Haralson v. U.S. Aviation Services Corp. et al

Filing 55

STIPULATION AND ORDER re 54 STIPULATION WITH PROPOSED ORDER TO CONTINUE THE DEADLINE TO FILE MOTION FOR CLASS CERTIFICATION filed by James Haralson. Signed by Judge Jon S. Tigar on February 14, 2018. (wsn, COURT STAFF) (Filed on 2/14/2018)

1 Shaun Setareh (SBN 204514)
[e-mail]
2 H. Scott Leviant (SBN 200834)
[e-mail]
3 SETAREH LAW GROUP
9454 Wilshire Boulevard, Suite 907
4 Beverly Hills, California 90212
Telephone [phone]
5 Facsimile [phone]
6 Attorneys for Plaintiff
JAMES HARALSON
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8 Brendan Dolan (SBN 126732)
[e-mail]
9 Christopher A. Braham (SBN 293367)
[e-mail]
10 VEDDER PRICE (CA), LLP
275 Battery Street, Suite 2464
11 San Francisco, California 94111
T: [phone]
12 F: [phone]
13 Attorneys for Defendant
U.S. AVIATION SERVICES CORP.
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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18 JAMES HARALSON, on behalf of himself,
all others similarly situated, and the general
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public,
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Plaintiff,
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vs.
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23 U.S. AVIATION SERVICES CORP., a
Nevada corporation; UNITED AIRLINES,
24 INC., a Delaware corporation; and DOES 150, inclusive,
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Case No. 3:16-cv-05207-JST
Assigned For All Purposes To The Honorable
Jon S. Tigar, Courtroom 9
STIPULATION TO CONTINUE THE
DEADLINE TO FILE MOTION FOR
CLASS CERTIFICATION; [PROPOSED]
ORDER

Action Filed: August 9, 2016
Defendants.

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STIPULATION TO CONTINUE THE DEADLINE TO FILE MOTION FOR CLASS CERTIFICATION;
[PROPOSED] ORDER

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JOINT STIPULATION

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This Stipulation is made by and between Plaintiff JAMES HARALSON (“Plaintiff”), and

3 Defendant U.S. AVIATION SERVICES CORP., and Defendant UNITED AIRLINES, INC.
4 (collectively “Defendants”), (“collectively “the Parties”), through their respective counsel of record,
5 with reference to the following facts:
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WHEREAS, the deadline to file a Motion for Class Certification is on March 5, 2018;

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WHEREAS, on February 7, 2018, the Parties attended all day mediation with Mark Rudy in

8 San Francisco, California;
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WHEREAS, even though no settlement was reached, the Parties are continuously engaged

10 in meaningful discussions regarding a class wide settlement;
WHEREAS, Mark Rudy, the mediator, recommends continuing the class certification

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12 briefing schedule, which will give him an opportunity to attempt to settle the case without the
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Parties incurring additional costs and fees associated with the class certification schedule;

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WHEREAS, given the Parties’ continuous meaningful discussions and Mark Rudy’s

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recommendation to continue the class certification schedule, the Parties enter into a Stipulation
respectfully seeking an Order to continue the deadline up to 60 days to file a Motion for Class

18 Certification;
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WHEREAS, the Parties will also use the 60 days to conduct a Rule 30(b)(6) deposition;

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WHEREAS, the Parties have agreed that, except as otherwise stated, nothing in this

21 Stipulation shall operate as a waiver of any rights they may have in this action.
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THEREFORE, the Parties hereby stipulate and agree as follows:
1. The Parties enter into a Stipulation respectfully seeking an Order to continue the
deadline to file a Motion for Class Certification up to 60 days;
2. Except as otherwise stated, nothing in this Stipulation shall operate as a waiver of
any rights that either Plaintiff or Defendants may have in this action.

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STIPULATION TO CONTINUE THE DEADLINE TO FILE MOTION FOR CLASS CERTIFICATION;
[PROPOSED] ORDER

1 DATED: February 13, 2018

SETAREH LAW GROUP

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/S/ Shaun Setareh
SHAUN SETAREH
Attorneys for Plaintiff
JAMES HARALSON

6 DATED: February 13, 2018

VEDDER PRICE (CA), LLP

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/S/ Christopher A. Braham
BRENDAN DOLAN
CHRISTOPHER A. BRAHAM
Attorneys for Defendant
U.S. AVIATION SERVICES CORP.

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STIPULATION TO CONTINUE THE DEADLINE TO FILE MOTION FOR CLASS CERTIFICATION;
[PROPOSED] ORDER

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[PROPOSED] ORDER
Pursuant to the Parties’ Stipulation, the Court hereby orders the deadline to file Motion for

3 Class Certification to be continued up to 60 days.
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IT IS SO ORDERED.

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7 Dated: February ___, 2018
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_____________________________

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Honorable Jon S. Tigar
United States District Judge

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STIPULATION TO CONTINUE THE DEADLINE TO FILE MOTION FOR CLASS CERTIFICATION;
[PROPOSED] ORDER