Hochstetler et al v. Pacific Gateway Concessions LLC

Filing 29

STIPULATION AND ORDER Continuing Case Management Conference. Case Management Statement due by 6/8/2015. Initial Case Management Conference set for 6/15/2015 01:30 PM in Courtroom 12, 19th Floor, San Francisco. Signed by Judge Thelton E. Henderson on 04/06/2015. (tmi, COURT STAFF) (Filed on 4/7/2015)

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MARA E. ROSALES, State Bar No. 104844
[e-mail]
ROBERT D. SANFORD, State Bar No.129790
[e-mail]
ROSALES LAW PARTNERS LLP
433 California Street, Suite 630
San Francisco, CA 94104
Telephone:
[phone]
Attorneys for Defendant
PACIFIC GATEWAY CONCESSIONS LLC.

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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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)
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)
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Plaintiffs,
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vs.
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PACIFIC GATEWAY CONCESSIONS LLC, et )
al.,
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Defendants.
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_______________________________________ )
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PACIFIC GATEWAY CONCESSIONS LLC, et )
al.,
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Cross-Claimant,
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vs.
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POINT SOLUTIONS, LLC,
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Cross-Defendant. )
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)
RACHEL HOCHSTETLER,
CIRENA TORRES,

CASE NO. 3:14-CV-04748-TEH
STIPULATION AND [PROPOSED]
ORDER CONTINUING INITIAL CASE
MANAGEMENT CONFERENCE
Date: April 13, 2015
Time: 1:30 p.m.
Courtroom: 12

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Stipulated Order Continuing CMC

Case No. 3:14-cv-04748-TEH

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STIPULATION

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Plaintiffs Rachel Hochstetler and Cirena Torres, Defendant and Cross-Claimant

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Pacific Gateway Concessions LLC ("PGC"), and Cross-Defendant Point Solutions, LLC

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("PS") hereby stipulate as follows:

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Recitals

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1.

The Initial Case Management Conference in this action was originally

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scheduled for February 2, 2015, per the Clerk's Notice Scheduling Case Management

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Conference on Reassignment (Docket 12), then continued until April 13, 2015 since PS

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had not yet appeared in the action (Docket 24).

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2.

On April 1, 2015, the parties participated in a mediation before court-

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appointed mediator David Bluhm. As a result of the mediation, Plaintiffs and PGC

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reached a tentative settlement of the class action by agreeing to a settlement fund for

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putative class members. Plaintiffs and PGC are presently discussing payment of attorney

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fees and costs to Plaintiffs' counsel if counsel is appointed class counsel and payment of

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an incentive award to the Plaintiffs if they are appointed class representatives. If

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Plaintiffs and PGC are able to reach agreement on all settlement terms, they intend to

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seek preliminary approval of the class settlement from the Court. PGC and PS also

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engaged in settlement negotiations during the mediation, which are still ongoing.

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3.

In the interest of efficient case management and minimizing the burden of

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the action on the Court's resources, the parties agree that the Initial Case Management

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Conference should be continued from April 13, 2015 for 60 days in order to permit

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settlement discussions to conclude.

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Stipulated Order Continuing CMC

Case No. 3:14-cv-04748-TEH

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Stipulation
4.

Based on the foregoing recitals, the parties stipulate that the Initial Case

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Management Conference of April 13, 2015 should be continued for 60 days in order to

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permit settlement discussions to conclude.

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So Stipulated.

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Dated: April 2, 2015

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CHANT & COMPANY,
A Professional Law Corporation
By:

/s/ Chant Yedalian
CHANT YEDALIAN
Attorneys for Plaintiffs
RACHEL HOCHSTETLER and CIRENA
TORRES

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Dated: April 2, 2015

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ROSALES LAW PARTNERS LLP
By:

/s/ Robert D. Sanford
ROBERT D. SANFORD
Attorney for Defendant and Cross-Claimant
PACIFIC GATEWAY CONCESSIONS
LLC

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Dated: April 2, 2015
LLP

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HUDDLESTON & SIPOS LAW GROUP

By:

/s/ Robert A. Huddleston
ROBERT A. HUDDLESTON
Attorney for Cross- Defendant
POINT SOLUTIONS, LLC

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Stipulated Order Continuing CMC

Case No. 3:14-cv-04748-TEH

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ORDER
Pursuant to stipulation, it is so ordered. The Initial Case Management Conference
June 15
shall occur on _________, 2015 at 1:30 pm in Courtroom 12 on the 19th floor, United
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States District Courthouse, 450 Golden Gate Avenue, San Francisco, CA 94102. Not less

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than seven days prior, counsel shall submit a joint case management conference

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statement, and all other deadlines are continued according to the new date of the Initial

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Case Management Conference.

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Dated: April ___, 2015

UNIT
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Judge T

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_________________________________
Honorable Thelton E. Henderson
United States District Court Judge

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Stipulated Order Continuing CMC

Case No. 3:14-cv-04748-TEH