Rulo v. Ricoh Americas Corporation, et al

Filing 37

ORDER by Judge Haywood S. Gilliam, Jr. Granting 36 Stipulation to Extend Deadline to Complete ADR. (ndrS, COURT STAFF) (Filed on 12/1/2015)

1 Michele J. Beilke (SBN 194098)
REED SMITH LLP
2 355 South Grand Avenue, Suite 2900
Los Angeles, CA 90071-1514
3 Telephone: [phone]
Facsimile: [phone]
4 Email: [e-mail]
5 Philip J. Smith (SBN 232462)
REED SMITH LLP
6 101 Second Street, Suite 1800
San Francisco, CA 94105-3659
7 Telephone: [phone]
Facsimile: [phone]
8 Email: [e-mail]

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

9 Attorneys for Defendants
Ricoh Americas Corporation and Ricoh USA,
10 Inc.
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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15 PATRICK RULO,
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Case No. 15-00736 HSG
Plaintiff,

STIPULATION AND ORDER TO EXTEND
DEADLINE TO COMPLETE ADR

vs.

18 RICOH AMERICAS CORPORATION, RICOH
USA, INC., and DOES 1-100,
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Defendant.
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The Honorable Haywood S. Gilliam, Jr.

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US_ACTIVE-123724483.2

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STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINE TO COMPLETE ADR

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Plaintiff Patrick Rulo (“Plaintiff”) and Defendants Ricoh USA, Inc. and Ricoh Americas

2 Corporation (collectively, “Defendants”) (Plaintiff and Defendants will be referred to as the
3 “Parties”), by and through their respective attorneys of record, hereby agree and stipulate to extend
4 their deadline to complete ADR, as follows:
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WHEREAS, on May 4, 2015, the Parties submitted a Stipulation and Order Selecting ADR

6 Process (“ADR Stipulation”), selecting private mediation to be completed by October 30, 2015;
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WHEREAS, on October 23, 2015, Plaintiff applied ex parte to extend the Parties’ deadline to

8 complete ADR to November 30, 2015;
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WHEREAS, on October 30, 2015, the Court granted Plaintiff’s ex parte application and

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

10 extended the Parties’ deadline to complete ADR on November 30, 2015;
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WHEREAS, on November 10, 2015, the Parties spoke with Howard Herman, Director of the

12 Court’s ADR Program, to select a form of ADR, but were unable to agree to a form of ADR and
13 agreed to continue their telephone conference with Mr. Herman to November 18, 2015;
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WHEREAS, on November 18, 2015, the Parties notified Mr. Herman that the Parties agreed

15 to participate in Court sponsored mediation;
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WHEREAS, on November 18, 2015, the Parties notified Mr. Herman that the Parties will not

17 be able to complete their respective initial discovery prior to November 30, 2015, and thus will not
18 be able to adequately prepare for participation in ADR by that date;
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WHEREAS, after Defendants proposed extending the deadline to complete ADR to

20 December 30, 2015, Mr. Herman suggested the Parties stipulate to extend the deadline to complete
21 ADR to January 29, 2016 because of the limited availability of mediators close to the holidays;
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THEREFORE, the Parties stipulate that good cause exists to extend the deadline to complete

23 ADR to January 29, 2016.
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STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINE TO COMPLETE ADR

1 IT IS SO STIPULATED, THOUGH COUNSEL.
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DATED: November 25, 2015

Reed Smith LLP

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By: /s/ Philip J. Smith________________________
Michele J. Beilke
Philip J. Smith
Attorneys for Defendants
Ricoh Americas Corporation and Ricoh USA, Inc.

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7 DATED: November 25, 2015

Law Offices of Tanya Gomerman

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By: /s/ Arcolina Panto
Arcolina Panto
Attorneys for Plaintiff
Patrick Rulo

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REED SMITH LLP

A limited liability partnership formed in the State of Delaware

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________________

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12 PURSUANT TO STIPULATION, AND FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
13 DATED: December 1, 2015
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________________________________________
Haywood S. Gilliam, Jr.

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STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINE TO COMPLETE ADR