Kay v. Main Street Hub, Inc.

Filing 28

STIPULATION AND ORDER re 27 STIPULATION WITH PROPOSED ORDER To Extend Deadline For Mediation filed by Main Street Hub, Inc. Status Report due by 5/26/2016. Status Conference reset for 6/2/2016 10:30 AM in Courtroom 5, 17th Floor, San Francisco before Edward M. Chen.. Signed by Judge Edward M. Chen on 3/28/16. (bpf, COURT STAFF) (Filed on 3/28/2016)

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DANIEL J. MCCOY (CSB No. 206099)
[e-mail]
SHEEVA J. GHASSEMI-VANNI (CSB No. 246639)
[e-mail]
FENWICK & WEST LLP
Silicon Valley Center
801 California Street
Mountain View, CA 94041
Telephone:
650.988.8500
Facsimile:
650.938.5200

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Attorneys for Defendant
MAIN STREET HUB, INC.
FRANK P. SARRO (CSB No. 129780)
2121 North California Boulevard, Suite 290
Walnut Creek, CA 94596
Telephone:
415.816.5141

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Attorney for Plaintiff
NORMAN KAY

MOUNTAIN VIEW

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ATTORNEYS AT LAW

F ENWICK & W EST LLP

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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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NORMAN KAY,
Plaintiff,

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Case No.: 3:15-cv-04666-EMC

v.

STIPULATION AND [PROPOSED]
ORDER TO EXTEND DEADLINE FOR
MEDIATION

MAIN STREET HUB, INC., and DOES 1
through 200, inclusive,

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Defendants.
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STIP AND [PROPOSED] ORDER TO
EXTEND MEDIATION DEADLINE

Case No.: 3:15-cv-04666-EMC

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STIPULATION

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This Stipulation and [Proposed] Order is entered into by and between counsel for Plaintiff

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Norman Kay (“Plaintiff”) and counsel for Defendant Main Street Hub, Inc. (“Defendant”)

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(Plaintiff and Defendant are collectively referred to hereafter as the “parties”) as follows:

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WHEREAS, in its February 10, 2016 Case Management and Pretrial Order for Jury Trial,

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the Court ordered the parties to complete Court-sponsored mediation by April 19, 2016 (Dkt. No.

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25);

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WHEREAS, the parties have been actively engaged in meet and confer with each other
and mediator Judith D. Keyes about the date for such mediation;

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participate in mediation on or before April 19 is extremely limited;

MOUNTAIN VIEW

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ATTORNEYS AT LAW

F ENWICK & W EST LLP

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WHEREAS, the number of dates for which both parties and the mediator are available to

WHEREAS, Plaintiff’s counsel has several hearings and a trial in April, Defendant’s

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company representative has limited availability through April, and the parties need enough time

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to conduct meaningful discovery prior to mediation;

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WHEREAS, the parties have identified May 16, 2016 as a date that will work for the
parties and the mediator; and

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WHEREAS, both parties and the mediator concur with this request to extend the deadline
to May 16, 2016.

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NOW THEREFORE, the parties through their respective counsel of record, hereby
stipulate, subject to Court approval, as follows:

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1.

The deadline for completing Court-sponsored mediation shall be extended from

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April 19, 2016, to May 16, 2016.

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STIP AND [PROPOSED] ORDER TO
EXTEND MEDIATION DEADLINE

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Case No.: 3:15-cv-04666-EMC

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IT IS SO STIPULATED.

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Dated: March 24, 2016

FENWICK & WEST LLP

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By:
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/s/ Sheeva J. Ghassemi-Vanni
Sheeva J. Ghassemi-Vanni
Attorneys for Defendant
MAIN STREET HUB, INC.

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Dated: March 24, 2016

FRANK SARRO LAW

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By:

MOUNTAIN VIEW

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ATTORNEYS AT LAW

F ENWICK & W EST LLP

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/s/ Frank P. Sarro
Frank P. Sarro
Attorney for Plaintiff
NORMAN KAY

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STIP AND [PROPOSED] ORDER TO
EXTEND MEDIATION DEADLINE

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Case No.: 3:15-cv-04666-EMC

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UNIT
ED

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Honorable Edward M. Chen
TA
United States District Judge

DERED
SO OR ED
IT IS
DIFI
AS MO

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RT

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RT
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O

S

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status conference reset for 6/2/16 at 10:30 a.m. Updated joint status report
due 5/26/16.
S DISTRICT
Dated:
3/28/2016
TE
C

dward
Judge E

ER

n

M. Che

MOUNTAIN VIEW

ATTORNEYS AT LAW

F ENWICK & W EST LLP

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A

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R NIA

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Court-sponsored mediation shall be extended from April 19, 2016, to May 16, 2016. 5/12/16

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PURSUANT TO STIPULATION, IT IS SO ORDERED that the deadline for completing

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[PROPOSED] ORDER

N

D IS T IC T
R

OF

C

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STIP AND [PROPOSED] ORDER TO
EXTEND MEDIATION DEADLINE

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Case No.: 3:15-cv-04666-EMC

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ATTORNEY ATTESTATION
I, Sheeva J. Ghassemi-Vanni, am the ECF User whose identification and password are

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being used to file this STIPULATION AND [PROPOSED] ORDER TO EXTEND

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DEADLINE FOR MEDIATION. In compliance with Civil Local Rule 5-1(i)(3), I hereby attest

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that all signatories have concurred in this filing.

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Dated: March 24, 2016

FENWICK & WEST LLP

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By:

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/s/ Sheeva J. Ghassemi-Vanni
Sheeva J. Ghassemi-Vanni
Attorneys for Defendant
MAIN STREET HUB, INC.

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MOUNTAIN VIEW

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ATTORNEYS AT LAW

F ENWICK & W EST LLP

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STIP AND [PROPOSED] ORDER TO
EXTEND MEDIATION DEADLINE

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Case No.: 3:15-cv-04666-EMC