United States District Court, N.D. California, Oakland Division
JUSTIN ASTON, STEVEN DE BORBA, and FREDRICK RODRIGUEZ, individually and on behalf of all similarly-situated current and former employees of UNITED PARCEL SERVICE, INC. and UPS GROUND FREIGHT, INC. Plaintiffs,
v.
UNITED PARCEL SERVICE, INC. and UPS GROUND FREIGHT, INC., Defendants.
Justin
Aston, Plaintiff, represented by David Roger Markham, The
Markham Law Firm, Graham Stephen Paul Hollis, GrahamHollis
A.P.C., Joseph E. Jaramillo, Housing and Economic Rights
Advocates, Maggie K. Realin, The Markham Law Firm, Marta
Manus, GrahamHollis APC, Peggy J. Reali, The Markham Law Firm
& Walter Lewis Haines, United Employees Law Group, P.C..
Steven
De Borba, Plaintiff, represented by David Roger Markham, The
Markham Law Firm, Graham Stephen Paul Hollis, GrahamHollis
A.P.C., Joseph E. Jaramillo, Housing and Economic Rights
Advocates, Maggie K. Realin, The Markham Law Firm, Marta
Manus, GrahamHollis APC, Peggy J. Reali, The Markham Law Firm
& Walter Lewis Haines, United Employees Law Group, P.C..
Fredrick Rodriguez, Plaintiff, represented by David Roger
Markham, The Markham Law Firm & Marta Manus, GrahamHollis
APC.
United
Parcel Service, Inc., Defendant, represented by Elizabeth
Alexandra Brown, Grube Brown & Geidt LLP, E. Jeffrey Grube,
Esq., Grube Brown & Geidt LLP & Katherine C. Huibonhoa, Grube
Brown & Geidt LLP.
UPS
Ground Freight, Inc., Defendant, represented by Elizabeth
Alexandra Brown, Grube Brown & Geidt LLP.
JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE:
DEADLINE REGARDING CLASS CERTIFICATION DISCOVERY, FUTHER CASE
MANAGEMENT CONFERENCE, AND HEARING ON PLAINTIFFS' MOTION
FOR CLASS CERTIFICATION
JEFFREY S. WHITE, District Judge.
TO THE
COURT:
By and
through their respective counsel of record, Plaintiffs Steven
E. De Borba and Fredrick Rodriguez ("Plaintiffs")
and Defendants United Parcel Service, Inc. and UPS Ground
Freight, Inc. ("Defendants") (collectively
"the parties") hereby submit this Stipulation and
[Proposed] Order To Continue: Deadline Regarding Class
Certification Discover, Further Case Management Conference,
and Hearing On Plaintiffs' Motion For Class
Certification.
By and
through their respective attorneys of record, the parties
stipulate and agree as follows:
WHEREAS,
on September 11, 2015, the Court scheduled a Further Case
Management Conference and Hearing on Motion for Class
Certification, respectively at 9:00 a.m. and 11:00 a.m.;
WHEREAS,
on March 11, 2016, the parties held a first mediation with
experienced mediator, David Rotman, and at the close of the
session, determined a second mediation was necessary to
attempt to settle the claims;
WHEREAS,
on March 28, 2016, the Court continued the hearing on
Plaintiffs' Motion for Class Certification to September
23, 2016 at 9:00 a.m.;
WHEREAS,
consistent with continuance of the hearing on Plaintiffs'
Motion for Class Certification, the parties requested
additional time to conduct discovery related to class
certification;
WHEREAS,
on May 23, 2016 the Court continued the parties'
discovery deadline related to class ...