Nieves v. County of San Mateo

Filing 16

Order by Hon. Vince Chhabria granting 15 Stipulation for Request for Order Continuing Initial Case Management Conference.(knm, COURT STAFF) (Filed on 3/2/2015)

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JOHN C. BEIERS, COUNTY COUNSEL (SBN 144282)
By: Daniel J. Valim, Deputy (SBN 233061)
Hall of Justice and Records
400 County Center, 6th Floor
Redwood City, CA 94063
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]

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Attorneys for Defendant
COUNTY OF SAN MATEO

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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NANCY NIEVES,
Plaintiff,

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vs.

Case No. CV 14-05160 VC
JOINT STIPULATION FOR REQUEST
FOR ORDER CONTINUING INITIAL
CASE MANAGEMENT CONFERENCE
AND PROPOSED ORDER

COUNTY OF SAN MATEO, ET AL.,
Defendant

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The parties in this matter, Plaintiff Nancy Nieves and Defendant County of San Mateo, hereby

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submit this Joint Stipulated Request for Order Continuing Initial Case Management Conference,

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currently scheduled for March 10, 2015. The parties request a new date for the Initial Case Management

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Conference approximately 90 days out from the current date of March 10, 2015 for the following

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reasons:

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1.

The parties are currently discussing settlement and exchanging informal discovery;

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2.

Because this is an action under the Fair Labor Standards Act Plaintiff has requested

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attorneys’ fees if she prevails on the merits of the case. In order to facilitate more effective settlement

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discussions, the parties seek to avoid incurring unnecessary attorneys’ fees at this time;

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3.

The parties seek to serve the interests of judicial economy and eliminate any unnecessary

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burdens on the parties by postponing the Initial Case Management Conference and all deadlines that

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accompany it such as the filing of a Joint Initial Case Management Statement until after the parties

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conclude their initial settlement discussions. The Initial Case Management Statement is currently due on
Case No. CV 14-05160 VC
-1JOINT STIPULATION FOR REQUEST FOR ORDER CONTINUING INITIAL CASE MANAGEMENT
CONFERENCE AND PROPOSED ORDER

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March 3, 2015 but would be continued along with the Conference.
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A continuance of 90 days will provide the parties with sufficient time to exchange formal

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discovery and, if a settlement is reached, negotiate its terms and seek any necessary approval from

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Defendant’s governing body.

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Dated: February 26, 2015.

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Respectfully submitted,
JOHN C. BEIERS, COUNTY COUNSEL

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By: _____________/s/_____________________
Daniel J. Valim, Deputy
Attorneys for Defendant
COUNTY OF SAN MATEO

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Dated: February 26, 2015.

JASON M. ELRICH,
MCCORMACK & ELRICH, LLP

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By:_____________/s/_____________________
Jason M. Erlich, Esq.
Attorneys for Plaintiff
NANCY NIEVES

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GOOD CAUSE APPEARING, AND PURSUANT TO STIPULATION, IT IS SO
ORDERED:

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The Court hereby grants the stipulated request of the parties and sets a new date for the Initial

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June 9, 2015, at 10:00 a.m
Case Management Conference of ___________________________. All deadlines accompanying the

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Initial Case Management Conference, such as the Initial Case Management Statement are continued to

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the corresponding date as defined by statute.

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Dated: March 2, 2015
HONORABLE VINCE CHHABRIA

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Case No. CV 14-05160 VC
-2JOINT STIPULATION FOR REQUEST FOR ORDER CONTINUING INITIAL CASE MANAGEMENT
CONFERENCE AND PROPOSED ORDER