JAVIER HERRERA, individually and on behalf of all others similarly situated, Plaintiff,
CREDIT BUREAU OF NAPA COUNTY, INC., a California corporation, Defendant.
Jay Edelson, Rafey S. Balabanian, Benjamin H. Richman (Admitted Pro Hac Vice) Christopher L. Dore (Admitted Pro Hac Vice) EDELSON PC Chicago, Illinois, Sean P. Reis (SBN 184044) EDELSON PC, Rancho Santa Margarita, California, Counsel for Plaintiff and the putative class.
Christopher C. Saldaña, Esq. LAW OFFICES OF CHRISTOPHER C. SALDAÑA, San Diego, California, Robert L. Arleo, Esq., New York, New York, One of Defendant's Attorneys
PARTIES' JOINT REPORT REGARDING STATUS OF SETTLEMENT PROCEEDINGS AND REQUEST TO CONTINUE STAY FOR THIRTY DAYS
SUSAN ILLSTON, District Judge.
Plaintiff Javier Herrera and Defendant Credit Bureau of Napa County, Inc. ("CBNC"), by and through their undersigned counsel, and pursuant to the Court's December 11, 2013 Order staying this matter pending private mediation (Dkt. 34), hereby submit the instant joint report regarding the status of settlement proceedings in this matter and state as follows:
By Order entered December 11th, the Court stayed this matter pending the Parties' upcoming private mediation before John B. Bates, Jr. of JAMS (San Francisco) and requested that the Parties file a joint report following the mediation regarding the status of the potential settlement. (Dkt. 34.) On January 14th, the Parties proceeded with an all-day mediation before Mr. Bates and, with his assistance, were able to reach an agreement in principle with respect to the resolution of Herrera's claims against CBNC in this matter. Since the mediation, Herrera's counsel has prepared and circulated to counsel for CBNC a draft written settlement agreement for their review and comments. The Parties anticipate that a written settlement agreement will be finalized and fully executed within fourteen (14) days of the filing of the instant report, and that all conditions precedent to the anticipated dismissal of Herrera's claims will be completed within seven (7) days thereafter.
In light of the foregoing and in order to allow them to focus their efforts and resources on finalizing their settlement, the Parties respectfully request that the Court continue the stay of this case for an additional thirty (30) days, at which point either Plaintiff Herrera will have voluntarily dismissed his claims against CBNC or the Parties will inform ...