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Jon J. Cordova, An Individual v. Convergys Corporation

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA


August 5, 2011

JON J. CORDOVA, AN INDIVIDUAL, PLAINTIFF,
v.
CONVERGYS CORPORATION, A CORPORATION,
DEFENDANT.

The opinion of the court was delivered by: The Honorable Richard Seeborg U.S. District Court for the Northern District of California

*E-Filed 8/5/11*

GUY O. KORNBLUM [SBN 39974] GUY KORNBLUM & ASSOCIATES 1388 Sutter Street, Suite 820 San Francisco, California 94109 Telephone: (415) 440-7800 Facsimile: (415) 440-7898 gkornblum@kornblumlaw.com PHILLIP A. JARET, ESQ. [SBN 092212] ROBERT S. JARET, ESQ. [SBN 124876] JARET & JARET 1016 Lincoln Avenue San Rafael, California 94901 Telephone: (415) 455-1010 Facsimile: (415) 455-1050 jaretlaw@comcast.net Attorneys for Plaintiff JON J. CORDOVA

STIPULATION AND [PROPOSED] ORDER FOR A HOLD ON CASE-RELATED DATES AND FOR AN INITIAL CASE MANAGEMENT CONFERENCE

which requires the submission of a joint Case Management Conference Statement by August 4, 2011; ("Defendant") currently has until August 10, 2011 to file its responsive pleading; to engage in a formal private mediation before retired Alameda Superior Court Judge Richard Hodge, 8 most likely in September 2011; to or at mediation; by and through their respective counsel, that they jointly request that the Court impose a 75-day hold on 13 this case, during which the parties will not be required to file with the Court or serve on each other any 14 case-related documents which would otherwise be required without this hold, including but not limited 15 to a responsive pleading to the Second Amended Complaint, Initial Disclosures, or any other pleadings.

In the event that this matter is not resolved through mediation, the Court shall schedule an Initial Case Management Conference on October 20, 2011, at 10:00 a.m., or another date convenient with the Case Management Conference and the parties' Rule 26(f) conference shall be conducted on or prior to 21 that date. Assuming the case has not settled and a Request for Dismissal is not submitted to the Court, 22 the Defendant shall file his responsive pleading to Plaintiff's Second Amended Complaint within 21 23 days of the final session of the unsuccessful mediation.

WHEREAS a Case Management Conference is scheduled for August 11, 2011 at 10:00 a.m.,

WHEREAS Plaintiff Jon J. Cordova ("Plaintiff") filed his Second Amended Complaint on July 20, 2011, and pursuant to the Court's July 18, 2011 order, Defendant Convergys Corporation

WHEREAS the parties have continued to engage in settlement discussions, and recently agreed

WHEREAS, the parties are hopeful that this mediation will lead to resolution of this matter prior

THEREFORE, IT IS HEREBY STIPULATED AND AGREED by the Plaintiff and Defendant, The 75-day hold will run from August 4, 2011 through October 18, 2011.

Court's calendar. The parties shall submit a joint Case Management Statement one week prior to the

IT IS SO STIPULATED.

[PROPOSED] ORDER

Based on the request and stipulation of the parties, and for good cause showing, the Court hereby orders a 75-day day hold on litigation, as outlined in the parties' stipulation, while the parties pursue 16 mediation. In the event the case is not resolved through mediation, the Court further orders that a Case Management Conference will be held on October 20, 2011, at 10:00a.m. The parties shall submit a joint Case Management Statement one week prior to the Case Management Conference and the parties' Rule 26(f) conference shall be conducted on or prior to that date. The Defendant shall file his responsive pleading to Plaintiff's Second Amended Complaint within 21 days of 21 the final session of the unsuccessful mediation

20110805

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