Padayhag v. Ferguson Enterprises, Inc.

Filing 22

JOINT STIPULATION AND ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE (approving 21 ). Initial Case Management Conference set for 2/18/2016 09:00 AM in Courtroom 3, 5th Floor, San Jose. (blflc1, COURT STAFF) (Filed on 1/20/2016)

1

(Counsel of record on next page)

2
3
4
5
6
7
8

UNITED STATES DISTRICT COURT

9

NORTHERN DISTRICT OF CALIFORNIA

10
11

ERIC PADAYHAG,
Plaintiff,

12
13
14
15

vs.

CASE NO. 5:15-CV-04561 BLF
JOINT STIPULATION AND [PROPOSED]
ORDER TO CONTINUE CASE
MANAGEMENT CONFERENCE

FERGUSON ENTERPRISES, INC.; and
DOES 1 to 25,
Defendants.

16
17
18
19
20
21
22
23
24
25
26
27
28
JOINT STIPULATION & ORDER TO CONTINUE
CASE MANAGEMENT CONFERENCE
U.S.D.C., N.D. Cal., No. 5:15-cv-04561 BLF
LEGAL_US_W # 84752593.1

1
2
3
4

JASON M. ERLICH (SB# 203661)
[e-mail]
MCCORMACK AND ERLICH, LLP
150 Post Street, Suite 742
San Francisco, CA 94108
Telephone: [phone]
Facsimile: (415) 296-85552

5
6
7
8
9
10
11

Attorney for Plaintiff
ERIC PADAYHAG
LESLIE L. ABBOTT (SB# 155597)
[e-mail]
PAUL HASTINGS LLP
515 South Flower Street
Twenty-Fifth Floor
Los Angeles, CA 90071-2228
Telephone: [phone]
Facsimile: [phone]

12
13
14
15
16
17
18
19

PAUL W. CANE, JR. (SB# 100458)
[e-mail]
ZINA DELDAR (SB# 282637)
[e-mail]
PAUL HASTINGS LLP
55 Second Street
Twenty-Fourth Floor
San Francisco, CA 94105-3441
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
FERGUSON ENTERPRISES, INC.

20
21
22
23
24
25
26
27
28
JOINT STIPULATION & ORDER TO CONTINUE
CASE MANAGEMENT CONFERENCE
U.S.D.C., N.D. Cal., No. 5:15-cv-04561 BLF
LEGAL_US_W # 84752593.1

1
2
3

JOINT STIPULATION
Plaintiff Eric Padayhag and Defendant Ferguson Enterprises, Inc. (“Ferguson”), acting
through their respective counsel of record, hereby stipulate as follows:

4

1.

The parties have scheduled a private mediation on January 28, 2016.

5

2.

The Court has scheduled the Initial Case Management Conference for February 4,

6

2016, at 11:00 a.m., and the parties’ Joint Case Management Statement is due on January 28, the

7

same day as the mediation. In addition, the Defendant’s Motion to Compel Arbitration is

8

currently scheduled for hearing just two weeks later, on February 18, 2016 at 9:00 a.m.

9

3.

In order to save the parties’ and the Court’s time and resources, Plaintiff and

10

Defendant respectfully request that the Initial Case Management Conference be continued to

11

February 18, 2016, at 9:00 a.m., or thereafter at the Court’s convenience, with a Joint Case

12

Management Statement due one week before the rescheduled Initial Case Management

13

Conference.

14
15

DATED: January 19, 2016

McCORMACK AND ERLICH, LLP

16
By:

/s/ Jason M. Erlich
Jason M. Erlich
Attorneys for Plaintiff
ERIC PADAYHAG

17
18
19
20

DATED: January 19, 2016

21

PAUL HASTINGS LLP
By:

/s/ Zina Deldar
Zina Deldar

22

Attorneys for Defendant
FERGUSON ENTERPRISES, INC.

23
24
25
26
27
28

-1LEGAL_US_W # 84752593.1

JOINT STIPULATION & ORDER TO CONTINUE
CASE MANAGEMENT CONFERENCE
U.S.D.C., N.D. CAL., NO. 5:15-CV-04561 BLF

1

ORDER

2

On the stipulation of the parties, and good cause appearing therefor,

3

IT IS ORDERED that the Initial Case Management Conference on February 4, 2016 at

4

11:00 a.m. in this action is continued to ________ ___________, 2016 at ________ [a.m./p.m.].

5

The Joint Case Management Statement is to be filed one week prior to the Initial Case

6

Management Conference.

7

Dated:__________________

8
Hon. Beth Labson Freeman
United States District Judge

9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
-1LEGAL_US_W # 84752593.1

JOINT STIPULATION & ORDER TO CONTINUE
CASE MANAGEMENT CONFERENCE
U.S.D.C., N.D. CAL., NO. 5:15-CV-04561 BLF