Argueta v. Interstate Management Company, LLC

Filing 26

STIPULATION AND ORDER re 25 STIPULATION WITH PROPOSED ORDER Regarding Extension of ADR Deadline Pursuant to Local Rule 6-5 filed by Interstate Management Company, LLC. Signed by Judge Jon S. Tigar on August 18, 2017. (wsn, COURT STAFF) (Filed on 8/18/2017)

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1 2 3 4 5 6 7 8 9 10 11 12 ADAM J. FISS, Bar No. 211799 afiss@littler.com TINA SUNDAR, Bar No. 288022 tsundar@littler.com LITTLER MENDELSON, P.C. 50 W. San Fernando St., 15th Floor San Jose, California 95113.2303 Telephone: 408.998.4150 Facsimile: 408.668.0992 Attorneys for Defendant INTERSTATE MANAGEMENT COMPANY, LLC MICHAEL S. CUNNINGHAM, Bar No. 272969 michael@michaelcunninghamlaw.com 32605 Temecula Parkway, Suite 211 Temecula, Ca 92592 Telephone: (951) 213-4786 Facsimile: (858) 366-4158 Attorney for Plaintiff SARA ARGUETA 13 UNITED STATES DISTRICT COURT 14 NORTHERN DISTRICT OF CALIFORNIA 15 SAN FRANCISCO DIVISION 16 17 SARA ARGUETA, 18 19 20 21 22 Plaintiff, v. INTERSTATE MANAGEMENT COMPANY, LLC; and DOES 1 through 10, inclusive, Case No. 3:17-cv-01426-JST JOINT STIPULATION AND [PROPOSED] ORDER REGARDING EXTENSION OF ADR DEADLINE PURSUANT TO LOCAL RULE 6-5 Defendants. 23 24 25 26 27 28 LITTLER MENDELSON, P.C. 50 W. San Fernando, 15th Floor San Jose, CA 95113.2303 408.998.4150 CASE NO. 3:17-CV-01426-JST JOINT STIPULATION 1 Pursuant to Local Rules for Alternative Dispute Resolution in the United States 2 District Court for the Northern District of California, ADR LR 6-5, Plaintiff Sara Argueta 3 (“Plaintiff”) and Defendant Interstate Management Company, LLC (“Defendant”) (collectively 4 referred to as “the Parties”) hereby stipulate and agree as follows: 5 1. On June 21, 2017, the parties appeared for a case management conference 6 before this Court at which time the Court ordered the parties to mediate this matter in order to satisfy 7 the parties’ alternative dispute resolution requirements. 8 9 10 11 12 2. The deadline for the parties to mediate this matter was set for September 19, 3. Subsequently, the parties agreed to mediate this matter on September 19, 2017. 2017, before the assigned mediator, Honorable David Garcia (Retired). 4. At the time the parties agreed to mediate this matter, counsel for Defendant 13 had a trial scheduled to begin on September 8, 2017 in San Diego County Superior Court. 14 Subsequent to the scheduling of the parties’ mediation, the September 8, 2017 trial date for counsel 15 for Defendant was reset to September 15, 2017. Accordingly, counsel for Defendant will no longer 16 be available to mediate this matter on September 19, 2017. 17 5. Counsel for Plaintiff and Defendant spoke on August 16, 2017 regarding the 18 need to reschedule the mediation and request that the Court extend the parties’ deadline to complete 19 mediation. Both parties agree to make such a request to the Court. 20 6. In order to provide the parties the ability to reschedule and timely conduct 21 their mediation, the parties stipulate and agree to extend the timeline to complete alternative dispute 22 resolution in this matter from September 19, 2017 to October 31, 2017. 23 7. Both Plaintiff, by and through her counsel of record Michael Cunningham, 24 and Defendant, by and through its counsel of record Adam J. Fiss, concur in this request to extend 25 the deadline to complete mediation. 26 27 8. The Parties respectfully request that this Court grant this Stipulation and issue an Order extending the deadline to complete the mediation to October 31, 2017. 28 LITTLER MENDELSON, P.C. 50 W. San Fernando, 15th Floor San Jose, CA 95113.2303 408.998.4150 CASE NO. 3:17-CV-01426-JST 2. JOINT STIPULATION SO STIPULATED AND AGREED. 1 2 Dated: August 17, 2017 3 /s/ Adam J. Fiss ADAM J. FISS TINA SUNDAR LITTLER MENDELSON, P.C. Attorneys for Defendant INTERSTATE MANAGEMENT COMPANY, LLC 4 5 6 7 Dated: August 17, 2017 8 /s/ Michael S. Cunningham MICHAEL S. CUNNINGHAM CUNNINGHAM LAW APC Attorneys for Plaintiff SARA ARGUETA 9 10 11 12 13 14 15 PURSUANT TO STIPULATION, IT IS SO ORDERED. Dated: August 18, 2017 Hon. Jon S. Tigar United States District Court Judge 16 17 18 19 Firmwide:149495152.1 079499.1041 20 21 22 23 24 25 26 27 28 LITTLER MENDELSON, P.C. 50 W. San Fernando, 15th Floor San Jose, CA 95113.2303 408.998.4150 CASE NO. 3:17-CV-01426-JST 3. JOINT STIPULATION

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