Sharifi v. Elite Line Services, LLC et al

Filing 24

STIPULATION AND ORDER RE 23 TO EXTEND MEDIATION AND DISCOVERY DEADLINES AS AMENDED BY THE COURT. Case Management Statement due by 6/16/2016. Further Case Management Conference previously set for 4/21/2016 Continued to 6/23/2016 at 10:00 AM in Courtroom 3, 17th Floor, San Francisco. Signed by Judge Richard Seeborg on 3/4/16. (cl, COURT STAFF) (Filed on 3/4/2016)

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Yousef Jamil Totah (SBN: 296759)
The Law Office of Yousef J. Totah
951 Mariners Island Blvd, Suite 300
San Mateo, CA 94404
[e-mail]
Telephone: [phone]
Facsimile: [phone]

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Attorney for Plaintiff MOHAMMAD SHARIFI

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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)
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MOHAMMAD SHARIFI
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Plaintiff,
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vs.
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ELITE LINE SERVICES, LLC, a limited
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liability company; KEN FOWLER, an
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individual; PATTY NIEKAMP, an individual; )
and DOES 1 through 25, inclusive
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Defendants.

Case Number: 3:15-cv-03677-EDLRS
STIPULATION AND [PROPOSED]
ORDER TO EXTEND MEDIATION AND
DISCOVERY DEADLINES AS
AMENDED BY COURT

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Plaintiff Mohammad Sharifi, by and through their counsel of record, The Law Office of
Yousef J. Totah, and Defendants Elite Line Services, LLC, Ken Fowler, and Patty Niekamp, by

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and through their counsel of record, Masuda, Funai, Eifert & Mitchell, LTD., hereby enter into

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the below stipulation to continue the mediation and discovery deadlines in this matter.

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This stipulation is made in consideration of the fact that the parties have been actively

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engaged in discovery, but need additional time to complete further written discovery, mediation,

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and depositions. The parties engaged in mediation February 16, 2016, but the case did not settle.

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The parties have agreed to continue further facilitated discussions and continue mediation. The

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parties have agreed to continue mediation with Mr. Baldwin Lee on March 21, 2016.

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Page 1 of 4
STIPULATION AND [PROPOSED] ORDER TO EXTEND MEDIATION AND DISCOVERY DEADLINES

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Based on the foregoing, the parties submit that there is good cause to continue the

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mediation completion deadline and all discovery dates by at least 60 days. This would move the

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mediation completion date from March 19, 2016 to May 19, 2016. This would move the non-

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expert discovery cutoff from April 19, 2016 to June 19, 2016. This would move the date to

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disclose experts (retained and non retained) from February 19, 2016 to April 19, 2016. This

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would move the date to disclose supplemental and rebuttal experts from March 19, 2016 to May

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19, 2016. This would move the date of all expert discovery from April 19, 2016 to June 19,

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2016. This would move the date to submit all dispositive pretial motions from July 21, 2016 to

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September 19, 2016. This would move the date of a further case management conference from

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April 21, 2016 to June 23, 2016.

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The parties hereby stipulate that the Case’s Management Order and Pretrial Order may be
amended as set forth below.

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Dated: __03/04/2016________

THE LAW OFFICE OF YOUSEF J. TOTAH

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By: _____/s/_Yousef J. Totah____________

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Yousef J. Totah

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Attorney for Plaintiff Mohammad Sharifi

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Dated:__03/04/2016________

MASUDA, FUNAI, EIFERT & MITCHELL, LTD.

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By:____/s/_Asa _Markel________________
Asa Markel
Alan Kaplan
Attorneys for Elite Line Services, LLC; Ken
Fowler; and Patty Niekamp

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STIPULATION AND [PROPOSED] ORDER TO EXTEND MEDIATION AND DISCOVERY DEADLINES

ORDER

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Based on the foregoing stipulation, the mediation completion date of March 19, 2016, is
off calendar. The new mediation completion date is May 19, 2016.
The non-expert discovery cutoff date of April 19, 2016, is off calendar. The new
non-expert discovery cutoff date is June 19, 2016.

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The date to disclose experts (retained and non-retained) of February 19, 2011, is off
calendar. The new date to disclose experts (retained and non-retained) is April 19, 2016.
The date to disclose supplemental and rebuttal experts of March 19, 2016, is off calendar.
The new date to disclose supplemental and rebuttal experts is May 19, 2016
The expert discovery cutoff deadline of April 19, 2016, is now off calendar. The new

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expert discovery cutoff deadline is June 19, 2016.
The cutoff date to submit all dispositive pretrial motions of July 21, 2016, is off calendar.

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The new last date to submit hear all dispositive pretrial motions is September 19, 2016

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September 22, 2016.

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The further case management conference date of April 21, 2016, is off calendar. The new

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further case management conference date is June 23, 2016
IT IS SO ORDERED.

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Dated: March 4, 2016
UNITED STATES DISTRICT JUDGE

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STIPULATION AND [PROPOSED] ORDER TO EXTEND MEDIATION AND DISCOVERY DEADLINES

CERTIFICATE OF SERVICE

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I hereby certify that on March 4, 2016, the foregoing STIPULATION AND [PROPOSED]
ORDER TO EXTEND MEDIATION AND DISCOVERY DEADLINES was filed
electronically, and served automatically upon opposing counsel by operation of the Court’s
electronic filing system.

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_______/s/__Yousef J. Totah_________________
Yousef J. Totah, Esq. (California Bar # 296759)

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STIPULATION AND [PROPOSED] ORDER TO EXTEND MEDIATION AND DISCOVERY DEADLINES