LAFAYETTE & KUMAGAI LLP, GARY T. LAFAYETTE, BRIAN H. CHUN, San Francisco, California. Attorneys for Defendant UNITED PARCEL SERVICE, INC.
WILLIAM R. TAMAYO, JONATHAN T. PECK, U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, San Francisco District Office, San Francisco, CA, Attorneys for Plaintiff, EQUAL EMPLOYMENT OPPORTUNITY COMMISSION
STIPULATION AND REQUEST TO EXTEND DEADLINE FOR CONDUCTING MEDIATION; [PROPOSED] ORDER
JEFFREY S. WHITE, District Judge.
STIPULATION AND REQUEST
Plaintiff Equal Employment Opportunity Commission ("Plaintiff") and Defendant United Parcel Service, Inc. ("Defendant") (collectively referred to as the "Parties") through their respective counsel hereby stipulate and request as follows:
WHEREAS on January 14, 2013, the Court issued an Order referring the Parties to a court-provided mediation pursuant to stipulation of the Parties;
WHEREAS on March 26, 2013, the Court granted the Parties stipulated request to extend the deadline for conducting mediation from April 15, 2013 to June 18, 2013 in order to give the Parties sufficient time to conduct initial discovery prior to the mediation;
WHEREAS on April 16, 2013, Plaintiff issued to Charging Party Talal Alfaour ("Charging Party") two right to sue notices relating to the Americans with Disabilities Act ("ADA") allegations contained in Charging Party's complaints filed with Plaintiff;
WHEREAS the Parties believe Charging Party's deadline to pursue his ADA claims is on or about July 18, 2013;
WHEREAS the Parties agree that a mediation would be more productive if it takes place after Charging Party's deadline to pursue his ADA claims; and
WHEREAS the Parties have contacted Eric Grover, the court-appointed mediator, regarding rescheduling the mediation;
NOW, THEREFORE, IT IS HEREBY STIPULATED AND REQUESTED by and between the Parties through their respective attorneys of record that the deadline to conduct mediation be extended from June 18, 2013 to August 16, 2013.
Good cause appearing therefor and pursuant to the parties' stipulation, it is hereby ORDERED that the parties' deadline for conducting mediation be extended to August 16, ...