Yanushkevich v. Walgreen Co.

Filing 28

ORDER GRANTING STIPULATION TO ENLARGE TIME FOR DEFENDANT WALGREEN CO. TO RESPOND TO PLAINTIFF'S MOTION TO ENFORCE SETTLEMENT AND FOR CONTINUATION OF THE HEARING ON THE MOTION TO ENFORCE SETTLEMENT, granting 27 . 9/2/2016 Motion Hearing is reset to 10/14/2016 at 9:00 AM in Courtroom 6, 4th Floor, San Jose before Hon. Ronald M. Whyte. Response due by 9/23/2016. Reply due by 9/30/2016. Signed by Hon. Ronald M. Whyte on 8/5/2016. (ofr, COURT STAFF) (Filed on 8/5/2016)

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Attorneys for Defendant
WALGREEN CO.

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hyte

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onald M
Judge R

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LAW OFFICE OF IRENE KARBELASHVILI
Irene Karbelashvili, State Bar Number 232223
Irakli Karbelashvili, State Bar Number 302971
12 South First Street, Suite 413
Telephone: [phone]
Fax: [phone]

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Michael D. Thomas (SBN 226129)
[e-mail]
OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.
Steuart Tower, Suite 1300
One Market Plaza
San Francisco, CA 94105
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Telephone:
415.442.4810
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Facsimile:
415.442.4870
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Laura D. Heckathorn (SBN 228861)
[e-mail]
OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.
400 South Hope Street, Suite 1200
Los Angeles, CA 90071
Telephone:
213.239.9800
Facsimile:
213.239.9045

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Attorneys for Plaintiff
DMITRY YANUSHKEVICH

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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DMITRY YANUSHKEVICH,
Plaintiff,

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v.
WALGREEN CO., an Illinois corporation
d/b/a WALGREENS #03344; and DOES 1
through 10, inclusive,

STIPULATION TO ENLARGE TIME FOR
DEFENDANT WALGREEN CO. TO
RESPOND TO PLAINTIFF’S MOTION TO
ENFORCE SETTLEMENT AND FOR
CONTINUATION OF THE HEARING ON
THE MOTION TO ENFORCE
SETTLEMENT

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Date: September 2, 2016
Time: 9:00 a.m.
Crtm: Courtroom 6

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Complaint filed: October 28, 2015

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Defendant.

Case No. 5:15-cv-04964

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Case No. 5:15-cv-04964
STIPULATION TO ENLARGE TIME TO RESPOND TO PLAINTIFF’S MOTION TO ENFORCE SETTLEMENT
AND FOR CONTINUATION OF THE HEARING ON THE MOTION TO ENFORCE SETTLEMENT

This stipulation is entered into by and between Plaintiff Dmitry Yanushkevich (“Plaintiff”),

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on the one hand, and Defendant Walgreen Co. (“Defendant”) (collectively “the Parties), on the

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other hand, by and through their undersigned counsel of record, with reference to the following

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facts and recitals:

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WHEREAS, on July 25, 2016, Plaintiff filed a Notice of Motion and Motion to Enforce
Settlement;

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WHEREAS, on August 2, 2016, the Parties appeared before Mediator Tamara Lange for a
pre-mediation phone conversation.

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WHEREAS, during the August 2, 2016 pre mediation conversation, the Parties began to

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have effective conversations regarding amicably resolving their dispute without the need for

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Plaintiff’s Motion to Enforce Settlement or Mediation;

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WHEREAS, the Parties have agreed to continue settlement conversations to resolve their
disputes with the guidance of the mediator;
WHEREAS, Defendant’s deadline to file an opposition to Plaintiff’s Motion to Enforce

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Settlement is August 8, 2016.
WHEREAS, the hearing on Plaintiff’s Motion to Enforce Settlement is currently scheduled

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for September 2, 2016.

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WHEREAS, the Parties believe it is more efficient to spend their time attempting to resolve
their disputes then engage in Motion practice.

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WHEREAS, this stipulated request is filed more than 14 days before the September 2, 2016
hearing and therefore the stipulation does not violation Civil Local Rule 6-1(b).

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It is therefore STIPULTED AND AGREED, by and between the undersigned counsel and

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pursuant to Civil Local Rule 6-2, that the time for Defendant to oppose Plaintiff’s Motion to

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Enforce Settlement shall be continued to September 23, 2016 and the hearing on Plaintiff’s Motion

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Case No. 5:15-cv-04964
STIPULATION TO ENLARGE TIME TO RESPOND TO PLAINTIFF’S MOTION TO ENFORCE SETTLEMENT
AND FOR CONTINUATION OF THE HEARING ON THE MOTION TO ENFORCE SETTLEMENT

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to Enforce Settlement shall be continued to October 14, 2016. Plaintiff may also submit a Reply

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brief per the Local Rules and the Federal Rules of Civil Procedure.

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DATED: August 4, 2016

OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.

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By:

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/s/ Michael D. Thomas
Laura D. Heckathorn
Michael D. Thomas

Attorneys for Defendant
WALGREEN CO.

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DATED: August 4, 2016

LAW OFFICE OF IRENE KARBELASHVILI

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By:

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/s/ Irene Karbelashvili
Irene Karbelashvili
Irakli Karbelashvili

Attorneys for Plaintiff
DMITRY YANUSHKEVICH

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SIGNATURE ATTESTATION

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Pursuant to Civil Local Rule 5-1(i)(3), I attest that concurrence in the filing of this

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document has been obtained from the other signatories.

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DATED: August 4, 2016

By:

/s/ Michael D. Thomas

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Case No. 5:15-cv-04964
STIPULATION TO ENLARGE TIME TO RESPOND TO PLAINTIFF’S MOTION TO ENFORCE SETTLEMENT
AND FOR CONTINUATION OF THE HEARING ON THE MOTION TO ENFORCE SETTLEMENT