNIA
10
SAN FRANCISCO DIVISION
11
12
13
14
JOSE RUBIO-DELGADO, individually,
on behalf of other similarly situated
individuals, and on behalf of the general
public,
17
18
JOINT STATUS REPORT AND
STIPULATION REGARDING DISCOVERY
Plaintiff,
15
16
Case No. 13-CV-3105-SC
v.
AEROTEK, INC.,
Defendant.
19
20
21
22
23
24
25
26
27
28
JOINT STATUS REPORT/STIPULATION
AND ORDER
Case No. 13-cv-3105-SC
1
2
3
4
5
6
7
ROD M. FLIEGEL, Bar No. 168289
rfliegel@littler.com
ALISON S. HIGHTOWER, Bar No. 112429
ahightower@littler.com
ROXANNA IRAN, Bar No. 273625
riran@littler.com
LITTLER MENDELSON, P.C.
650 California Street, 20th Floor
San Francisco, California 94108.2693
Telephone:
415.433.1940
Facsimile:
415.399.8490
Attorneys for Defendant
AEROTEK, INC.
8
THE LAW OFFICES OF DEVIN H. FOK
Devin H. Fok (SBN #256599)
devin@devinfoklaw.com
P.O. Box 7165
Alhambra, CA 91802-7165
Phone:
(310) 430-9933
Fax:
(323) 563-3445
A NEW WAY OF LIFE REENTRY
PROJECT
Ely Grinvald (SBN #285475)
egrinvald@anewwayoflife.org
958 E 108th Street
Los Angeles, CA 90059
Phone:
(323) 563-3575
Fax:
(323) 563-3445
9
NICHOLS KASTER, PLLP
Rebekah L. Bailey, CA Bar No. 258551
bailey@nka.com
E. Michelle Drake, MN Bar No. 0387366*
drake@nka.com
Anna P. Prakash, MN Bar No. 0351362*
aprakash@nka.com
4600 IDS Center
80 South 8th Street
Minneapolis, MN 55402
Phone:
(612) 256-3200
Fax:
(612) 338-4878
*admitted pro hac vice
10
11
12
13
14
15
16
Attorneys for Individual and Representative
Plaintiff
JOSE RUBIO-DELGADO
17
18
19
20
21
22
23
24
25
26
27
28
JOINT STATUS REPORT/STIPULATION
AND ORDER
Case No. 13-cv-3105-SC
1
Plaintiff JOSE RUBIO-DELGADO and Defendant AEROTEK, INC. (collectively, the
2
“Parties”), by and through their respective attorneys of record, hereby submit the following status
3
report and pre-mediation discovery plan.
4
5
1.
reach a settlement.
6
7
2.
WHEREAS, the Parties have agreed to continue settlement discussions and have
scheduled a mediation for September 16, 2014.
8
9
WHEREAS, the Parties attended mediation in this case on June 18, 2014, but did not
3.
WHEREAS, pursuant to this Court’s Order of July 25, 2014, the Parties are to submit
a Joint Status Report and Discovery Plan today.
10
4.
WHEREAS, the Parties have held additional “meet and confer” discussions, resulting
11
in an agreement to engage in certain formal discovery prior to their September 16 mediation that
12
both sides believe will enhance the likelihood of a settlement being reached, without expending
13
resources on discovery that can be deferred until after the mediation.
14
5.
WHEREAS, the Parties have agreed that, prior to the September 16 mediation,
15
Plaintiff will respond to certain document requests and Defendant will respond to certain requests for
16
admission, interrogatories, and document requests.
17
6.
WHEREAS, the Parties have agreed that the responses to the agreed upon discovery
18
referenced in Paragraph 5 above shall be due on August 15, 2014, and that responses to all other
19
written discovery that has been served in this case shall not be due until 30 days following the
20
September 16 mediation, absent further agreement or court order. All objections and rights with
21
regard to such discovery are preserved.
22
7.
WHEREAS, the Parties have agreed that, within seven (7) days of the September 16
23
mediation, they will provide the Court with either notice that they have settled or an updated Joint
24
Status Report and Discovery Plan for the remainder of the case.
25
WHEREFORE, the Parties jointly request that the instant Stipulation be granted, that
26
discovery continue as outlined above, and that the Court set September 23, 2014 as the deadline for
27
///
28
JOINT STATUS REPORT/STIPULATION
AND ORDER
1.
Case No. 13-cv-3105-SC
1
the parties to either inform the Court that they have settled or file an updated Joint Status Report and
2
Discovery Plan for the remainder of the case.
3
4
IT IS SO STIPULATED:
Dated: August 1, 2014
5
6
/s/ E. Michelle Drake
E. Michelle Drake
ANNA P. PRAKASH
NICHOLS KASTER, PLLP
Attorneys for Plaintiff
JOSE RUBIO-DELGADO
7
8
9
10
Dated: August 1, 2014
11
/s/ Rod M. Fliegel
ROD M. FLIEGEL
ALISON S. HIGHTOWER
ROXANNA IRAN
LITTLER MENDELSON, P.C.
Attorneys for Defendant
AEROTEK, INC.
12
13
14
15
16
17
[PROPOSED] ORDER
18
The Court grants the parties’ Joint Status Report and Stipulation Regarding
19
Discovery, and orders that, on September 23, 2014, the Parties either file a notice informing the
20
Court that they have settled or file an updated Joint Status Report and Discovery Plan.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
22
S
UNIT
ED
NO
Firmwide:128241654.1 071691.1029
onti
amuel C
Judge S
H
ER
LI
RT
27
28
JOINT STATUS REPORT/STIPULATION
AND ORDER
2.
FO
25
R NIA
____________________________________
THE HONORABLE SAMUEL CONTI
JUDGE OF THE UNITED STATES
DISTRICT COURT
24
26
S DISTRICT
TE
C
TA
RT
U
O
23
08/04
DATED: _________________, 2014
A
21
N
F
D IS T IC T O
R
C
Case No. 13-cv-3105-SC
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?