Young et al

Filing 67

STIPULATION AND ORDER re 66 STIPULATION WITH PROPOSED ORDER to Continue Mediation Deadline filed by CWC Travel Inc., Holland America Line, N.V., Carnival Corporation dba Carniaval Cruise Line. Signed by Judge Jon S. Tigar on June 14, 2017. (wsn, COURT STAFF) (Filed on 6/14/2017)

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Lisa M. Conner (SBN 167903)
[e-mail]
Norry S. Harn (SBN 306124)
[e-mail]
FLYNN, DELICH & WISE LLP
One World Trade Center, Suite 1800
Long Beach, California 90831-1800
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants,
HOLLAND AMERICA LINE, N.V., COSTCO WHOLESALE
CORPORATION and CARNIVAL CORPORATION

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
ATTORNEYS AT LAW
One World Trade Center, Suite 1800
Long Beach, California 90831-1800
[phone]

FLYNN, DELICH & WISE

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11 GLORIA YOUNG, MARGARET
CEPHASS-GROSS,
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Plaintiffs,
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vs.
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CASE NO: 3:16-cv-04820 JST
STIPULATED REQUEST TO
CONTINUE MEDIATION DEADLINE
AND [PROPOSED] ORDER

15 HOLLAND AMERICA LINE, N.V., a
foreign corporation; CARNIVAL
16 CORPORATION, dba CARNIVAL
CRUISE LINES, a foreign corporation;
17 CWC TRAVEL, INC., dba COSTCO
TRAVEL, a Washington corporation; and
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Defendants.

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Plaintiffs GLORIA YOUNG and MARGARET CEPHAS-GROSS (collectively,
“Plaintiffs”), and Defendants HOLLAND AMERICA LINE, N.V., CARNIVAL
CORPORATION dba CARNIVAL CRUISE LINES and CWC TRAVEL, INC. dba COSTCO
TRAVEL (collectively, “Defendants”), by and through their respective counsel, hereby stipulate
as follows pursuant to Civil L.R. 6-2:

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1.

By court order, the deadline to complete private mediation is currently set for

July 5, 2017 and the deadline to file a joint mediation statement is set for July 12, 2017 [Dkt.
No. 57];
-1–
3:16-CV-04820 JST

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2.

The parties have scheduled private mediation with mediator Harris E. Weinberg

of Harris E. Weinberg Mediation on September 11, 2017;

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3.

Due to scheduling conflicts between the parties, their respective counsel, and

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the agreed-upon mediator, September 11, 2017 is the earliest date that the parties are able to

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complete private mediation;

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4.

does not result from any lack of diligence on the parties’ or counsels’ parts;

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The parties and their respective counsel agree that this request for continuance

5.

Pursuant to Civil L.R. 6-2(a)(2), the parties hereby disclose the following

previous time modifications in this case: By stipulation, the parties agreed to extend the time for

ATTORNEYS AT LAW
One World Trade Center, Suite 1800
Long Beach, California 90831-1800
[phone]

FLYNN, DELICH & WISE

10 Defendants to answer Plaintiffs’ Complaint from January 11, 2017 to January 25, 2017 [Dkt.
11 No. 53];
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6.

Pursuant to Civil L.R. 6-2(a)(3), the parties note that the deadline for expert

13 disclosures is currently set for September 1, 2017 and the deadline for expert rebuttals is set for
14 September 28, 2017;
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7.

The parties agree that in light of the scheduled mediation, and to conserve

16 litigation fees and costs, good cause also exists for a short continuance of the current expert
17 disclosure and rebuttal deadlines;
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8.

Based on the foregoing, the parties respectfully request that the Court continue

19 the deadline to complete private mediation to September 13, 2017 in order to account for the
20 possibility of a multi-day mediation, and continue the deadline to file a joint mediation statement
21 to September 20, 2017; and
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9.

The parties respectfully request that the Court also continue the deadline for

23 expert disclosures and expert rebuttals to September 27, 2017 and October 24, 2017, respectively,
24 or to dates agreeable to the Court.
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3:16-CV-04820 JST

June 14