Ramirez et al v. Taqueria Santa Rosa #1 et al

Filing 18

STIPULATION AND ORDER EXTENDING DEADLINE TO COMPLETE MEDIATION re 17 Stipulation filed by John V. Colletto, James S. Colletto. Signed by Judge Phyllis J. Hamilton on 8/28/14. (nahS, COURT STAFF) (Filed on 8/28/2014)

ROBERT S. AARON (SBN 138903)
TIMOTHY C. WILSON (SBN 173928)
AARON & WILSON, LLP
150 Post Street, Suite 400
San Francisco, California 94108
Telephone: [phone]
Facsimile:
[phone]
Email:
[e-mail]
[e-mail]
Email:
WILLIAM W. HATCHER, JR., ESQ.
HATCHER & RUNDEL
114 Pierce Street
Santa Rosa, California 95404
Telephone: [phone]
Facsimile:
[phone]
[e-mail]
Email:
Attorneys for Defendants

JAMES S. COLLETTO and JOHN V.
COLLETTO, as Successor Co-trustees of the
JOSEPH S. COLLETTO and ANN D.
COLLETTO TRUST dated November 1, 1988,
specifically as to Trust B of Said Trust

UNITED STATES DISTRICT COURT
ES
NORTHERN DISTRICT OF CALIFORNIA
IRMA RAMIREZ; and DAREN
HEATHERLY,
Plaintiff(s),
v.
TAQUERIA SANTA ROSA #1; JAMES S.
COLLETTO and JOHN V. COLLETTO, as
Successor Co-trustees of the JOSEPH S.
COLLETTO and ANN D. COLLETTO
TRUST, dated November 1, 1988,
specifically as to Trust B of Said Trust; and
FRANCISCO G. SAHAGUN, an individual
dba TAQUERIA SANTA ROSA #1,
Defendant(s).

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Case No. C13-05900-PJH
JOINT STIPULATION TO EXTEND THE
DEADLINE FOR CONDUCTING A
MEDIATION (ADR L.R. 6-5)

Complaint Filed:

December 19, 2013

TO THE HONORABLE COURT:

;met Sop to ExLend Duca= for Medaatiaa953paaltac

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Joint Stipulation to Extend the Deadline for Conducting a Mediation (ADR L.R. 6-5) - Case No. C13-05900-PJH

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The parties hereto, Plaintiffs IRMA RAMIREZ; and DAREN HEATHERLY, and

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Defendants JAMES S. COLLETTO and JOHN V. COLLETTO, as Successor Co-trustees of the

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JOSEPH S. COLLETTO and ANN D. COLLETTO TRUST dated November 1, 1988,

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specifically as to Trust B of Said Trust, and FRANCISCO G. SAHAGUN, an individual dba

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TAQUERIA SANTA ROSA #1, by and through their counsel of record, hereby stipulate as

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follows:

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WHEREAS, this matter was referred to mediation on May 23, 2014;

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WHEREAS, mediator John Vrieze was appointed mediator on June 27, 2014;

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WHEREAS, the joint telephone conference, per ADR L.R. 6.6, was held by mediator

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John Vrieze, with counsel for the various parties, on July 23, 2014, during the course of which

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potential mediation dates were discussed. However, due to trial dates and related commitments,

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plaintiffs' counsel was unavailable on the dates proposed by mediator John Vrieze for the

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mediation.

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WHEREAS, subsequent discussions have yet to result in an exact date for mediation;

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although, the likely date appears to lie in the last part of October or the first part of November,

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2014.

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WHEREAS, the parties have agreed, pending approval by this Court, that the deadline for
conducting the mediation be extended to November 30, 2014.

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WHEREAS, there have been no prior extension of the deadline for conducting the
mediation.

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WHEREAS, Plaintiffs and Defendants do not anticipate that this extension of time will
alter the date of any event or any deadline already fixed by Court order.

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IT IS HEREBY STIPULATED by and between Plaintiffs and Defendants through their
respective counsel of record that the deadline for conducting the mediation be extended to
November 30, 2014.

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///

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///
,cuts to Exlmd ['Male for Molattave.54

16.

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Joint Stipulation to Extend the Deadline for Conducting a Mediation (ADR L.R. 6-5) - Case No. C13-05900-PJH

IT IS SO STIPULATED
AARON & WILSON, LLP

Dated: August 27, 2014

By

/S/

ROBERT S. AARON
Attorneys for Defendants

JAMES S. COLLETTO and JOHN V.
COLLETTO, as Successor Co-trustees of
the JOSEPH S. COLLETTO and ANN
D. COLLETTO TRUST dated November
1, 1988, specifically as to Trust B of Said
Trust
HATCHER & RUNDELL

Dated: August 27, 2014

By

/S/

WILLIAM W. HATCHER, JR.
Attorneys for Defendants

JAMES S. COLLETTO and JOHN V.
COLLETTO, as Successor Co-trustees of
the JOSEPH S. COLLETTO and ANN
D. COLLETTO TRUST dated November
1, 1988, specifically as to Trust B of Said
Trust

