Anderson v. Chevron U.S.A. Inc.

Filing 15

ORDER REFERRING CASE to Private ADR. STIPULATION AND ORDER re 11 STIPULATION and Proposed Order selecting Mediation. Signed by Judge Edward M. Chen on 4/3/17. (bpf, COURT STAFF) (Filed on 4/3/2017)

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RICHARD E. QUINTILONE II (SBN 200995)
ALVIN B. LINDSAY (SBN 220236)
GEORGE A. ALOUPAS (SBN 313112)
QUINTILONE & ASSOCIATES
22974 EL TORO ROAD, SUITE 100
LAKE FOREST, CA 92630
TELEPHONE: [phone]
FACSIMILE: [phone]
E-MAIL: [e-mail]; [e-mail]
Attorneys for Plaintiff, JENNIFER ANDERSON on behalf of herself and on behalf of a Class of all
other persons similarly situated
ROBERT D. EASSA, State Bar No. 107970
[e-mail]
DELIA A. ISVORANU, State Bar No. 226750
[e-mail]
SEDGWICK LLP
333 Bush Street, 30th Floor
San Francisco, CA 94104-2834
Telephone: [phone]
Facsimile: 415.781.2635
Attorneys for Defendant, CHEVRON U.S.A. INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA – SAN FRANCISCO DIVISION

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JENNIFER ANDERSON, on behalf of herself
and on behalf of a Class of all other persons
similarly situated

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Plaintiff,
vs.
CHEVRON U.S.A., INC., a Delaware
Corporation; and DOES 1 through 100,
inclusive,

Case No.: 3:17-cv-00103-EMC
CLASS ACTION
Assigned For All Purposes To:
Hon. Edward M. Chen
STIPULATION AND [PROPOSED] ORDER
SELECTING ADR PROCESS

Defendants.
Complaint Filed: September 7, 2016
Removed: January 9, 2017

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-1STIPULATION AND ORDER SELECTING ADR PROCESS

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Pursuant to the Civil Local Rules (“Civil L.R.”) and the Local ADR Rules (“ADR L.R.”),

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Plaintiff, Jennifer Anderson, on behalf of herself and other similarly situated employees of Defendant

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Chevron U.S.A. Inc. (“Defendant”) (collectively, “the Parties”), by and through their respective

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undersigned counsel of record, report that they have met and conferred regarding ADR and have

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reached the following stipulation pursuant to Civil L.R. 16-8 and ADR L.R. 3-5. The Parties agree to

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participate in the following ADR process:

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Early Neutral Evaluation (ENE) (ADR L.R. 5)

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Mediation (ADR L.R. 6)

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X – Private ADR (specify process and provider)


Private mediation by a mediator to be agreed upon by the Parties who has
expertise in wage and hour class and collective actions.

The Parties agree to hold the ADR session by:
the presumptive deadline (90 days from the date of the order referring the case to ADR,

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unless otherwise ordered).

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X - other requested deadline: As this is a class and collective action, the Parties request that

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the Court set a mediation completion deadline of September 1, 2017 to allow the Parties to progress

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with class certification discovery and FLSA conditional certification and to accommodate the

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schedules of the Parties and the mediator.

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Dated: March 23, 2017

QUINTILONE & ASSOCIATES

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By: ___________________________________
RICHARD E. QUINTILONE II,
ALVIN B. LINDSAY
GEORGE A. ALOUPAS
Attorney for Plaintiff JENNIFER ANDERSON,
on behalf of herself and on behalf of a Class of all
other persons similarly situated

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-2STIPULATION AND ORDER SELECTING ADR PROCESS

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Dated: March 23, 2017

SEDGWICK LLP

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By: ___________________________________
ROBERT D. EASSA
DELIA A. ISVORANU
Attorneys for Defendant, CHEVRON U.S.A. INC.

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_______________________________________
U.S. DISTRICT/MAGISTRATE JUDGE
en
d M. Ch
e Edwar
Judg

NO

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4/3/2017
Date: ________________________

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D

RDERE

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IT IS S

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R NIA

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UNIT
ED

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S DISTRICT
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xIT IS SO ORDERED
IT IS SO ORDERED WITH MODIFICATIONS:

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N

F
D IS T IC T O
R

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-3STIPULATION AND ORDER SELECTING ADR PROCESS

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PROOF OF SERVICE

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I, the undersigned, declare as follows:

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I am a citizen of the United States, over the age of 18 years, and not a party to the within action. I am an
employee of or agent for Quintilone & Associates, whose business address is 22974 El Toro Rd., Suite 100,
Lake Forest, CA 92630-4961.

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On March 23, 2017, I served the foregoing document(s):

STIPULATION AND [PROPOSED] ORDER SELECTING ADR PROCESS
on the following parties in this action addressed as follows:

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SEE ATTACHED SERVICE LIST
______

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______

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(BY FACSIMILE) By use of facsimile machine number 949.458.9679, I served a copy of the
within document(s) on the above interested parties at the facsimile numbers listed above. The
transmission was reported as complete and without error. The transmission report was properly
issued by the transmitting facsimile machine.

___X___

(BY E-MAIL through ECF) I caused a true and correct copy of each document to be delivered by
Electronic Mail through the Court’s ECF system

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(BY US-MAIL) I caused a true copy of each document, placed in a sealed envelope with postage
fully paid, to be placed in the United States mail at Lake Forest, California. I am "readily
familiar" with this firm's business practice for collection and processing of mail, that in the
ordinary course of business said document(s) would be deposited with the U.S. Postal Service on
that same day. I understand that the service shall be presumed invalid if the postal cancellation
date or postage meter date on the envelope is more than one day after the date of deposit for
mailing contained on this affidavit.
(BY OVERNIGHT DELIVERY) I caused a true copy of each document, placed in a sealed
envelope with delivery fees provided for, to be deposited in a box regularly maintained by Federal
Express or Overnight Express. I am readily familiar with this firm's practice for collection and
processing of documents for overnight delivery and know that in the ordinary course of
Quintilone & Associates’ business practice the document(s) described above will be deposited in a
box or other facility regularly maintained by Federal Express or Overnight Express or delivered to
a courier or driver authorized by Federal Express or Overnight Express to receive documents on
the same date it is placed at Quintilone & Associates for collection.

Executed on March 23, 2017, at Lake Forest, California

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(FEDERAL) I declare under penalty of perjury that the above is true and correct.

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_______

(STATE) I declare under penalty of perjury that the above is true and correct.

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_______________________
ALVIN B. LINDSAY

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-1PROOF OF SERVICE

SERVICE LIST

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Delia A. Isvoranu, Esq.
Counsel for Defendant Chevron U.S.A, Inc.
Sedgwick, LLP
333 Bush Street, 30th Floor
San Francisco, CA 94104-2834
Phone: [phone] direct
Fax: [phone]
Email [e-mail]
Q&A Case No.: 16.01263

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-2PROOF OF SERVICE