Blaszkowski et al v. Mars Inc. et al

Filing 621

STIPULATION and Request for Leave of Court to Use a California Mediator and Schedule a Mediation in California by Natura Pet Products, Inc.. (York, Jeffrey)

Blaszkowski et al v. Mars Inc. et al

Doc. 621

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION CASE NO. 1:07-21221 CIV- ALTONAGA/BROWN RENEE BLASZKOWSKI, et al., individually and on behalf of others similarly situated, Plaintiffs, v. MARS INC., et al., Defendants. ____________________________________. JOINT STIPULATION AND REQUEST FOR LEAVE OF COURT TO USE A CALIFORNIA MEDIATOR AND SCHEDULE A MEDIATION IN CALIFORNIA WHEREAS, pursuant to the Court's Scheduling Order, Plaintiffs Patricia Davis, Cindy Tregoe, Jo-Ann Murphy, and Susan Peters (collectively "Plaintiffs") and Defendant Natura Pet Products, Inc. (collectively "Defendant"), are required to report to the Court if the parties have agreed to mediate and identification of a Court-certified mediator; WHEREAS, the only remaining Defendant has its principal place of business located in San Jose, California; WHEREAS, Plaintiffs and Defendant have agreed to mediate before the Honorable William Cahill, (Retired), a JAMS Mediator, whose office is located in San Francisco, California, in close approximation to San Jose, California; WHEREAS, Plaintiffs and Defendant believe it is in the best interests of the parties to attend mediation before the Honorable William Cahill, (Retired) in California on February 24,

Dockets.Justia.com

2009, and request leave of Court to mediate before the Honorable William Cahill, (Retired) in California on February 24, 2009; WHERAS, the current deadline to conduct and report on mediation is February 23, 2009, and Plaintiffs and Defendant would like until the close of business on February 25, 2009 to report to the Court the outcome of this mediation; WHEREAS, Plaintiffs and Defendant, through their respective counsel hereby stipulate as follows: 1. Plaintiffs and Defendant request leave of Court to attend a full day mediation before the Honorable William Cahill, (Retired) in California on February 24, 2009. 2. Plaintiffs are permitted to appear by telephone; all others to appear in person. 3. Plaintiffs and Defendant shall jointly file a report on the mediation on February 25, 2009. IT IS SO STIPULATED TO AND AGREED BY: Patrick N. Keegan, Esq. KEEGAN & BAKER, LLP 5650 El Camino Real, Suite 120 Carlsbad, CA 92008 E-mail: [e-mail] Attorneys for Plaintiffs

s/Catherine J. MacIvor (with permission)___ Catherine J. MacIvor E-mail: [e-mail] Jeffrey Eric Foreman E-mail: [e-mail] Jeffrey Bradford Maltzman E-mail: [e-mail] Darren W. Friedman E-mail: [e-mail] Bjorg Eikeland E-mail: [e-mail] MALTZMAN FOREMAN PA One Biscayne Tower 2 South Biscayne Boulevard, Suite 2300 Miami, FL 33131-1803 Telephone: [phone] Facsimile: [phone]

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s/Jeffrey S. York___________________ Kristen E. Caverly E-mail: [e-mail] HENDERSON & CAVERLY LLP P.O. Box 9144 16236 San Dieguito Road, Suite 4-13 Rancho Santa Fe, California 92067-9144 Jeffrey S. York E-mail: [e-mail] Michael M. Giel E-mail: [e-mail] McGUIRE WOODS LLP 50 N. Laura Street, Suite 3300 Jacksonville, Florida 32202 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant Natura Pet Products, Inc.

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