Cranford v. U.S. Foods, Inc. et al

Filing 28

STIPULATION AND ORDER re 27 STIPULATION WITH PROPOSED ORDER to Continue Mediation Deadline (Joint) filed by U.S. Foods, Inc. Signed by Judge Jon S. Tigar on August 29, 2018. (wsn, COURT STAFF) (Filed on 8/29/2018)

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CRABTREE SCHMIDT
Michael R. Dennis (SBN 215970)
1100 - 4th Street, Suite E, 2nd Floor
Modesto, CA 95354
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Plaintiff
ERIC CRANFORD

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SEYFARTH SHAW LLP
Michael A. Wahlander (SBN 260781)
[e-mail]
560 Mission Street, 31st Floor
San Francisco, California 94105
Telephone:
[phone]
Facsimile:
[phone]
SEYFARTH SHAW LLP
Monica Rodriguez (SBN 299026)
[e-mail]
2029 Century Park East, Suite 3500
Los Angeles, California 90067-3021
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendant
US FOODS, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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ERIC CRANFORD,

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Plaintiff,
v.
U.S. FOODS, INC. dba U.S. FOODSERVICE,
INC., a California Corporation; and DOES 1
through 50,

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Defendants.

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Case No. 3:18-cv-00301-JST
JOINT STIPULATION TO CONTINUE
MEDIATION DEADLINE AND
[PROPOSED] ORDER
[Assigned to The Honorable Jon S. Tigar,
Courtroom 9 – 19th Floor]
Complaint Filed: November 27, 2017
Trial Date: September 30, 2019

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JOINT STIPULATION TO CONTINUE MEDIATION DEADLINE / CASE NO. 3:18-CV-00301-JST
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Plaintiff Eric Cranford (“Plaintiff”) and Defendant US Foods, Inc. (“Defendant”) (collectively

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“the Parties”), by and through their counsel, and pursuant to ADR L.R. 6-5 and L.R. 7-12, hereby

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stipulate and jointly request that the Court continue the deadline to complete the mediation in this

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matter, currently set for October 28, 2018. The basis for the Parties’ request is as follows:

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1.

On March 29, 2018, the Court granted the Parties’ stipulation and request for a referral to

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the Northern District of California’s mediation program. (Dkt. No. 15.) The Court set the deadline for

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completing the mediation as October 28, 2018. (Id.)

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2.

On August 22, 2018, the Court appointed Katherine Clark as mediator. (Dkt. No. 24.)

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3.

In August of 2018, Defendant’s lead counsel, Candice Zee, left Seyfarth Shaw.

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Defendant has selected a new lead counsel, Michael A. Wahlander. However, due to Mr. Wahlander’s

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need to familiarize himself with the case, the Parties have postponed Plaintiff’s deposition. Due to

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scheduling conflicts, the Parties cannot reschedule it until November 2018, at the earliest. To ensure the

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mediation is productive, Defendant would like to complete Plaintiff’s deposition before commencing the

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mediation.

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4.

These developments prohibit the Parties from rescheduling the mediation by October 28,

2018, the current mediation deadline.

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5.

The Parties have not previously requested a continuance of any deadlines in this case.

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6.

Given that trial is not set to occur until September 2019, the continuance of the mediation

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date for this short period will not unduly delay the resolution of this matter. Continuing the mediation

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date will also not impact any of the other deadlines currently set in this matter.

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THEREFORE, the Parties STIPULATE and request as follows:

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1.

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD

That the Court extend the mediation deadline to December 28, 2018.

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JOINT STIPULATION TO CONTINUE MEDIATION DEADLINE / CASE NO. 3:18-CV-00301-JST
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DATED: August 28, 2018

CRABTREE SCHMIDT

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By: /s/ Michael R. Dennis
Michael R. Dennis

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DATED: August 28, 2018

SEYFARTH SHAW LLP

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By: /s/ Monica Rodriguez
Michael A. Wahlander
Monica Rodriguez

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Attorneys for Defendant
US FOODS, INC.

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I hereby attest that all signatories indicated by a conformed signature (/s/) have concurred in the filing of
this document.

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/s/ Monica Rodriguez

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Monica Rodriguez

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JOINT STIPULATION TO CONTINUE MEDIATION DEADLINE / CASE NO. 3:18-CV-00301-JST
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[PROPOSED] ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.
in
1.
The mediation deadline is this Action is reset to be completed by December 28, 2018.

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DATED:

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August 29, 2018
JUDGE JON S. TIGAR

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JOINT STIPULATION TO CONTINUE MEDIATION DEADLINE / CASE NO. 3:18-CV-00301-JST
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