THE FRANKOVICH GROUP

Dated: August 27, 2014

By

/S/

THOMAS E. FRANKOVICH
Attorneys for Plaintiffs

IRMA RAMIREZ; and DAREN
HEATHERLY
Dated: August 27, 2014

By

/S/

MARVIN PEDERSON

RT

FO

NO

amilton
yllis J. H

Judge Ph

R NIA

ED

ORDER

IT IS SO

A

H

ER

FRANCISCO G. SAHAGUN, an
individual dba TAQUERIA SANTA
ROSA #1

LI

UNIT
ED

Attorneys for Defendant

S DISTRICT
TE
C
TA

RT
U
O

S

8/28/14

N

F
D IS T IC T O
R

C

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Joint Stipulation to Extend the Deadline for Conducting a Mediation (ADR L.R. 6-5) - Case No. C13-05900-PJH

ATTESTATION

I hereby attest that I have on file all holographic signatures corresponding to any
signatures indicated by a conformed signature (/S/) within this e-filed document.
AARON & WILSON, LLP

Dated: August 27, 2014

By

/S/

ROBERT S. AARON
Attorneys for Defendants

JAMES S. COLLETTO and JOHN V.
COLLETTO, as Successor Co-trustees of
the JOSEPH S. COLLETTO and ANN D.
COLLETTO TRUST dated November 1,
1988, specifically as to Trust B of Said
Trust

hint St, terAload Dud, for Molatim-eSignadoc

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Joint Stipulation to Extend the Deadline for Conducting a Mediation (ADR L.R. 6-5) - Case No. C13-05900-PJH

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CERTIFICATE OF SERVICE

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STATE OF CALIFORNIA, CITY AND COUNTY OF SAN FRANCISCO

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I, Robert S. Aaron, declare:
I am a citizen of the United States, over 18 years of age and not a party to the within
action. I am self-employed in the City and County of San Francisco; my business address is 150
Post Street, Suite 400, San Francisco, California, 94108.
On August 27, 2014, I served the attached and/or enclosed:
JOINT STIPULATION TO EXTEND THE DEADLINE FOR CONDUCTING A
MEDIATION (ADR L.R. 6-5)

on all parties in this action, at the following address(es):
William W. Hatcher, Jr., Esq.
Thomas E. Frankovich, Esq.
Hatcher & Rundel
The Frankovich Group
114 Pierce Street
The Vinyard
4328 Redwood Highway, Suite 300
Santa Rosa, CA 95404
San Rafael, CA 94903
Fax: [phone]
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Tel: [phone]
Email: [e-mail]
Co-Counsel for Defendants, James S. Colletto
and John Colletto, as Successor Co-trustees of Counsel for Plaintiffs, Irma Ramirez and Daren
the Joseph S. Colletto and Arm D. Colletto
Heatherly
Trust dated November 1, 1988, specifically as
to Trust B of Said Trust

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Marvin Pederson, Esq.
1160 North Dutton Avenue, Suite 150
Santa Rosa, CA 95401
Fax: [phone]
Tel: [phone]
Email: [e-mail]
Counsel for Co-Defendant, Taqueria Santa Rosa

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Service was accomplished by causing either an original or a true copy of the abovereferenced document(s) to be distributed as follows:
BY MAIL: I caused such document(s) to be placed in a sealed envelope, addressed as
u
indicated above, with prepaid first-class postage thereon, and then placed the envelope(s) for
collection and mailing, in accordance with the firm's ordinary business practice. I am readily
familiar with the firm's ordinary business practice for collection and processing of
correspondence for mailing with the United States Postal Service. Under that practice
correspondence for mailing is deposited with United States Postal Service on the date indicated
for service, with prepaid first-class postage thereon.

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BY HAND DELIVERY: I caused such documents to be hand delivered to the addresses
u
indicated above.

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VIA FACSIMILE: I caused such documents to be transmitted via facsimile to the parties
u
indicated above, at their respective facsimile numbers.

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lointStp Extend INacIla for Mediation-eSigneicbc

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Joint Stipulation to Extend the Deadline for Conducting a Mediation (ADR L.R. 6-5) - Case No. C13-05900-PJH

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VIA EXPRESS CARRIER: I caused such documents to be collected by an agent for the
United States Postal Service, United Parcel Service, Federal Express or other overnight carrier,
to be delivered by way of overnight mail to the addresses indicated above.
E-MAIL. I caused such documents to be transmitted via e-mail to the parties indicated
above, at their respective e-mail addresses through the E-Filing website.
I declare under penalty of perjury under the laws of the State of California, that the
foregoing is true and correct.
Executed on August 27, 2014, at San Francisco, California.

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/S/

Robert S. Aaron

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Riot Sbp to Extend Oraellinc for Mcdatioa-aipoidsc

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Joint Stipulation to Extend the Deadline for Conducting a Mediation (ADR L.R. 6-5) - Case No. C13-05900-PJH