Marroquin v. Ashron Construction & Restoration, Inc et al

Filing 32

STIPULATION AND ORDER re 31 STIPULATION WITH PROPOSED ORDER CONTINUE MEDIATION DEADLINE filed by Cesar Gonzalez Marroquin, Vincent De La Torre. Signed by Magistrate Judge Howard R. Lloyd on 12/3/2013. (hrllc1, COURT STAFF) (Filed on 12/3/2013)

*E-Filed: December 3, 2013*
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TOMAS E. MARGAIN, Bar No. 193555
HUY TRAN, Bar No. 288196
PHUNG TRUONG, Bar No. 287687
JUSTICE AT WORK LAW GROUP
84 W. Santa Clara St., Ste. 790
San Jose, CA 95113
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Plaintiffs
CESAR GONZALEZ MARROQUIN
and VINCENT DE LA TORRE
Dawna J. Cilluffo [231219]
Chelsea K. Dunton [288742]
DC Law, Dawna J. Cilluffo, A Professional Corp.
2005 De La Cruz Blvd., Suite 215
Santa Clara, CA 95050
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Attorneys for Defendants
ASHRON CONSTRUCTION & RESTORATION, INC.,
EZRA COHEN and U.S. SPECIALTY INSURANCE COMPANY

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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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CESAR GONZALEZ MARROQUIN and
VINCENT DE LA TORRE,

)
)
)
Plaintiffs,
)
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vs.
)
)
ASHRON CONSTRUCTION &
)
RESTORATION, INC.; EZRA COHEN; and )
U.S. SPECIALTY INSURANCE COMPANY, )
)
Defendants.
)
)

Case Number: CV 13-00421 HRL
STIPULATION TO EXTEND
MEDIATION DEADLINE;
ORDER

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STIPULATION TO CONTINUE MEDIATION DEADLINE

Plaintiffs CESAR GONZALEZ MARROQUIN and VINCENT DE LA TORRE and

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Defendants ASHRON CONSTRUCTION & RESTORATION, INC. and EZRA COHEN

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through their attorneys’ of record, hereby stipulate as follows:

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1.

The parties wish to extend the deadline to conduct Court sponsored mediation

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(Currently December 16, 2013) to accommodate a scheduled January 9, 2014

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mediation. No deadlines in the Court’s Case Management Scheduling Conference

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will be disturbed by this stipulation. See Docket 29 CMC Order. Moreover, it will

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allow the parties enough time to complete discovery by the February 5, 2014 cut off.

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It will also allow the parties to schedule a Settlement Conference, if the mediation is

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not successful, well in advance of the April 17, 2014 Pre Trial Conference.
2.

On November 4, 2013, the parties and our assigned mediator Claire Cormier, Esq.

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held our pre-mediating conference. The parties agreed that we need to complete
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written discovery prior to mediation. Given the late December holidays, it was

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agreed that January 9, 2014 was the best date for mediation. That would allow the

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parties almost a month to take depositions if the mediation is not successful. It would

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also allow the parties to propound additional discovery based on the contents of the

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first set of written discovery which are being exchanged.

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3.

The parties request an Order to allow the mediator to occur after the December 16,

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2013 presumptive deadline to January 9, 2014.

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IT IS SO STIPULATED.

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FOR PLAINTIFFS
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DATED:

November 8, 2013

By: //s// Phung Truong
Tomas E. Margain
Phung H. Truong
Attorneys for Plaintiffs
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STIPULATION TO CONTINUE MEDIATION DEADLINE

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FOR DEFENDANTS

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DATED:

November 8, 2013

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By: //s// Dawna Cilluffo
Dawna J. Cilluffo
Attorney for Defendants

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ORDER

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Based on GOOD CAUSE shown, the initial Court Sponsored Mediation deadline is

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continued to January 9, 2014.
IT IS SO ORDERED.

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DATED:

12/3/13

By:
HOWARD R. LLOYD
UNITED STATES MAGISTRATE JUDGE

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STIPULATION TO CONTINUE MEDIATION DEADLINE