Cruz v. AT&T Mobility LLC et al

Filing 56

STIPULATION AND ORDER Continuing Deadline to Complete Mediation and to Continue Case Management Conference. Mediation Deadline is 11/05/2012. Case Management Statement due by 11/9/2012. Further Case Management Conference set for 11/19/2012 01:30 PM in Courtroom 12, 19th Floor, San Francisco. Signed by Judge Thelton E. Henderson on 08/30/2012. (tmi, COURT STAFF) (Filed on 8/31/2012)

Download PDF
1 4 S. Shane Sagheb (State Bar No. 109878) ssagheb@crowell.com CROWELL & MORING LLP 515 S. Flower Street, 40th Floor Los Angeles, CA 90071-2258 Telephone: (213) 622-4750 Facsimile: (213) 622-2690 5 Attorneys for Defendant AT&T Mobility Services, LLC 2 3 6 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 SAN FRANCISCO DIVISION 11 12 CARMEN CRUZ et al., 13 14 15 16 17 Plaintiffs, v. AT&T MOBILITY SERVICES LLC, a Delaware Limited Liability Company; and DOES 1-100, jointly and severally, Defendants. 18 Case No. CV11-04508-TEH STIPULATION AND [PROPOSED] ORDER TO CONTINUE DEADLINE TO COMPLETE MEDIATION AND TO CONTINUE CASE MANAGEMENT CONFERENCE Dept.: Judge: Courtroom 12 Hon. Thelton E. Henderson 19 20 Pursuant to the parties’ June 22, 2012 stipulation and the Court’s June 25, 21 2012 Order thereon, a mediation deadline was set for September 4, 2012, applicable 22 to the above referenced case and all related/consolidated cases. The Court also 23 scheduled a further Case Management Conference for September 17, 2012, at 24 which the parties would advise the Court of the mediation results. The parties 25 respectfully request jointly that the Court continue this mediation completion 26 deadline 60 days, to November 5, 2012, and that the Case Management Conference 27 be continued to November 16, 2012. 28 C ROWELL & M ORING LLP -1- ATTO RNEY S AT LAW DCACTIVE-20547081.1 STIPULATION AND [PROPOSED] ORDER TO CONTINUE MEDIATION DEADLINE; CASE NO. CV11-04508-TEH 1 Good cause exists to continue the mediation deadline in that the parties have 2 engaged in extensive discovery, but further analysis of the parties’ claims and 3 defenses is necessary to allow for a productive mediation. 4 responded to Defendant’s interrogatories, document requests, and requests for 5 admission. Defendants have objected and responded to Plaintiffs’ extensive written 6 discovery (91 requests for production of documents by each Plaintiff). Defendants 7 have not yet produced documents responsive to these requests, as they await the 8 entry of a Protective Order filed by joint stipulation on August 2, 2012. (Additional 9 language to the Protective Order was requested by the Court, and the revised 10 Protective Order was submitted on August 29, 2012.) In addition, Defendants have 11 completed the depositions of eight of the twelve Plaintiffs. Plaintiffs have 12 In addition to the remaining discovery, which will not be complete before the 13 September 4, 2012 deadline to complete mediation, the parties need additional time 14 to analyze the discovery responses and deposition testimony to develop settlement 15 positions in order for mediation to be successful. The parties have tentatively 16 reserved October 3, 2012 for a mediation before Susan Haldeman, Esq. in San 17 Francisco, this date being subject to the parties’ obtaining in advance the discovery 18 necessary to promote a fruitful mediation. 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 /// C ROWELL & M ORING LLP -2- ATTO RNEY S AT LAW DCACTIVE-20547081.1 STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE; CASE NO. CV11-04508-TEH 1 NOW, THEREFORE, subject to the Court’s approval, the parties, through 2 their counsel of record, stipulate and agree that the current September 4, 2012 3 mediation deadline shall be continued to November 5, 2012, and that the Case 4 Management Conference currently scheduled for September 17, 2012, shall be 5 continued to November 16, 2012. 6 Management Conference telephonically, as previously indicated. The parties intend to appear for this Case 7 8 Dated: August 30, 2012 CROWELL & MORING LLP 9 By: /s/ S. Shane Sagheb_______ S. Shane Sagheb ssagheb@crowell.com Attorney for Defendant 10 11 12 Dated: August 30, 2012 GREEN BRYANT & FRENCH, LLP 13 14 By: /s/ Joel R. Bryant_______ Joel R. Bryant, Esq. Jbryant@gbflawyers.com Attorney for Plaintiffs 15 16 17 18 19 20 21 22 23 24 25 26 27 28 C ROWELL & M ORING LLP -3- ATTO RNEY S AT LAW DCACTIVE-20547081.1 STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE; CASE NO. CV11-04508-TEH 1 ORDER 2 1. , 2012; and 6 8 2. The September 17, 2012 Case Management Conference is continued to , 2012 at e parties may appear telephonically. UNIT ED 08/30/2012 Dated: _______________ ISTRIC ES D TC AT T RT U O 10 S 9 ______________________________________ Honorable Thelton E. Henderson 11 n rso . Hende helton E Judge T NO 12 RT 13 H ER 14 R NIA 7 The September 4, 2012 mediation completion deadline is continued to FO 5 THEREFORE, IT IS ORDERED THAT: LI 4 PURSUANT TO STIPULATION, AND GOOD CAUSE APPEARING A 3 N F D IS T IC T O R C 15 16 17 18 19 20 21 22 23 24 25 26 27 28 C ROWELL & M ORING LLP -4- ATTO RNEY S AT LAW DCACTIVE-20547081.1 STIPULATION AND [PROPOSED] ORDER TO CONTINUE MEDIATION DEADLINE; CASE NO. CV11-04508-TEH

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?