Torres v. Compass Group USA, Inc.

Filing 21

STIPULATION AND ORDER TO CONTINUE DEADLINE TO CONDUCT ENE. Signed by Judge ARMSTRONG on 6/27/13. (lrc, COURT STAFF) (Filed on 6/27/2013)

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BETH A. HUBER (SBN 184702)
THE HUBER LAW FIRM
807 E Street
San Rafael, California 94901
Telephone:
[phone]
Facsimile:
[phone]
E-mail: [e-mail]
Attorneys for Plaintiff
MARY GEORGE TORRES

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FRANCIS J. ORTMAN III (SBN 213202)
JUSTIN T. CURLEY (SBN 233287)
SEYFARTH SHAW LLP
560 Mission Street, Suite 3100
San Francisco, California 94105
Telephone:
[phone]
Facsimile:
[phone]
E-mail: [e-mail]
E-mail: [e-mail]

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Attorneys for Defendant
COMPASS GROUP USA, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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Plaintiff,

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Case No. 13-cv-00179-SBA

MARY GEORGE TORRES,

STIPULATION AND ORDER TO
CONTINUE DEADLINE TO CONDUCT
EARLY NEUTRAL EVALUATION

vs.
COMPASS GROUP USA, INC. dba EUREST
DINING SERVICES, and Does 1 through 10
inclusive,

Judge:

Hon. Saundra Brown Armstrong

FAC Filed:
FAC Served:
FAC Removed:

Defendants.

December 12 , 2012
December 13, 2012
January 14, 2013

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Plaintiff Mary George Torres (“Plaintiff”) and Defendant Compass Group USA, dba

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Eurest Dining Services (“Compass”) (together “Parties”), by and through their respective

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counsel, hereby agree and stipulate, and jointly request that the Court enter this stipulation as an

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Order of the Court, as follows:

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This matter was referred to Early Neutral Evaluation via court order on April 25, 2014.
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Stipulation and [Proposed] Order to Continue ENE Deadline

Case No. 13-cv-00179-SBA

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Under ADR L.R. 5-4(b), any such evaluation must be completed within 90 days which is July
24, 2013. The parties have stipulated to continue this deadline an additional 45 days or until
September 9, 2013 and request this order be entered by the Court.
Good cause exists for this continuance in that the parties have exchanged initial
disclosures and a first set of written discovery; however, the parties are continuing to conduct
discovery including the exchange of documents and the taking of depositions. Based upon the
service of said requests and the availability of witnesses, such discovery will likely take place
during July and August 2013. Both parties prefer to conduct this initial round of discovery to
facilitate the effectiveness of the early neutral evaluation process as both parties presently hope
said evaluation will assist in resolving this matter, thus avoiding continued costly litigation.
IT IS SO STIPULATED:

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DATED: June___, 2013

THE HUBER LAW FIRM

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By

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Beth A. Huber
Attorneys for Plaintiff
MARY GEORGE TORRES

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DATED: June__, 2013

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SEYFARTH SHAW LLP
By
Francis J. Ortman III
Justin T. Curley
Attorneys for Defendant
COMPASS GROUP USA, INC.

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IT IS SO ORDERD:

DATED: June 27,2013

By ______________________________
Honorable Saundra Brown Armstrong

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Stipulation and [Proposed] Order to Continue ENE Deadline

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PROOF OF SERVICE
I, Elizabeth Erickson, declare: I am a resident of the United States, over the age of 18
years, and not a party to the above captioned suit. My business address is 807 E Street, San
Rafael, California 94901. I am readily familiar with my offices’ business practices for
collection and processing of correspondence.
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Stipulation and [Proposed] Order to Continue ENE Deadline

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On the date set forth below, I served the following document(s):
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STIPULATION AND [PROPOSED] ORDER TO CONTINUE DEADLINE TO
CONDUCT EARLY NEUTRAL EVALUATION

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X___ (By mail) I caused each of the above document(s) to be placed in a sealed envelope, with
postage thereon fully prepaid, to be deposited this date in San Rafael, California
addressed to each party or parties at the addresses listed below

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____ (By Personal Service) I delivered by hand on this date the above document(s), sealed in an
envelope, to the party listed below at the address indicated.
___ (By Overnight Mail) On this date I placed the above document(s) to be picked up by
California Overnight, an overnight courier service, to deliver to the party or parties listed
below at the address indicated.
__X__ (By Facsimile) I Faxed the above document(s) on this date to the party or parties
indicated below at the fax number indicated.

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__X__ (By E-Mail) I e-mailed the above document(s) on this date to the party or parties
indicated below at the e-mail indicated.

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_X__ By PACER electronic service
Peter R. Boutin
Keesal, Young & Logan
450 Pacific Ave.
San Francisco, CA 94133
E:Mail: [e-mail]

ADR Unit
United States District Court
Northern District of California
450 Golden Gate Ave., 16th Floor
San Francisco, CA 94102
Fax: [phone]

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I declare under penalty of perjury under the laws of the State of California that
the foregoing is true and correct.

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Executed on June 26, 2013 at San Rafael, California.

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_______________________
Elizabeth Erickson

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Stipulation and [Proposed] Order to Continue ENE Deadline

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Stipulation and [Proposed] Order to Continue ENE Deadline

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