Titus et al v. Humboldt County Fair Association et al
Filing
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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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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
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PROFESSIONAL CORPORATION
ANDRADA & ASSOCIATES
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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
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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Case No.: 4:14-cv-01043-SBA
STUART P. TITUS, CAROLINE TITUS,
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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,
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Defendants.
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1.
The parties hereto – plaintiffs Stuart and Caroline Titus and defendants Humboldt
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County Fair Association, John Burger, Jeff Farley and Cindy Olsen – join in this Stipulation to
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request that the court allow them to move the date for completion of the mediation, and reschedule
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the Case Management Conference to allow them to first complete some initial depositions and
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mediation.
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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.
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{00100161.DOC/}CFSA 1072
JOINT STIPULATION
Titus
v. Humboldt County Fair Association, et al.
4:14-cv-01043-SBA
3.
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The firm known as Foster Employment Law represented the defendants at that time.
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There was a Rule 26 Disclosure by both sides. There was also an additional disclosure of documents
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by both sides. Some interrogatories were also served by both sides.
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The parties then agreed to mediate the case on or by December 19, 2014. Pursuant to
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a stipulation of the parties, the court entered an order on September 2, 2014 to set December 19 as
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the mediation completion date. The court also scheduled a Case Management Conference for
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January 8, 2015.
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5.
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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
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6.
The court appointed Mr. Robert Edwards to serve as mediator on October 15, 2014.
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7.
The attorneys have met and conferred among themselves and with Mr. Edwards to
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select a mediation date in light of all the circumstances. The agreed upon date is March 13, 2015.
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The parties are continuing to engage in discovery. It is anticipated that the plaintiffs will be deposed
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in January, 2015.
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8.
Accordingly, the parties respectfully request that: 1) the court revise the mediation
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completion date to March 13, 2015; and 2) the court continue the Case Management Conference
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presently set for January 8, 2015 to a date after March 13. The parties suggest the date of March 26,
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2015.
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Dated:
December 4, 2014
ANDRADA & ASSOCIATES
/s/ J. Randall Andrada
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By
J. RANDALL ANDRADA
Attorneys for Defendants
HUMBOLDT COUNTY FAIR
ASSOCIATION, JEFF FARLEY, CINDY
OLSEN, and JOHN BURGER
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Dated:
December 4, 2014
/s/ Peter E. Martin
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By
PETER E. MARTIN
Attorneys for Plaintiffs
STUART TITUS and CAROLINE TITUS
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{00100161.DOC/}CFSA 1072
JOINT STIPULATION
Titus
v. Humboldt County Fair Association, et al.
4:14-cv-01043-SBA
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ORDER
Having considered the Stipulation of the parties, the Court orders that: (1) the mediation
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completion date is reset to March 13, 2015; and (2) the Case Management Conference is rescheduled
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to March 26, 2015 at 3:00 p.m. The parties shall meet and confer prior to the conference and shall
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prepare a joint Case Management Statement which shall be filed no later than seven (7) days prior to
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the Case Management Conference that complies with the Standing Order for All Judges of the
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Northern District of California and the Standing Order of this Court. Plaintiffs shall be responsible
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for filing the statement as well as for arranging the conference call. All parties shall be on line and
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shall call (510) 879-3550 at the above indicated date and time.
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IT IS SO ORDERED.
PROFESSIONAL CORPORATION
ANDRADA & ASSOCIATES
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DATED: December 8, 2014
Judge Saundra Brown Armstrong
United States District Judge
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{00100161.DOC/}CFSA 1072
JOINT STIPULATION
Titus
v. Humboldt County Fair Association, et al.
4:14-cv-01043-SBA
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