Reardon et al v. Uber Technologies, Inc.

Filing 58

STIPULATION AND ORDER re 57 STIPULATION and Proposed Order selecting Private ADR by Justin Bartolet, Jonathan Grindell, James Lathrop, Julie McKinney, Sandeep Pal, Jennifer Reilly. Signed by Judge Jon S. Tigar on September 2, 2015. (wsn, COURT STAFF) (Filed on 9/2/2015)

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Hassan A. Zavareei (SBN 181547)
[e-mail]
TYCKO AND ZAVAREEI, LLP
2000 L Street, N.W., Suite 808
Washington, DC 20036
Tel.: [phone]
Fax: [phone]
Attorney for Plaintiffs James Lathrop, Julie
McKinney, Jonathan Grindell, Sandeep Pal,
Jennifer Reilly, and Justin Bartolet
LOCKE LORD LLP
Susan J. Welde (SBN: 205401)
[e-mail]
300 South Grand Avenue, Suite 2600
Los Angeles, California 90071
Telephone: [phone]
Facsimile: [phone]
LOCKE LORD LLP
Martin Jaszczuk (Pro Hac Vice)
[e-mail]
Nick J. Di Giovanni (Pro Hac Vice)
[e-mail]
111 S. Wacker Drive
Chicago, Illinois 60606
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant Uber Technologies,
Inc.
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

JAMES LATHROP, JULIE MCKINNEY,
21 JONATHAN GRINDELL, SANDEEP PAL,
JENNIFER REILLY, and JUSTIN BARTOLET
22 on behalf of themselves and all others similarly
situated,
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Plaintiffs,
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vs.
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UBER TECHNOLOGIES, INC.,
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Defendant.
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Civil Action No.: 14-cv-05678-JST
Honorable Jon S. Tigar
STIPULATION TO PARTICIPATE IN
PRIVATE MEDIATION PROCESS

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STIPULATION TO PARTICIPATE IN PRIVATE MEDIATION PROCESS

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Plaintiffs JAMES LATHROP, JULIE MCKINNEY, JONATHAN GRINDELL, SANDEEP
PAL, JENNIFER REILLY, and JUSTIN BARTOLET and Defendant UBER TECHNOLOGIES,
INC. (collectively, “the Parties”) hereby submit, through the undersigned counsel of record, the
following Stipulation to Participate in Private Mediation Process. In support of this stipulation, the
Parties state as follows:
1.

Plaintiffs filed their initial Complaint on December 31, 2014.

2.

On March 13, 2015, the parties filed their Stipulation and Proposed Order Selecting

ADR Process. See Docket No. 30. In that Stipulation, the parties agreed to participate in mediation
using the Court’s process by November 30, 2015.
3.

On April 29, 2015, the parties timely filed their Joint Case Management Statement.

See Docket No. 37. In that Joint Case Management Statement, the parties agreed to conduct
mediation by February 16, 2016.
4.

On July 19, 2015, the Court granted in part and dismissed in part Defendant’s partial

Motion to Dismiss. See Docket No. 49.
5.

The parties have had further meet and confer discussions concerning mediation and

have agreed that a private mediation is preferable to the Court process. Pending the Court’s
approval, the parties have agreed to conduct a private mediation with a mediator agreeable to both
parties. The parties do not currently have a private mediation scheduled, but will schedule such a
mediation when they believe that it will be productive.
IT IS THEREFORE STIPULATED AND AGREED by the Parties, through the
undersigned, as follows:
1.

Provided that the Court approves, the Parties agree to participate in private mediation

with a mediator to be jointly approved by the parties.
2.

The Parties agree that the case should be removed from the Court’s mediation

program.
IT IS SO STIPULATED.

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STIPULATION TO PARTICIPATE IN PRIVATE MEDIATION PROCESS

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2 DATED: September 2, 2015

TYCKO AND ZAVAREEI, LLP

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By

/s/ Hassan A. Zavareei
Hassan A. Zavareei

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Attorneys for Plaintiffs
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6 DATED: September 2, 2015

LOCKE LORD LLP

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By

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/s/ Martin W. Jaszczuk
Martin W. Jaszczuk

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Attorneys for Defendant

PURSUANT TO STIPULATION, IT IS SO ORDERED.

NO

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J u d ge J o

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n S. T

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__________________________________
The Honorable Jon S. Tigar
UNITED STATES DISTRICT JUDGE
i ga r

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September 2, 2015
14 DATED: ______________

D

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IT IS S

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UNIT
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S DISTRICT
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R NIA

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STIPULATION TO PARTICIPATE IN PRIVATE MEDIATION PROCESS

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FILER’S ATTESTATION
Pursuant to General Order No. 45, Section X, Subparagraph B, the undersigned attests that
all parties have concurred in the filing of this Stipulation.

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5 DATED: September 2, 2015

TYCKO AND ZAVAREEI, LLP

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By

/s/ Hassan A. Zavareei
Hassan A. Zavareei

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Attorney for Plaintiffs
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FILER’S ATTESTATION