The opinion of the court was delivered by: The Honorable Richard Seeborg U.S. District Court for the Northern District of California
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 email@example.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 firstname.lastname@example.org 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
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
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. ...