UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA
April 12, 2012
BRENDA J. BOOKER , PLAINTIFF,
WINDSOR MANOR CONVALESCENT & REHABILITATION OF CONCORD ,
The opinion of the court was delivered by: United States District Judge Maria-Elena R O Judge James
DE CASTRO LAW GROUP, P.C. Jose-Manuel A. de Castro (State Bar No. 213769) 2 firstname.lastname@example.org Lori V. Minassian (State Bar No. 223542) 3 email@example.com 9000 W. Sunset Boulevard, Suite 450 4 Los Angeles, California 90069 Telephone: (310) 270-9877 5 Facsimile: (310) 341-2330 6 Attorneys for Defendant Windsor Convalescent & Rehabilitation Center of Concord, LLC, dba 7 Windsor Manor Convalescent & Rehabilitation Center of Concord 8
STIPULATION AND [PROPOSED] ORDER COMPELING ARBITRATION AND STAYING ACTION
Plaintiff, Brenda Booker, and Defendant, Windsor Convalescent & Rehabilitation Center of Concord, LLC, dba Windsor Manor Convalescent & Rehabilitation Center of Concord, by and 3 through their respective undersigned counsel, hereby stipulate, agree, and jointly request that the 4 Court enter an order, pursuant to Section 2 of the Federal Arbitration Act: 5
1. Compelling the parties to submit all claims and causes of action in this matter to 6 binding arbitration pursuant to the valid and binding written pre-dispute arbitration agreement 7 entered into by the parties; and 8
2. Staying this matter for all purposes pending a motion by Plaintiff or Defendant to 9 confirm or vacate an award entered into in connection with an arbitration of the claims in this matter, 10 or a request, by Plaintiff, for dismissal of this matter.
PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
I am employed in the County of Los Angeles, State of California. I am over the age of 18 years and not a party to the within action. My business address is 9000 W. Sunset Boulevard, Suite 4 450, Los Angeles, California 90069.
On April ___, 2012, I served the foregoing document described as: on the interested parties in this action. 6
by placing the original and/or a true copy thereof enclosed in (a) sealed envelope(s), 7 addressed as follows:
BY REGULAR MAIL: I
deposited such envelope in the mail at 9000 W. Sunset Boulevard, Suite
450, Los Angeles, California 90069. The envelope was mailed with
postage thereon fully prepaid. I am "readily familiar" with my
office's practice of collection and processing correspondence for
mailing. It is deposited with the U.S. Postal Service on that same day
in the ordinary course of business. I am aware that on motion of the
party served, service is presumed invalid if postal cancellation date
or postage meter date is more than one (1) day after date of deposit
for mailing in affidavit.
BY FACSIMILE MACHINE: I transmitted a copy of the original document to
the listed facsimile numbers, as noted below the address for said
addressee(s). BY PERSONAL
SERVICE: I caused such envelope(s) to be delivered by hand to the
listed addressee(s), as noted below the address for said addressee(s).
(State) I declare under penalty of perjury under the laws of the State of California that the 17 foregoing is true and correct.
Executed on April ___, 2012, at Los Angeles, California.
PROOF OF SERVICE
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