Scott Crawford et al v. Uber Technologies, Inc. et al

Filing 121

STIPULATION AND ORDER RE 120 to Extend Stay AS MODIFIED BY THE COURT. Bench Trial set for 6/22/2020 at 09:00 AM before Judge Richard Seeborg. Further Case Management Conference set for 5/14/2020 at 10:00 AM in San Francisco, Courtroom 03, 17th Floor. Pretrial Conference set for 6/10/2020 at 10:00 AM in San Francisco, Courtroom 03, 17th Floor before Judge Richard Seeborg. Signed by Judge Richard Seeborg on 10/25/19. (cl, COURT STAFF) (Filed on 10/25/2019)

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MORGAN, LEWIS & BOCKIUS LLP
Anne Marie Estevez (pro hac vice)
200 Biscayne Boulevard, Suite 5300
Miami, FL 33131
T: 305.415.3000
F: 305.415.3001
[e-mail]
Stephanie Schuster (pro hac vice)
Patrick A. Harvey (pro hac vice)
Clara Kollm (pro hac vice)
1111 Pennsylvania Avenue, NW
Washington, DC 20004
T: 202.739.3000
F: 202.739.3001
[e-mail]
[e-mail]
[e-mail]

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Kathy H. Gao (CA Bar No. 259019)
300 South Grand Avenue, 22nd Floor
Los Angeles, CA 90071
T: 213.612.2500
F: 213.612.2501
[e-mail]

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Attorneys for Defendants

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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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SCOTT CRAWFORD and JARVIS
JERNIGAN, JR.,

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Plaintiffs,
v.
UBER TECHNOLOGIES, INC. and
RASIER, LLC,

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Defendants.
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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
WASHINGTON, D.C.

Case No. 3:17-cv-02664-RS
ORDER
STIPULATED MOTION TO EXTEND
STAY AS MODIFED BY THE COURT
Hon. Richard J. Seeborg

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STIPULATED MOTION TO EXTEND STAY

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Plaintiffs Scott Crawford and Jarvis Jernigan, Jr. (“Plaintiffs”), and Defendants Uber

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Technologies, Inc. and Rasier, LLC (“Defendants”) (collectively, the “Parties”), through counsel,

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submit this Joint Motion to Extend the Stay. In support of this stipulated joint motion, the Parties

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state as follows:

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1.

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On October 17, 2018, the Parties participated in a mediation session conducted by

Mediator Howard A. Herman. ECF No. 111.
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With the assistance of Mediator Herman, the Parties negotiated a confidential

agreement to, among other things, jointly seek an order staying all proceedings in this action for

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eighteen months.

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3.

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On October 30, 2018, the Parties filed a Joint Stipulation to Stay Proceedings in the

captioned case seeking an eighteen month stay. ECF No. 113.
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On November 5, 2018, this Court granted the joint request for a stay, but modified

the stay to only twelve months. ECF No. 114 ¶¶ 3, 6.
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The parties continue to believe that they will be more likely to resolve the case if

the Court enters the original eighteen month stay to which the parties agreed.
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An order extending the stay would also impact the scheduled November 7, 2019

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status conference and attendant deadline to file a joint case management statement by October 31,

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2019. As such, the parties further request the Court to continue the status conference and attendant

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deadline to submit a joint case management statement to a date after April 30, 2020.

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WHEREFORE, the Parties jointly move this Court to extend the stay entered in this case to

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April 30, 2020, and to continue the status conference and attendant deadline to submit a joint

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management statement to dates after April 30, 2020. Pretrial Conference set for June 10, 2020 at
10:00 am. Bench Trial set for June 22, 2020 at 9:00 am. Further Case Management Conference
set for May 14, 2020 at 10:00 am. Case Management Statement due May 7, 2020.

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[SIGNATURES APPEAR ON THE FOLLOWING PAGE]

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
WASHINGTON, D.C.

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Dated: October 24, 2019

Respectfully submitted,

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s/Anne Marie Estevez
MORGAN, LEWIS & BOCKIUS LLP
By: s/ Anne Marie Estevez
Anne Marie Estevez
Stephanie Schuster
Patrick A. Harvey
Clara Kollm
Kathy H. Gao

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Attorneys for Defendants

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s/ Garret DeReus
BIZER AND DEREUS, LLC
Garret DeReus
Andrew Bizer

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Attorney for Plaintiffs
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s/ William Most
AQUA TERRA AERIS LAW GROUP
William Most

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Attorney for Plaintiffs
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Pursuant to Local Rule 5-1(i)(3), I hereby attest that I will have on file all holographic
signatures corresponding to any signature indicated by a conformed signature (s/) within this efiled document.

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s/Anne Marie Estevez
Anne Marie Estevez

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PURSUANT TO STIPULATION
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IT IS SO ORDERED, this ______day of October, 2019.
25th
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Hon. Richard Seeborg
United States District Judge

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW
WASHINGTON, D.C.

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