Yousuf v. Robert A Bothman, Inc.

Filing 47

ORDER GRANTING 46 STIPULATION TO EXTEND TIME TO COMPLETE DEPOSITIONS. Signed by Judge Edward J. Davila on 12/4/2017. (ejdlc2S, COURT STAFF) (Filed on 12/4/2017)

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Amy Carlson (Bar No. CA 213294)
EMPLOYMENT RIGHTS ATTORNEYS, LLP
1500 E. Hamilton Ave., Suite 118
Campbell, California 95008
Tel: [phone]
Fax: [phone]
Attorneys for Plaintiff, Saeed Yousuf
John C. Fox (Bar No. CA 135668)
Alexa L. Morgan (Bar No. CA 234911)
Christopher W. Loweth (Bar No. CA 20185)
FOX, WANG & MORGAN P.C.
315 University Avenue
Los Gatos, CA 95030
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants Robert A. Bothman, Inc., a California
Corporation; Robert A. Bothman, Inc., a Stakeholder Equity Participation
Plan; Robert A. Bothman, Inc. Deferred Compensation Plan, an ERISA
Pension or Trust

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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)
)
Plaintiff,
)
vs.
)
)
ROBERT A. BOTHMAN, INC., a California )
Corporation;
)
ROBERT A. BOTHMAN, INC., Stakeholder )
Equity Participation Plan;
)
ROBERT A. BOTHMAN, INC. DEFERRED )
COMPENSATION PLAN, an ERISA Pension )
or Trust
)
Defendant.
)
)
SAEED YOUSUF,

Case Number: 5:16-cv-05098-EJD

STIPULATION & [PROPOSED] ORDER
EXTENDING TIME TO COMPLETE
NOTICED DEPOSITIONS

Plaintiff SAEED YOUSUF and Defendants ROBERT A. BOTHMAN, INC., ROBERT

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A. BOTHMAN, INC., Stakeholder Equity Participation Plan, and ROBERT A. BOTHMAN

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INC. Deferred Compensation Plan, an ERISA Pension or Trust (collectively referred to as the

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“Parties), through their respective counsel, hereby stipulate as follows:

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Page 1 of 4
Stip. and Proposed Order – Yousuf v. Robert A. Bothman, Inc.

5:16-cv-05098-EJD

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WHEREAS, on January 25, 2017, the Parties filed their Joint Case Management
Statement setting forth discovery cut-off dates [Dkt. 19]; and
WHEREAS, on March 31, 2017 this Court issued an Order setting forth the requested

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discovery cut-offs, including ordering that fact discovery was to be completed by January 1,

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2018 [Dkt. 25]; and

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WHEREAS, on November 22, 2017, the parties filed a Joint Stipulation asking the Court
to appoint a Court-sponsored mediator [Dkt. 43]; and

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WHEREAS, the parties have diligently been pursuing discovery, including propounding

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and responding to requests to produce, requests to admit, interrogatories, and issuing deposition

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notices for Plaintiff Saeed Yousuf and Defendant witnesses Robert Bothman and John Fox; and

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WHEREAS, on November 28, 2017, the Court issued an order appointing W. George
Wailes as mediator [Dkt. 45]; and

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WHEREAS, no trial date is currently on calendar [Dkt. 25];

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THEREFORE, in order to reduce potential litigation costs and allow mediation to occur

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before depositions move forward, the Parties hereby stipulate as follows:
[1.]

The Court shall issue a Stipulated Order allowing the parties to take the currently

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noticed depositions of Saeed Yousuf, Robert Bothman, and John Fox after the close of discovery

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after mediation in front of W. George Wailes is concluded;

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[2.]

The current Fact Discovery Cutoff of January 1, 2018 shall remain intact.

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Dated: December 1, 2017

/s/ Amy Carlson
Amy Carlson, Esq.
EMPLOYMENT RIGHTS ATTORNEYS, LLP
Counsel for Plaintiff

Dated: December 1, 2017

/s/ Christopher W. Loweth
John C. Fox, Esq.
Alexa Morgan, Esq.
Christopher W. Loweth, Esq.
FOX, WANG & MORGAN P.C.
Counsel for Defendants

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Stip. and Proposed Order – Yousuf v. Robert A. Bothman, Inc.

5:16-cv-05098-EJD

[PROPOSED] ORDER

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Counsel for the Parties in the above-captioned action submitted a Joint Stipulation to

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allow the currently noticed depositions of Saeed Yousuf, Robert Bothman, and John Fox to go

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forward after the close of fact discovery, currently set for January 1, 2018, pending completion

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of mediation. All other dates, including the January 1, 2018 close of discovery, set by this

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Court’s Case Management Order of March 31, 2017 shall remain. [In addition, the Court makes

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the further orders stated below:]

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IT IS SO ORDERED.
Dated: December 4, 2017
UNITED STATES DISTRICT JUDGE

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Stip. and Proposed Order – Yousuf v. Robert A. Bothman, Inc.

5:16-cv-05098-EJD

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CERTIFICATE OF SERVICE
I hereby certify that I electronically filed the foregoing STIPULATION & [PROPOSED]

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ORDER EXTENDING TIME TO COMPLETE NOTICED DEPOSITIONS with the Clerk of

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the Court for the United States District Court for the Northern District of California using the

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CM/ECF system on December 1, 2017.

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I certify that all participants in the case are registered CM/ECF users and that service will
be accomplished by the CM/ECF system, which sends notifications of such filing via electronic
mail to all counsel of record.

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Dated: December 1, 2017

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/s/ Christopher W. Loweth
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Christopher W. Loweth
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Stip. and Proposed Order – Yousuf v. Robert A. Bothman, Inc.

5:16-cv-05098-EJD