Fraser et al v. Nationwide Mutual Insurance Company

Filing 27

STIPULATION AND ORDER re 25 Stipulation filed by Nationwide Mutual Insurance Company to continue CMC statement deadline. Signed by Judge Edward M. Chen on 9/26/17. (bpfS, COURT STAFF) (Filed on 9/26/2017)

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JOHN S. HONG, Bar No. 255150
[e-mail]
COURTNEY OSBORN, Bar No. 312011
[e-mail]
LITTLER MENDELSON, P.C.
333 Bush Street
34th Floor
San Francisco, CA 94104
Telephone:
415.433.1940
Facsimile:
415.399.8490
JAMES J. OH, (Admitted pro hac vice)
[e-mail]
LITTLER MENDELSON, P.C.
321 N. Clark Street, Suite 1000
Chicago, IL 60654
Telephone: [phone]
Facsimile: 312.602.3807
Attorneys for Defendant
NATIONWIDE MUTUAL INSURANCE
COMPANY

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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JULIAN FRASER, JOSEPH WUCHER,
IRENE DAMSKY, KIM ZAIA, and
CHRIS JACKSON as individuals and in
their representative capacity,
Plaintiffs,

Case No. 3:17-cv-03702-EMC
JOINT STIPULATION AND PROPOSED
ORDER ENLARGING TIME TO FILE
RULE 26(F) REPORT AND JOINT CASE
MANAGEMENT STATEMENT

v.
NATIONWIDE MUTUAL INSURANCE
COMPANY, a corporation,
Defendant.

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Plaintiffs JULIAN FRASER, JOSEPH WUCHER, IRENE DAMSKY, KIM ZAIA, and

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CHRIS JACKSON, by and through their counsel of record, Rudy, Exelrod, Zieff & Low, LLP, and

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Defendant NATIONWIDE MUTUAL INSURANCE COMPANY, by and through their respective

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counsel of record, Littler Mendelson, PC, hereby stipulate and agree as follows:

LITTLER MENDELSON, P.C.
321 North Clark Street
Suite 1000
Chicago, IL 60654
312.372.5520

JOINT STIPULATION AND PROPOSED
ORDER

(No. 3:17-cv-03702)

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1.

On June 28, 2017, Plaintiffs filed a Complaint alleging that Defendant violated

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various California wage and hour laws with respect to the terms and conditions of Plaintiffs’

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employment.

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2.

On June 29, 2017, this matter was initially assigned to Magistrate Judge Sallie Kim.

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Judge Kim ordered the Initial Case Management Conference to take place on October 2, 2017 at

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1:30 p.m. and the Rule 26(f) Report and Case Management Statement to be filed on September 25,

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2017.

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3.

On August 23, 2017, this matter was reassigned from Judge Kim to Judge Edward M.

Chen. (See Doc. # 24, Order Reassigning Case). The reassignment order vacated all hearing dates
and trial dates then presently scheduled.
4.

As of the date of filing of this Stipulation, the Court has not yet rescheduled the date

of the Initial Case Management Conference.
5.

On September 25, 2017, counsel for the parties met telephonically to discuss the

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Initial Case Management Conference and the parties’ anticipated filing of their Rule 26(f) Report

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and the Joint Case Management Statement. Because no Initial Case Management Conference is

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currently scheduled, the parties agreed to request of the Court that the deadlines associated with the

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Initial Case Management Conference be continued.

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6.

The parties therefore request that the parties’ deadline to file a Joint Rule 26(f) Report

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and Joint Case Management Statement, and to serve their respective Rule 26(a) initial disclosures, be

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set to either October 16, 2017 or twenty-one (21) days in advance of the date of the rescheduled

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Initial Case Management Conference, to be determined by the Court, whichever is later.

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LITTLER MENDELSON, P.C.
321 North Clark Street
Suite 1000
Chicago, IL 60654
312.372.5520

JOINT STIPULATION AND PROPOSED
ORDER

2.

(No. 3:17-cv-03702)

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/s/ John S. Hong
JOHN S. HONG
LITTLER MENDELSON, P.C.
Attorneys for Defendant
NATIONWIDE MUTUAL INSURANCE
COMPANY

Dated: September 25, 2017

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Dated: September 25, 2017

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/s/ Chaya Mandelbaum
CHAYA MANDELBAUM
RUDY, EXELROD, ZIEFF & LOWE, L.L.P.
Attorneys for Plaintiff
JULIAN FRASER, et al.

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9/26/17

NO

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RT

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dward
Judge E

R NIA

DATED:

n

M. Che

H

LI

HONORABLE EDWARD M. CHEN
ER
UNITED STATES DISTRICTC
JUDGE

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DERED

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IT IS S

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S DISTRICT
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IT IS SO ORDERED.

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UNIT
ED

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S

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N

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F
D IS T IC T O
R

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LITTLER MENDELSON, P.C.
321 North Clark Street
Suite 1000
Chicago, IL 60654
312.372.5520

JOINT STIPULATION AND PROPOSED
ORDER

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(No. 3:17-cv-03702)

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Firmwide:150226203.2 050511.1191

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LITTLER MENDELSON, P.C.
321 North Clark Street
Suite 1000
Chicago, IL 60654
312.372.5520

JOINT STIPULATION AND PROPOSED
ORDER

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(No. 3:17-cv-03702)