Men Nguyen v. David Tibbles et al

Filing 39

STIPULATION AND ORDER re 38 Stipulation and [Proposed] Order Regarding ADR re 36 Stipulation and Order filed by Ocean Angel IV, LLC. Signed by Judge Jon S. Tigar on December 6, 2017. (wsn, COURT STAFF) (Filed on 12/6/2017)

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COX, WOOTTON, LERNER,
GRIFFIN & HANSEN LLP
Galin G. Luk (SBN 199728)
Marc A. Centor (SBN 252011)
900 Front Street, Suite 350
San Francisco, CA 94111
Telephone No.: [phone]
Facsimile No.: [phone]

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Attorneys for Defendant
OCEAN ANGEL IV, LLC

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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MEN NGUYEN, Surviving Spouse of TOAN
TRAN,

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Case No.: 3:16-cv-04023 EDL JST
STIPULATION AND PROPOSED
ORDER REGARDING ADR

Plaintiff,
v.
OCEAN ANGEL IV, LLC, and DOES 1-10,
inclusive, in personam, and the F/V OCEAN
ANGEL IV, and her engines, tackles, apparel,
etc., in rem,

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Defendants.
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Defendants OCEAN ANGEL IV, LLC, in personam, and the F/V OCEAN ANGEL

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IV, in rem (“Defendants”) and plaintiff MEN NGUYEN (“Plaintiff”) hereby jointly submit

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this Stipulation and Proposed Order Regarding ADR.

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On June 22, 2017, this Court ordered the parties to engaged in a private mediation

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various factors beyond their control the parties have been unable to mediate this case by

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that deadline. The parties have, however, agreed to and scheduled a January 17, 2018,

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COX, WOOTTON,
LERNER, GRIFFIN &
HANSEN LLP

by December 1, 2017. Although the parties have worked diligently toward this end, due to

private mediation.

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The parties believe that their unanimous availability on January 17, 2018, and their

900 Front Street, Suite 350
San Francisco, CA 94111
TEL: [phone]
FAX: [phone]

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stipulation to that date with an agreed-upon mediator, constitutes good cause for an

USF.Nguyen

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extension of the mediation deadline previously set in this case.
-1STIPULATION AND PROPOSED ORDER REGARDING ADR

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The parties therefore stipulate and respectfully request that this Court grant the

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proposed order below and extend the mediation deadline in this matter through January 17,

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2018.

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Dated: December 5, 2017

COX, WOOTTON, LERNER,
GRIFFIN & HANSEN, LLP
Attorneys for Defendant
OCEAN ANGEL IV, LLC
and F/V OCEAN ANGEL IV

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/s/Marc A. Centor
Marc A. Centor

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Dated: December 5, 2017

DL LAW GROUP
Attorneys for Plaintiff
MEN NGUYEN

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/s/ Katie J. Spielman
Katie J. Spielman

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[PROPOSED] ORDER

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IT IS ORDERED that the deadline in this action for private mediation is extended
through January 17, 2018.

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December 6, 2017
Dated: _______________________

_______________________________
Jon S. Tigar
United States District Judge

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COX, WOOTTON,
LERNER, GRIFFIN &
HANSEN LLP

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900 Front Street, Suite 350
San Francisco, CA 94111
TEL: [phone]
FAX: [phone]

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USF.Nguyen

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-2STIPULATION AND PROPOSED ORDER REGARDING ADR