Ferras v. Husqvarna Construction Products North America, Inc. et al

Filing 36

STIPULATION AND ORDER re 35 STIPULATION WITH PROPOSED ORDER CONTINUING ADR DEADLINE BY THREE WEEKS filed by Gary Ferras. Mediation deadline extended until 10/21/16. Signed by Judge Saundra Brown Armstrong on 9/30/16. (sisS, COURT STAFF) (Filed on 9/30/2016)

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Alan F. Cohen (State Bar No. 194075)
LAW OFFICES OF ALAN F. COHEN
1 Sansome Street, Suite 810
San Francisco, CA 94104
415.984.1943 (tel.)
415.984.1953 (fax)
[e-mail]
Attorney for Plaintiff Gary Ferras
Jason A. Geller (CA SBN 168149)
[e-mail]
Juan C. Araneda (CA SBN 213041)
[e-mail]
FISHER & PHILLIPS LLP
One Embarcadero Center, Suite 2050
San Francisco, CA 94111
Telephone: [phone]
Facsimile: 415/490-9001
Attorneys for Defendant
HUSQVARNA CONSTRUCTION PRODUCTS
NORTH AMERICA, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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GARY FERRAS, an
individual,

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Plaintiff,

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v.

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HUSQVARNA CONSTRUCTION
PRODUCTS NORTH AMERICA, INC.,
HUSQVARNA NORTH AMERICA,
HUSQVARNA GROUP, and
DOES 1 through 100 inclusive,

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Defendants.

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Fed. Ct. Case No. 4:16-CV-01081-SBA
[Removed from Contra Costa County Superior Court, Civil
Case No. C16-00131]
STIPULATION AND [PROPOSED] ORDER
CONTINUING ADR DEADLINE BY
THREE WEEKS

Complaint Filed: January 25, 2016
Trial Date: July 17, 2017

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The parties, Plaintiff Gary Ferras and Defendant Husqvarna Construction Products

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North America, Inc., by and through their attorneys of record, hereby stipulate and request that the

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Court extend the deadline to complete mediation in this action by three weeks after the previous

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Fed. Ct. Case No. 4:16-CV-01081-SBA

STIPULATIOND AND [PROPOSED] ORDER CONTINUING ADR DEADLINE

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deadline due to difficulties accommodating the parties’ schedules. The parties are set for mediation
on October 19, 2016.

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Pursuant to the May 31, 2016 Stipulation and Order Selecting ADR Process, the
parties had agreed to hold the ADR session by September 30, 2016. The parties initially agreed on a
mediation date within that timeframe but had to reschedule due to conflicts that arose after the
parties filed the Stipulation. October 19 was the first date available for all parties, including out-ofstate representatives, counsel, and the mediator. The parties have agreed to mediate on October 19
with the assistance of the mediator appointed by the Court, Kyungah (Kay) Suk. The parties
therefore request that the deadline to complete ADR be continued for three weeks to accommodate
this change. This is the first request to continue the mediation deadline.

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DATED: September 28, 2016

FISHER & PHILLIPS LLP

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By: _____[S]_________________
Jason A. Geller
Juan C. Araneda
Attorneys for Defendant
HUSQVARNA CONSTRUCTION
PRODUCTS NORTH AMERICA, INC.

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DATED: September 28, 2016

LAW OFFICES OF ALAN F. COHEN

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By: _____[S]_________________
ALAN F. COHEN
Attorney for Plaintiff
GARY FERRAS

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///

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///

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///

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Fed. Ct. Case No. 4:16-CV-01081-SBA

STIPULATIOND AND [PROPOSED] ORDER CONTINUING ADR DEADLINE

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[PROPOSED] ORDER

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Good cause appearing from the Parties' stipulation, the Court hereby orders that the
deadline for completing mediation is extended by three weeks to October 21, 2016.

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SO ORDERED.

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9/30/16
Date: __________________

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___________________________________
Honorable Saundra B. Armstrong
UNITED STATES DISTRICT COURT JUDGE

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Fed. Ct. Case No. 4:16-CV-01081-SBA

STIPULATIOND AND [PROPOSED] ORDER CONTINUING ADR DEADLINE