Titus et al v. Humboldt County Fair Association et al

Filing 45

ORDER by Judge Saundra Brown Armstrong granting 44 Joint Stipulation and Re Mediation Process, Mediation Completion Date and next Case Management Conference. (ndr, COURT STAFF) (Filed on 12/8/2014)

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1 2 3 4 J. RANDALL ANDRADA (SBN 70000) randrada@andradalaw.com ANDRADA & ASSOCIATES PROFESSIONAL CORPORATION 180 Grand Avenue, Suite 225 Oakland, California 94612 Tel.: (510) 287-4160 Fax: (510) 287-4161 5 6 7 8 9 10 PROFESSIONAL CORPORATION ANDRADA & ASSOCIATES 11 Attorneys for Defendants HUMBOLDT COUNTY FAIR ASSOCIATION, JEFF FARLEY, CINDY OLSEN, AND JOHN BURGER PETER E. MARTIN (SBN 121672) peter@petermartinlaw.com A Law Corporation 917 Third Street Eureka, CA 95501 Tel: (707) 268-0445 Fax: (707) 667-0318 Attorney for Plaintiffs 12 13 UNITED STATES DISTRICT COURT 14 NORTHERN DISTRICT OF CALIFORNIA 15 17 18 19 Case No.: 4:14-cv-01043-SBA STUART P. TITUS, CAROLINE TITUS, 16 Plaintiffs, JOINT STIPULATION AND ORDER RE MEDIATION PROCESS, MEDIATION COMPLETION DATE AND NEXT CASE MANAGEMENT CONFERENCE v. HUMBOLDT COUNTY FAIR ASSOCIATION, JEFF FARLEY, CINDY OLSEN, JOHN BURGER, Does 1 through 10, 20 Defendants. 21 22 1. The parties hereto – plaintiffs Stuart and Caroline Titus and defendants Humboldt 23 County Fair Association, John Burger, Jeff Farley and Cindy Olsen – join in this Stipulation to 24 request that the court allow them to move the date for completion of the mediation, and reschedule 25 the Case Management Conference to allow them to first complete some initial depositions and 26 mediation. 27 28 2. Plaintiffs filed this lawsuit on March 6, 2014. A First Amended Complaint was filed on April 24, 2014. The defendants answered on May 8, 2014. 1 {00100161.DOC/}CFSA 1072 JOINT STIPULATION Titus v. Humboldt County Fair Association, et al. 4:14-cv-01043-SBA 3. 1 The firm known as Foster Employment Law represented the defendants at that time. 2 There was a Rule 26 Disclosure by both sides. There was also an additional disclosure of documents 3 by both sides. Some interrogatories were also served by both sides. 4. 4 The parties then agreed to mediate the case on or by December 19, 2014. Pursuant to 5 a stipulation of the parties, the court entered an order on September 2, 2014 to set December 19 as 6 the mediation completion date. The court also scheduled a Case Management Conference for 7 January 8, 2015. 8 5. 9 10 The firm known as Andrada & Associates substituted into the case for the defendants on or about October 8, 2014. As a practical matter, the substitution meant that the mediation deadline needed to be extended. PROFESSIONAL CORPORATION ANDRADA & ASSOCIATES 11 6. The court appointed Mr. Robert Edwards to serve as mediator on October 15, 2014. 12 7. The attorneys have met and conferred among themselves and with Mr. Edwards to 13 select a mediation date in light of all the circumstances. The agreed upon date is March 13, 2015. 14 The parties are continuing to engage in discovery. It is anticipated that the plaintiffs will be deposed 15 in January, 2015. 16 8. Accordingly, the parties respectfully request that: 1) the court revise the mediation 17 completion date to March 13, 2015; and 2) the court continue the Case Management Conference 18 presently set for January 8, 2015 to a date after March 13. The parties suggest the date of March 26, 19 2015. 20 Dated: December 4, 2014 ANDRADA & ASSOCIATES /s/ J. Randall Andrada 21 By J. RANDALL ANDRADA Attorneys for Defendants HUMBOLDT COUNTY FAIR ASSOCIATION, JEFF FARLEY, CINDY OLSEN, and JOHN BURGER 22 23 24 25 Dated: December 4, 2014 /s/ Peter E. Martin 26 By PETER E. MARTIN Attorneys for Plaintiffs STUART TITUS and CAROLINE TITUS 27 28 2 {00100161.DOC/}CFSA 1072 JOINT STIPULATION Titus v. Humboldt County Fair Association, et al. 4:14-cv-01043-SBA 1 2 ORDER Having considered the Stipulation of the parties, the Court orders that: (1) the mediation 3 completion date is reset to March 13, 2015; and (2) the Case Management Conference is rescheduled 4 to March 26, 2015 at 3:00 p.m. The parties shall meet and confer prior to the conference and shall 5 prepare a joint Case Management Statement which shall be filed no later than seven (7) days prior to 6 the Case Management Conference that complies with the Standing Order for All Judges of the 7 Northern District of California and the Standing Order of this Court. Plaintiffs shall be responsible 8 for filing the statement as well as for arranging the conference call. All parties shall be on line and 9 shall call (510) 879-3550 at the above indicated date and time. 10 IT IS SO ORDERED. PROFESSIONAL CORPORATION ANDRADA & ASSOCIATES 11 12 DATED: December 8, 2014 Judge Saundra Brown Armstrong United States District Judge 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 {00100161.DOC/}CFSA 1072 JOINT STIPULATION Titus v. Humboldt County Fair Association, et al. 4:14-cv-01043-SBA

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