Equal Employment Opportunity Commission v. Guardsmark, LLC

Filing 18

JOINT STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; ORDER re 17 Stipulation filed by Guardsmark, LLC. 12/20/2011 Case Management Conference continued to 2/14/2012 at 02:00 PM in Courtroom 5, 4th Floor, San Jose. Deadline to conduct mediation 1/15/2012. Signed by Judge Paul S. Grewal on 12/5/2011. (ofr, COURT STAFF) (Filed on 12/5/2011)

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Attorneys for Defendant
GUARDSMARK, LLC

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rewal

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IT IS S DIFIED.
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MARTIN D. BERN (SBN 153203)
[e-mail]
MUNGER, TOLLES & OLSON LLP
560 Mission Street, Twenty-Seventh Floor
San Francisco, CA 94105-2907
Telephone:
[phone]
Facsimile:
[phone]

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION,
Plaintiff,

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v.

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GUARDSMARK, LLC,

CASE NO. CV 11-3190 PSG
JOINT STIPULATION TO CONTINUE
CASE MANAGEMENT CONFERENCE;
[PROPOSED] ORDER
Ctrm.:
Judge:

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Hon. Paul S. Grewal

Defendant.

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Pursuant to Federal Rule of Civil Procedure 16(b), Plaintiff Equal Employment

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Opportunity Commission and Defendant Guardsmark, LLC hereby request an extension of the

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case management hearing and related deadlines as set out in this Court’s November 9, 2011 Order

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[Docket No. 15]. The Scheduling Conference is presently calendared for December 20, 2011.

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Good cause exists for the granting of an extension. First, lead counsel for Defendant has

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been subpoenaed for jury service in Alameda County on December 20, 2011, the date of the case

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management conference in this case. Having already taken one extension, he must attend Court

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on that day. Second, lead counsel for Plaintiff will be on an extended leave beginning the first

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week of January to the beginning of February. Third, counsel have continued to make progress

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in their settlement discussions, and therefore an extension may ultimately save the Court and

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counsel the time and effort which would be expended if the scheduling conference were to go
15823744.2

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JOINT STIPULATION TO CONTINUE CMC;
CASE NO. CV 11-03190 PSG

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forward as currently scheduled.
The Court has granted two previous extensions in this case. Based on the foregoing, the
parties respectfully request that the Court extend the Case Management Dates as follows:

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1/15/12

Deadline to conduct mediation

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2/2/12

Last day to file Rule 26(f) Report, complete initial disclosures or
state objection, and file Case Management Statement

2/2/12

Defendant to respond to complaint

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2/16/12
2/14/12

Initial Case Management Conference (CMC) in Court 5, 4th Floor,
San Jose at 2:00 p.m.

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In addition, counsel for the parties and the mediator have agreed that a continuance of the

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Court’s deadline to mediate would be prudent, given that the parties have continued to exchange

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information and make progress through their own efforts. Accordingly, the parties respectfully

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request an extension of their deadline to mediation from December 15, 2011 to January 15, 2011.

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DATED: November 30, 2011

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By:

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/s/ Martin D. Bern
Martin D. Bern
Attorneys for DEFENDANT
GUARDSMARK, LLC

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By:

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/s/ Linda S. Ordonio Dixon
Linda S. Ordonio Dixon
Attorney for PLAINTIFF EEOC

Signature Attestation

Pursuant to the Court’s General Order 45, Section X.B. regarding Electronic Case Filing, I hereby
attest that Linda S. Ordonio Dixon has authorized the electronic signature which appears above.

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DATED: November 30, 2011

By:

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Attorneys for DEFENDANT
GUARDSMARK, LLC

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/s/ Martin D. Bern
Martin D. Bern

IT IS SO ORDERED.
DATED: December , 2011

By:
U.S. Magistrate Judge

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15823744.2

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JOINT STIPULATION TO CONTINUE CMC;
CASE NO. CV 11-03190 PSG