Aston v. United Parcel Service, Inc.

          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 ...