Jakosalem v. Air Serv Corporation

Filing 27

ORDER, Motions terminated: 26 STIPULATION WITH PROPOSED ORDER CONTINUING DEADLINES TO ALLOW FOR MEDIATION filed by Air Serv Corporation. Motion Hearing (Motion to Certify Class) set for 2/13/2015 09:00 AM in Courtroom 10, 19th Floor, San Francisco before Hon. Susan Illston.. Signed by Judge Susan Illston on 10/27/14. (tfS, COURT STAFF) (Filed on 10/28/2014)

1
2
3
4
5
6
7
8
9
10
11

KEITH A. JACOBY, Bar No. 150233
[e-mail]
LITTLER MENDELSON, P.C.
2049 Century Park East, 5th Floor
Los Angeles, California 90067.3107
Telephone: [phone]
Facsimile:
310.553.5583
MICHELLE B. HEVERLY, Bar No. 178660
[e-mail]
MAIKO NAKARAI-KANIVAS, Bar No. 271710
[e-mail]
LITTLER MENDELSON, P.C.
650 California Street, 20th Floor
San Francisco, California 94108.2693
Telephone: [phone]
Facsimile:
415.399.8490
Attorneys for Defendant
AIR SERV CORPORATION (erroneously sued as
“AIR SERV CORP.”)

12

UNITED STATES DISTRICT COURT

13

NORTHERN DISTRICT OF CALIFORNIA

14

SAN FRANCISCO DIVISION

15
16
17
18
19
20
21

MARIO JAKOSALEM, on behalf of
himself, and on behalf of others similarly
situated, and the general public,
Plaintiff,
v.

Case No. 3:13-cv-05944-SI
STIPULATION AND [PROPOSED]
ORDER CONTINUING DEADLINES TO
ALLOW FOR MEDIATION
Complaint Filed: October 28, 2013

AIR SERV CORP., and DOES 1 through
50,
Defendants.

22
23
24

IT IS HEREBY STIPULATED by and between Plaintiff MARIO JAKOSALEM

25

(“Plaintiff”) and Defendant AIR SERV CORPORATION (“Defendant”) (collectively the “Parties”),

26

by and through their attorneys of record:
WHEREAS, on August 8, 2014 this Court held an initial Case Management

27
28
LITTLER MENDELSON, P.C.
2049 Century Park East
5th Floor
Los Angeles, CA 90067.3107
310.553.0308

Conference;
STIPULATION AND ORDER CONTINUING
DEADLINES

Case No. 3:13-cv-05944-SI

1
2

WHEREAS, at the initial Case Management Conference, the following dates were set
by the Court:

3

•

4

Certification;

5

•

6

January 12, 2015 - Deadline for Defendant to file Opposition to Plaintiff’s
Motion for Class Certification;

7

•

8

January 26, 2015 - Deadline for Plaintiff to file a reply memorandum in
support of Motion for Class Certification; and

9

•

10
11

December 8, 2014 - Deadline for Plaintiff to file Motion for Class

February 13, 2015 at 9:00 a.m. - Hearing on Motion for Class Certification.

WHEREAS, the Parties have agreed to attend a mediation before Mark Rudy on
January 23, 2015 at 9:00 a.m. This was Mr. Rudy’s first available date for mediation.

12

WHEREAS, in light of the timing of the mediation, the Parties agree that conducting

13

significant formal discovery and briefing the motion for class certification would be counter-

14

productive and would not encourage resolution of the matter. Accordingly, the Parties have agreed

15

to continue the relevant deadlines subject to Court approval. The parties have exchanged documents

16

and other information and will take any necessary depositions before the January 23, 2015 mediation

17

date.

18
19
20
21
22

NOW THEREFORE, IT IS HEREBY STIPULATED by and among the undersigned
Parties, through their counsel of record, as follows:
1.

All currently scheduled dates, including the date for hearing on Plaintiff’s

motion for class certification, are vacated pending the Parties January 2015 mediation.
2.

The Parties (Plaintiff or Defendant individually or the Parties jointly) will

23

notify the Court within three days of reaching impasse so that new dates for class certification and

24

trial (and all related dates) can be set. If the case does not resolve, the Parties anticipate being ready

25

for certification by July 2015.

26

3.

This Stipulation may be signed in counterparts.

27
28
LITTLER MENDELSON, P.C.
2049 Century Park East
5th Floor
Los Angeles, CA 90067.3107
310.553.0308

STIPULATION AND ORDER CONTINUING
DEADLINES

2.

Case No. 3:13-cv-05944-SI

1
2
3

LIBERATION LAW GROUP, PC
DATED: October 23, 2014

By: /s/ Arlo Uriate Garcia
Arlo Uriarte Garcia
Attorney for Plaintiffs

4
5
6

LITTLER MENDELSON, P.C.

7
8

DATED: October 23, 2014

By: /s/ Michelle B. Heverly
Keith A. Jacoby
Michelle B. Heverly
Attorneys for Defendant

9
10
11
12

[PROPOSED] O R D E R

13
It is so ordered.

14
15

27
DATED: ___October _____, 2014

___________________________

16

Honorable Susan Illston

17
18

________

19
20
21
22
23
24
25
26
27
28
LITTLER MENDELSON, P.C.
2049 Century Park East
5th Floor
Los Angeles, CA 90067.3107
310.553.0308

STIPULATION AND ORDER CONTINUING
DEADLINES

3.

Case No. 3:13-cv-05944-SI