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Rebecca Cooper, An Individual v. United Parcel Service of America

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION


November 18, 2011

REBECCA COOPER, AN INDIVIDUAL, PLAINTIFF,
v.
UNITED PARCEL SERVICE OF AMERICA, INC., AND DOES 1-50,
DEFENDANTS.

The opinion of the court was delivered by: Judge: Hon. Charles R. Breyer

WAUKEEN Q. McCOY, ESQ. (SBN: 168228) LAW OFFICES OF WAUKEEN Q. McCOY 703 Market Street, Suite 1407 San Francisco, California 94103 Telephone (415) 675-7705 Facsimile (415) 675-2530 SHYAMALA T. RAJENDER, ESQ. (SBN: 69806) RAJENDER LAW OFFICES 4115 Blackhawk Plaza Circle Suite 100 Danville, CA 94506 Telephone (925) 648-2028 Facsimile (925) 648-2035 Attorneys for Plaintiff REBECCA COOPER VILLARREAL HUTNER & TODD PC LARA VILLARREAL HUTNER, ESQ., Cal. Bar No. 178639 E-Mail: lhutner@vhtattorneys.com JESSICA N. LEAL, ESQ., Cal Bar No. 267232 E-Mail: jleal@vhtattorneys.com 575 Market Street, Suite 300 San Francisco, California 94105 Telephone: 415.543.4200 Facsimile: 415.512.7674 Attorneys for Defendant UNITED PARCEL SERVICE, INC., an Ohio Corporation (erroneously named as "UNITED PARCEL SERVICE OF AMERICA, INC."

JOINT STIPULATION AND [PROPOSED] ORDER TO RESCHEDULE CASE MANAGEMENT CONFERENCE

Date: December 2, 2011 Time: 8:30 a.m.

Plaintiff Rebecca Cooper (hereinafter "Plaintiff"), through her counsel Law Offices of 2 Waukeen Q. McCoy and Rajender Law Offices, and Defendant United Parcel Service, Inc. 3 (erroneously named as United Parcel Service of America, Inc., hereinafter "UPS"), through its 4 counsel Villarreal Hutner & Todd PC, (collectively "the Parties") do hereby agree and stipulate to 5 reschedule the December 2, 2011 case management conference for good cause for the reasons set 6 forth below, and as supported by the Declarations of Waukeen Q. McCoy and Lara Villarreal 7 Hutner. 8

1. On August 26, 2011, Plaintiff's counsel, Waukeen Q. McCoy, noticed the 9 deposition of Plaintiff's former manager Victor Neals for November 2, 2011. This date was 10 selected based on the Parties' availability in advance of the settlement conference initially 11 scheduled with Magistrate Judge Maria Elena James for November 15, 2011. 12

2. On October 31, 2011, Mr. McCoy notified UPS that he had to cancel Mr. Neals's 13 November 2nd deposition due to a conflict. 14

3. As the Parties were unavailable to reschedule Mr. Neals's deposition prior to the November 15th settlement conference with Magistrate Judge James, the Parties stipulated to 16 reschedule the settlement conference. Counsel for the Parties each believed that a settlement 17 conference would be most meaningful after the completion of Mr. Neals's deposition. 18

4. Given the holiday period from Thanksgiving to New Years is UPS's busiest season, 19 the Parties have agreed to reschedule Mr. Neals's deposition to January 10, 2012, which is a time 20 less disruptive to the company's peak season and when all parties and Mr. Neals are available. 21

5. The next date following Mr. Neals's deposition that the Parties and Magistrate 22 Judge James were available for a settlement conference is February 1, 2012. The Parties 23 submitted a joint request that the Court reschedule the settlement conference to February 1, 2012.

The Court granted this request on November 4, 2011.

6. A case management conference is currently on calendar for December 2, 2011.

This conference initially was set to occur after the originally scheduled settlement conference if 27 the Parties were unable to resolve the case on November 15, 2011. Now that the settlement 28 conference has been rescheduled for February 1, 2012, the Parties respectfully submit this joint 2 request that the Court reschedule the case management conference to a date after February 1, 3 2012.

7. Counsel for the Parties each believe that a case management conference will be 5 most meaningful after the completion of the February 1, 2012 settlement conference with Magistrate Judge James.

As a result, the request to reschedule the December 2, 2011 case 7 management conference is being made jointly, for good cause, and by stipulation.

SO STIPULATED: 10

IT IS SO ORDERED that: 2

1. The December 2, 2011 case management conference is taken off calendar. 3

2. The Parties' next case management conference will be rescheduled after the February 1, 2012 settlement conference with Magistrate Judge James, on 2012.

February 10 at 8:30 a.m.

By _____________________________________

Honorable Judge Charles R. Breyer

20111118

© 1992-2011 VersusLaw Inc.



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