Ditlevson v. Legal Express, Ltd. et al

Filing 38

JOINT STIPULATION AND ORDER TO EXTEND TIME TO COMPLETE MEDIATION. The deadline for the parties to complete mediation is extended to May 2, 2016. Signed by Judge Maxine M. Chesney on February 23, 2016. (mmclc2, COURT STAFF) (Filed on 2/23/2016)

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Mark E. Ellis- 127159
Andrew M. Steinheimer- 200524
Amanda F. Riley- 284440
ELLIS LAW GROUP LLP
740 University Avenue, Suite 100
Sacramento, CA 95825
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]

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Attorneys for Defendant LEGAL EXPRESS, LTD.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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LISA MARIE DITLEVSON,

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Case No.: 3:15-cv-03977 MMC

Plaintiff,

JOINT STIPULATION AND ORDER TO
EXTEND TIME TO COMPLETE
MEDIATION

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v.

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LEGAL EXPRESS, LTD., a California
corporation, KRAIG VORSATZ, individually
and in his official capacity; and DOES 1 through
10, inclusive,

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[ADR Local Rule 6-5]

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Defendants.
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·~------------------------------~

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The Court's Order dated November 25, 2015 (Dkt. No. 22) adopted the Parties' Stipulation and

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[Proposed] Order Selecting Mediation pursuant to Civil Local Rule 16-8 and ADR Local Rule 3-5

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(Dkt. No. 20), selecting the ADR process for this case using mediation to be completed before March

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3, 2016.

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The Parties have discussed the deadline, and have agreed that the mediation deadline is

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unrealistic given the parties' own informal and formal discovery timelines. Plaintiff is conducting its

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own investigation of the facts and Defendant Legal Express, Ltd. is still determining whether or not it

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will seek formal discovery responses at this time.
- 1JOINT STIPULATION AND ORDER TO EXTEND TIME TO COMPLETE MEDIATION

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On February 16, 2016, the Parties completed the joint phone conference with mediator Lillian

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Stenfeldt as prescribed by ADR Local Rule 6-6. During this pre-mediation conference, a potential

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conflict was determined by Ms. Stenfeldt, and she has recused herself as the assigned mediator. (Dkt.

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No. 35.)

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On February 19, 2016, mediator Mark H. Penskar was appointed as the parties' mediator. (Dkt.
No. 36.)

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Accordingly, the Parties hereby stipulate and respectfully request the Court to order that the

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deadline for completing mediation shall be extended from March 3, 2016 to a date that is at least sixty

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(60) days from the current mediation deadline.

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There has been no previous modification of the deadline for completing the mediation. The

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requested time modification would have no effect on the schedule for this case other than the date

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requested to be changed.

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IT IS SO STIPULATED.

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Dated: February 23, 2016
ELLIS LAW GROUP, LLP

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By Is/ Amanda F. Riley
Amanda F. Riley
Attorney for Defendant
LEGAL EXPRESS, LTD.

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Dated: February 23, 2016
CONSUMER LAW CENTER, INC.

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By Is/ Fred W Schwinn
Fred W. Schwinn
Attorney for Plaintiff
LISA MARIE DITLEVSON

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

Specifically, the deadline for the parties to complete mediation is hereby EXTENDED to
May 2, 2016.
Dated: February 23, 2016

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The Honorable Maxine M. Chesney
United States District Judge

-2JOINT STIPULATION AND ORDER TO EXTEND TIME TO COMPLETE MEDIATION