ICE Consulting, Inc. et al v. Jensen

Filing 86

STIPULATION AND ORDER re 85 for Early Settlement Conference filed by Gavin Jensen, ORDER REFERRING CASE to Magistrate Judge for Settlement. Signed by Judge Edward M. Chen on 11/4/16. (bpf, COURT STAFF) (Filed on 11/4/2016)

1
2
3
4
5
6
7

HARMEET K. DHILLON (SBN: 207873)
[e-mail]
NITOJ P. SINGH (SBN: 265005)
[e-mail]
DHILLON LAW GROUP INC.
177 Post Street, Suite 700
San Francisco, California 94108
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant Gavin Jensen

8
UNITED STATES DISTRICT COURT

9
10

NORTHERN DISTRICT OF CALIFORNIA

11

SAN FRANCISCO DIVISION

12
13

ICE CONSULTING, INC. et al.,

14

Plaintiffs,

15

Case Number: 16-CV-04349-EMC

v.

16

STIPULATED REQUEST BY ALL
PARTIES FOR AN EARLY REFERRAL
TO A JUDICIAL SETTLEMENT
CONFERENCE; AND [PROPOSED]
ORDER

GAVIN JENSEN,

17
Defendant.

18
19
20
21
22
23
24
25
26
27
28

1
Stipulated Request for an Early Referral to a Settlement Conference
30429960.v1

Case No. 16-CV-04349-EMC

1

Plaintiffs ICE Consulting, Inc., Uzair Sattar, and Derick Needham (collectively “Plaintiffs”),

2

and Defendant Gavin Jensen (“Defendant”), by and through their respective counsel, hereby enter

3

into this Stipulation for an early referral to a Settlement Conference pursuant to ADR L.R. 7, et seq.

4

The parties have worked in good faith in furtherance of a settlement in this matter, but are now at a

5

point where they believe further settlement discussions would strongly benefit from a judicial

6

settlement conference. In the interest of avoiding further attorneys’ fees and costs, the parties seek a

7

referral to the Court’s Settlement Conference program now, in advance of the December 8, 2016 Case

8

Management Conference in this matter.

9

WHEREAS, Plaintiffs initiated this matter on August 2, 2016 (Dkt. No. 1);

10

WHEREAS, counsel for Defendant was retained on August 16, 2016;

11

WHEREAS, since August 18, 2016, the parties have discussed settlement in good faith, and

12

have exchanged draft settlement agreements, but have now reached an impasse;

13

WHEREAS, the parties, due to their limited experience with litigation and the emotional

14

nature of this litigation, believe that further settlement discussions will benefit from a judicial

15

settlement conference in place of other ADR options;

16
17

WHEREAS, the parties believe that only limited additional information and document
exchanges may be necessary to effectuate a productive settlement conference;

18

WHEREAS, in the interest of avoiding incurring additional attorneys’ fees and costs, the

19

parties request an early referral to a judicial settlement conference in advance of the December 8,

20

2016 Case Management Conference in this matter; and

21

WHEREAS, while Plaintiffs have proposed continuing all dates on all deadlines and hearings

22

so that the parties may focus on settlement, Defendant would, at minimum, request that the Court

23

move forward with the Case Management Conference so that a trial date and other deadlines are set,

24

and that this matter not be further delayed should the parties be unable to reach a settlement;

25

ACCORDINGLY, THE PARTIES HEREBY STIPULATE to the following:

26

That all parties respectfully request that this matter be assigned to an early judicial settlement

27
28

conference as soon as possible;
IT IS SO STIPULATED.
2
Stipulated Request for an Early Referral to a Settlement Conference
30429960.v1

Case No. 16-CV-04349-EMC

1

Date: November 3, 2016

2

DHILLON LAW GROUP INC.
By: /s/ Nitoj P. Singh
Nitoj P. Singh

3
4

Attorneys for Defendant Gavin Jensen

5
6

Date: November 3, 2016

NOSSAMAN LLP
By: /s/ Andrew C. Crane
Veronica M. Gray
Andrew C. Crane

7
8
9

Attorneys for Plaintiffs ICE Consulting, Inc.;
Uzair Sattar; and Derick Needham

10
11
12

ORDER

13
14
15

PURSUANT TO THE STIPULATION, IT IS SO ORDERED. This case is referred
to a magistrate judge for an expedited settlement conference. Settlement conference

S DISTRICT
___________________________________
TE
C
Hon. Edward M. Chen
TA
United States District Judge

is to be completed within 30 days, if possible.

RT
U
O

S

19

NO

20

DERED
SO OR ED
IT IS
DIFI
AS MO

RT

21

ER

n

M. Che

23

A

H

22

dward
Judge E

R NIA

18

LI

UNIT
ED

17

FO

16

N

D IS T IC T
R

OF

C

24
25
26
27
28
3
Stipulated Request for an Early Referral to a Settlement Conference
30429960.v1

Case No. 16-CV-04349-EMC