Mitchell v. McCormick & Schmick Restaurant Corp. et al

Filing 26

STIPULATION AND ORDER CONTINUING DEADLINE FOR COMPLETION OF MEDIATION. Signed by Judge Richard Seeborg on 4/1/15. (cl, COURT STAFF) (Filed on 4/1/2015)

1 Janine S. Simerly (SBN 102361)
[e-mail]
2 MILLER LAW GROUP
A Professional Corporation
3
111 Sutter Street, Suite 700
4 San Francisco, CA 94104
Tel. [phone]
5 Fax [phone]

M ILLER L AW G ROUP

A P R OF E SS I ON AL C O RP OR A T IO N
C AL IF O RN I A

6 Attorneys for Defendants
7 McCORMICK & SCHMICK RESTAURANT CORP.;
McCORMICK & SCHMICK’S SEAFOOD
8 RESTAURANTS, INC.; and LANDRY’S, INC.
9 Arlo Garcia Uriarte (SBN 231764)
Un Kei Wu(SBN 270058)
10 Ernesto Sanchez(SBN 278006)
Brent A. Robinson (SBN 289373)
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LIBERATION LAW GROUP, P.C.
12 2760 Mission Street
San Francisco, CA 94110
13 Tel: [phone]
Fax: [phone]
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Attorneys for Plaintiff
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MAUDELLE MITCHELL
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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19 Maudelle Mitchell,

Case No.: C 14-04974 RS

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Plaintiff,

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v.

STIPULATION AND [PROPOSED] ORDER
CONTINUING DEADLINE FOR
COMPLETION OF MEDIATION

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McCormick & Schmick’s Seafood
24 Restaurants, Inc., Landry’s Inc., and DOES 125,
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Complaint filed: August 29, 2014
Trial Date: January 19, 2016

Defendants.

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STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINE FOR COMPLETION OF MEDIATION
Case No.: C 14-04974 RS

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Plaintiff MAUDELLE MITCHELL (“Plaintiff”) and Defendants McCORMICK &

2 SCHMICK

RESTAURANT

CORP.,

McCORMICK

&

SCHMICK’S

SEAFOOD,

3 RESTAURANTS, INC., and LANDRY’S, INC. (“Defendants”), by and through their
4 respective undersigned attorneys, hereby stipulate and agree to continue the deadlines for
5 the parties to complete mediation in this matter.
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WHEREAS, on November 10, 2014, Defendant removed this matter to this

8 Court from the Alameda Superior Court based on Diversity Jurisdiction;
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WHEREAS, on February 19, 2015, the parties attended an Initial Case

11 Management Conference;

M ILLER L AW G ROUP

A P R OF E SS I ON AL C O RP OR A T IO N
C AL IF O RN I A

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WHEREAS, on February 19, 2015, the Court issued a Case Management

14 Order setting the last day for the parties to hold mediation of this matter on June 19, 2015;
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WHEREAS, on March 16, 2015, the Court filed a Notice of Appointment of

17 Mediator of JoAnne Dellaverson;
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WHEREAS, Ms. Dellaverson is on vacation and unavailable for most of the

20 month of June;
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WHEREAS counsel for the parties have conferred and all parties have agreed

23 to have the mediation on July 23, 2015;
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WHEREAS, trial of this matter is not scheduled until January 19, 2016, and the

26 July 20 mediation date will have no impact on the trial date or any other pre-trial dates;
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STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINE FOR COMPLETION OF MEDIATION
Case No.: C 14-04974 RS

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NOW, THEREFORE,

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IT IS HEREBY STIPULATED AND AGREED by and between Plaintiffs and

4 Defendant, by and through their respective undersigned attorneys of record, to continue the
5 last date to complete mediation from June 19, 2015 to July 31, 2015.
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Good cause exists for this continuance of the existing date of the Court’s
Order for the reasons set forth above.

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IT IS SO STIPULATED.

M ILLER L AW G ROUP

A P R OF E SS I ON AL C O RP OR A T IO N
C AL IF O RN I A

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Dated: March 31, 2015

LIBERATION LAW GROUP

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By:

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/s/ Arlo Garcia Uriarte
Arlo Garcia Uriarte
Un Kei Wu
Ernesto Sanchez
Brent A. Robinson
Attorneys for Plaintiffs
MAUDELLE MITCHELL

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21 Dated: March 31, 2015

MILLER LAW GROUP
A Professional Corporation

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By:

/s/ Janine S. Simerly
Janine S. Simerly
Attorneys for Defendants
McCORMICK & SCHMICK RESTAURANT
CORP.; McCORMICK & SCHMICK’S
SEAFOOD RESTAURANTS, INC.; and
LANDRY’S, INC.

STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINE FOR COMPLETION OF MEDIATION
Case No.: C 14-04974 RS

1

[PROPOSED] ORDER

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Having reviewed the Stipulation executed by Plaintiff MAUDELLE MITCHELL

4 and Defendants McCORMICK & SCHMICK RESTAURANT CORP., McCORMICK &
5 SCHMICK’S SEAFOOD, RESTAURANTS, INC., and LANDRY’S, INC., and good cause
6 appearing, the Court hereby orders that:
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The deadline for the parties to complete the mediation of this matter

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through the Northern District ADR program is hereby continued from

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June 19, 2015 to July 31, 2015.

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

M ILLER L AW G ROUP

A P R OF E SS I ON AL C O RP OR A T IO N
C AL IF O RN I A

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4/1/15
13 Dated: ______________________
14

______________________________
Hon. Richard Seeborg
District Judge

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4849-6390-0706, v. 1

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STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINE FOR COMPLETION OF MEDIATION
Case No.: C 14-04974 RS