Piasecki v. Sanofi Pasteur Inc. et al

Filing 29

ORDER GRANTING STIPULATION TO ENGAGE IN PRIVATE MEDIATION by Judge William Alsup granting 27 Stipulation selecting Mediation.(whalc1, COURT STAFF) (Filed on 12/6/2017)

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Lisa B. Sween (State Bar No. 191155)
Spencer J. Davidson (State Bar No. 281169)
JACKSON LEWIS P.C.
50 Califomia Street, 9th Floor
San Francisco, Califomia 94111-4615
Telephone: [phone]
Facsimile: [phone]
E-mail: lisa.sween@j aclcsonlewis.com
E-mail: [e-mail]
Attomeys for Defendants
SANOFI PASTEUR, INC. and
SANOFI-AVENTIS U.S., LLC

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UNITED STATE DISTIUCT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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Case No. 3:17-cv-04101-WHA

MERCIA PIASECKI,

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STIPULATION BY AND BETWEEN
PLAINTIFF MERCIA PIASECKI AS
WELL AS DEFENDANTS SANOFI
PASTEUR, INC. AND SANOFI-AVENTIS
U.S., LLC TO ENGAGE IN PRIVATE
MEDIATION PRIOR TO A SETTLEMENT
CONFERENCE WITH MAGISTRATE
JUDGE KANDIS WESTMORE;
PROPOSED ORDER THEREON

Plaintiff:

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vs.

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SANOFI PASTEUR, INC., a corporation;
SANOFI-AVENTIS U.S., LLC, a limited
liability corporation; and DOES 1-20,

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Defendants.

Complaint Filed:
Removal Filed:
Trial Date:

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June 20, 2017
July 20, 2017
September 24, 2018

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TO THE COURT, ALL PARTIES, AND THEIR COUNSEL OF RECORD:

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PLEASE TAKE NOTICE that Plaintiff MERCIA PIASECKI ("Plaintiff') along with

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Defendants SANOFI PASTEUR, INC. and SANOFI-AVENTIS U.S., LLC ("Defendants,"

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collectively "the Parties") hereby stipulate and agree as follows:

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WHEREAS on September 25, 2017 the clerk of court served a Notice Setting Telephonic

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Conference, inf01ming the Parties that Magistrate Judge Kandis Westmore had been assigned to

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this matter for settlement purposes, and scheduling a pre-settlement conference telephone call

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with the Pa1ties to take place on November 9, 2017;

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WHEREAS on November 9, 2017, the Pmties appeared through their counsel of record at
STIPULATION TO ENGAGE IN PRIVATE MEDIATION

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PRIOR TO SETTLEMENT CONFERENCE

Case No. 3:17-cv-04101-WHA

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the pre-settlement conference telephone call with Judge Westmore, informing her of the facts and

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posture of the case, as well as the Parties' willingness to engage in alternative dispute resolution

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("ADR");

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WHEREAS during their November

9th

conference with Judge Westmore, the Parties

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informed the Judge that they had met and conferred pertaining to ADR, and reached an agreement

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to engage mediator Jeffrey Ross to conduct a private mediation of this matter in early 2018. The

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mediation session has been confirmed with Mr. Ross' office to occur on February 8, 2018;

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WI-IEREAS the Patties indicated during their conference with Judge Wcstmorc that they

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would prefer to conduct this mediation session in advance of a settlement conference with the

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Court, and reconvene with Judge Westmore after the Febmary 2018 mediation with Mr. Ross

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should a settlement not be reached;

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WHEREAS Judge Westmore indicated that she was amenable to this procedure, should
the Court enter an order allowing the Parties to proceed in this manner;

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IT IS THEREFORE STIPULATED and requested that the Patties be permitted to mediate

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with Jeffrey Ross in advance of any settlement conference with Judge Westmore, and that should

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the Court be so inclined, a fmther status conference be set on a date after February 8, 2018 in

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order to schedule such settlement conference should the Pa1ties fail to reach a mediated

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agreement.

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IT IS SO STIPULATED.
RUDY, EXELROD, ZIEFF & LOWE, LLP

Dated: November 10, 2017

02/~4·~

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Ill

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Ill

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Ill

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STIPULATION TO ENGAGE IN PRIVATE MEDIATION

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PRIOR TO SETTLEMENT CONFERENCE

CoseNo. 3:17-cv-04101-WHA

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JACKSON LEWIS P.C.

Dated: November 10, 2017

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By:

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Lisa Barn
Spencer J.
idson
Attorneys for Defendants
SANOFI A VENTTS U.S., LLC and
SANOFI PASTEUR, INC.

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Pursuant to Local Rule 5-l(i), the filing attorney certifies that this Stipulation is filed with
the consent and concurrence of all signatories identified above.

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PROPOSED ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED. The Parties shall be permitted
to engage in private mediation prior to any settlement conference.

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It is finther ordered: -----------------------------------------------

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December __ _ _
Dated: _ _ __ _ 6, 2017.

By: _ _ _ _ __ _ _ _ _ __ _ _ ____
JUDGE OF THE UNITED STATES DISTRICT
COURT-NORTHERN DISTRICT OF CALIFORNIA

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4833-8572-0660, v. 1

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STIPULATION TO ENGAGE IN PRIVATE MEDIATION

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PRIOR TO SETTLEMENT CONFERENCE

Case No. 3:17-cv-041 01-WHA