Shareefah Joseph v. Service Employees International Union, United Healthcare West (SEIU UHW)

Filing 27

STIPULATION AND ORDER re 26 Stipulated Request to Extend Deadline for Conducting Mediation; and Proposed Order filed by Service Employees International Union, United Healthcare West (SEIU UHW). Signed by Judge Edward M. Chen on 10/11/16. (bpf, COURT STAFF) (Filed on 10/11/2016)

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BRUCE A. HARLAND, Bar No. 230477
XOCHITL A. LOPEZ, Bar No. 284909
WEINBERG, ROGER & ROSENFELD
A Professional Corporation
1001 Marina Village Parkway, Suite 200
Alameda, California 94501
Telephone [phone]
Fax [phone]
E-Mail: [e-mail]
[e-mail]

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Attorneys for Defendant,
SEIU, UNITED HEALTHCARE WORKERS-WEST

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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No. 3:16-cv-01644-EMC

SHAREEFAH JOSEPH,
Plaintiff,
v.

STIPULATED REQUEST TO EXTEND
DEADLINE FOR CONDUCTING
MEDIATION; AND PROPOSED
ORDER

SEIU, UNITED HEALTHCARE WORKERSWEST,
Defendant.

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Pursuant to ADR L.R. 6-7 and L.R. 7-12, Plaintiffs and Defendant seek to extend the time

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for conducting mediation in this matter. The considerations supporting the request, as stipulated,

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are set forth below:

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The Parties voluntarily agreed to conduct a private mediation in this dispute to determine

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Defendant’s Motion to Dismiss, the Court ordered that private mediation was to be completed

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within one-hundred and fifty (150) days from the date of that hearing. The Court subsequently

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A Professional Corporation

to FRCP 12(b)(6). On July 21, 2016, during the Case Management Conference and hearing on

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1001 Marina Village Parkway, Suite 200
Alameda, California 94501
[phone]

agreed to delay discovery until after final adjudication of Defendant’s Motion to Dismiss pursuant

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WEINBERG, ROGER &
ROSENFELD

whether settlement may be achieved without the necessity for further litigation. The Parties

entered an order partially granting and partially denying Defendant’s Motion to Dismiss, thus
STIPULATED REQUEST TO EXTEND DEADLINE FOR CONDUCTING MEDIATION; AND PROPOSED
ORDER
Case No. 3:16-cv-01644-EMC

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clarifying the disputes subject to further litigation. Plaintiff declined to file an amended

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complaint, and Defendant filed its Answer on September 14, 2016.

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The Parties now desire to engage in meaningful discovery for the purpose of facilitating

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settlement prior to any mediation. The mediator selected by the Parties is unavailable until after

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the Court’s deadline for conducting mediation—the earliest availability being in December 2016

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and January 2017. In order to retain the neutral mediator selected by the Parties, and in order to

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have sufficient opportunity to engage in discovery, and to preserve the Parties’ resources and the

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resources of the Court, the Parties jointly request an extension of the deadline to conduct

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mediation to January 31, 2017, which is three weeks prior to the Parties’ next Case Management

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Conference.

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Dated: October 7, 2016

WEINBERG, ROGER & ROSENFELD
A Professional Corporation

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By:

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Dated: October 7, 2016

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GOYETTE & ASSOCIATES, INC.
/S/ GARY G. GOYETTE
GARY G. GOYETTE
Attorneys for Plaintiff,
SHAREEFAH JOSEPH

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UNIT
ED

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PURSUANT TO STIPULATION IT IS SO ORDERED.

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Dated:

October 11, 2016

DERED

O OR
IT IS S

. Chen

NO

ward M
HON. EDWARD M. CHENe Ed
Judg
JUDGE OF THE DISTRICT COURT

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RT

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ER

WEINBERG, ROGER &
ROSENFELD
A Professional Corporation
1001 Marina Village Parkway, Suite 200
Alameda, California 94501
[phone]

140652\884787

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/S/ BRUCE A. HARLAND
BRUCE A. HARLAND
XOCHITL A. LOPEZ
Attorneys for Defendant,
SEIU, UNITED HEALTHCARE WORKERSWEST

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F
D IS T IC T O
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STIPULATED REQUEST TO EXTEND DEADLINE FOR CONDUCTING MEDIATION; AND PROPOSED
ORDER

Case No. 3:16-cv-01644-EMC