Verdina v. CVS Caremark Corporation et al

Filing 37


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1 2 3 4 5 MICHAEL E. BREWER, Bar No. 177912 JOHANNA R. CARNEY, Bar No. 277946 LITTLER MENDELSON, P.C. Treat Towers 1255 Treat Boulevard, Suite 600 Walnut Creek, California 94597 Telephone: 925.932.2468 Facsimile: 925.946.9809 6 7 8 Attorneys for Defendants CVS CAREMARK CORPORATION, CVS RX SERVICES, INC., AMRITPAL VIRDEE, and RUI CAMACHO 12 ARTHUR C. CHAMBERS, Bar No. 53282 JOONG Y. IM, Bar No. 163720 ILONA BRUSIL, Bar No. 244723 601 Van Ness Ave., Suite 2056 San Francisco, CA 94102 Telephone: 415.775.2144 Facsimile: 415.775.1308 13 Attorneys for Plaintiff ROBERT VERDINA 9 10 11 14 15 UNITED STATES DISTRICT COURT 16 NORTHERN DISTRICT OF CALIFORNIA 17 18 19 20 21 22 23 24 25 Case No. 3: 13-cv-04359-MMC ROBERT VERDINA, Plaintiff, v. CVS CAREMARK CORPORATION, a Delaware Corporation; CVS RX SERVICES, INC., a New York Corporation; AMRIT VIRDEE, an individual; RUI CAMACHO, an individual, and DOES 1 through 120, JOINT STIPULATED REQUEST AND [PROPOSED] ORDER TO EXTEND DEADLINE FOR MANDATORY SETTLEMENT CONFERENCE Judge: Ron. Maxine M. Chesney Dept Courtroom 7, 19th Floor Trial Date: December 8, 2014 Defendant. 26 27 Plaintiff, Robert Verdina ("Plaintiff'), and Defendants CVS CAREMARK CORPORATION, CVS RX SERVICES, AMRIT VIRDEE, and RUI CAMACHO ("Defendants"), 28 UITLER MENDELSON. PC. Treat Towers 1255 Treat Boulevard Suito600 W-1 C<eok, CA 9<1597 925.932.24ll8 JOINT STIPULATED REQUEST AND [PROPOSED] ORDER TO EXTEND DEADLINE (NO. 3:13-CV-04359-MMC) 1 file this Joint Stipulated Request to extend the date for Mandatory Settlement Conference from May 2 29, 2014 to July 10, 2014, or as soon thereafter as the court be available. As grounds for this 3 Motion, the Parties state: 4 5 1. Littler Mendelson, P.C. began representing CVS in this manner on February 14, 2014. 2. The two named individual defendants, Rui Camacho and Amritpa1 Virdee, made their first 6 appearance in this case on May 6, 2014. 7 8 9 3. Pursuant to the January 10, 2014 Ci'vil Pretrial Minutes, the case was "referred to Magistrate Judge Nathaneal Cousins for a Settlement Conference, to be conducted in late in late May or 10 early June - his calendar permitting." 11 Setting Settlement Conference, the date set for the Mandatory Settlement Conference is 12 currently May 29, 2014. 13 Pursuant to the Court's January 14, 2014 Order 4. Counsel for the parties agree that settlement discussions would be premature and very likely 14 unsuccessful prior to the deposition of all named parties. 15 16 5. Plaintiff and CVS have engaged in good faith discovery efforts and have completed one 17 round of written discovery. The Parties require additional time to conduct depositions of one 18 of the named individual defendants and the plaintiff. 19 20 21 6. The Parties anticipate that they will not be able to complete the pending depositions by the current settlement conference date because of the challenges associated with, and additional time needed for, coordinating the deposition of one named defendant among counsel and the 22 witness' schedules prior to May 29, 2014. 23 24 7. The Parties have met and conferred and agree that they would be available on July 10, 2014 25 to conduct the Mandatory Settlement Conference. The Parties have checked with Magistrate 26 Judge Cousins' clerk and are of the infonnation and belief that this date is agreeable to 27 Magistrate Judge Cousins as well. 28 LITILER MENOaSON, P.C. Treat Towers 1255 Treat Boulevatd Suite600 Walnut Creek, CA 945.q7 925 932.2468 JOINT STIPULATED REQUEST AND [PROPOSED] ORDER TO EXTEND DEADUNES (NO. 3:13-CV-04359-MMC) 2. 8. Accordingly, the Parties respectfully request that the Court reschedule the Mandatory 2 Settlement Conference from May 29,2014 to July 10, 2014, or as soon thereafter as is 3 4 practicable. 9. Neither Party will be prejudiced by the extension of this date. Both Parties will, however, be 5 prejudiced if the Court denies this Motion and prevents them from conducting the pending 6 7 8 9 10 depositions to develop the factual record in this case. WHEREFORE, the Parties respectfully request that the Court extend the current deadline to conduct a settlement conference as set forth above. Respectfully submitted, 11 12 Dated: Mayj2,..2014 13 14 15 16 17 Attorneys for Plaintiff Robert Verdina Dated: Mayf2.,2014 18 I J ANNA R. CARNEY ITTLER MENDELSON A Professional Corporation Attomeys for Respondents CVS CAREMARK CORPORATION CVS RX SERVICES, INC. 19 20 21 22 23 IT IS SO ORDERED. 24 25 Dated: _ _20 _, 2014 May _ 26 HONORABLE MAXINE M. CHESNEY U.S. DISTRICT COURT JUDGE 27 28 UHLER MENDELSON. P.C r..atrowers 1255 Treat Boulevard SuiteOOO Creek, CA 94597 925.932.2<08 JOINT STIPULATED REQUEST AND [PROPOSED] ORDER TO EXTEND DEADLINES (NO.3: 13-CV-04359-MMC) 3.

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