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)
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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
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Attorneys for Defendant AT&T Mobility Services, LLC
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN FRANCISCO DIVISION
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CARMEN CRUZ et al.,
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Plaintiffs,
v.
AT&T MOBILITY SERVICES
LLC, a Delaware Limited Liability
Company; and DOES 1-100, jointly
and severally,
Defendants.
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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
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Pursuant to the parties’ June 22, 2012 stipulation and the Court’s June 25,
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2012 Order thereon, a mediation deadline was set for September 4, 2012, applicable
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to the above referenced case and all related/consolidated cases. The Court also
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scheduled a further Case Management Conference for September 17, 2012, at
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which the parties would advise the Court of the mediation results. The parties
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respectfully request jointly that the Court continue this mediation completion
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deadline 60 days, to November 5, 2012, and that the Case Management Conference
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be continued to November 16, 2012.
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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
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Good cause exists to continue the mediation deadline in that the parties have
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engaged in extensive discovery, but further analysis of the parties’ claims and
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defenses is necessary to allow for a productive mediation.
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responded to Defendant’s interrogatories, document requests, and requests for
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admission. Defendants have objected and responded to Plaintiffs’ extensive written
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discovery (91 requests for production of documents by each Plaintiff). Defendants
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have not yet produced documents responsive to these requests, as they await the
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entry of a Protective Order filed by joint stipulation on August 2, 2012. (Additional
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language to the Protective Order was requested by the Court, and the revised
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Protective Order was submitted on August 29, 2012.) In addition, Defendants have
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completed the depositions of eight of the twelve Plaintiffs.
Plaintiffs have
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In addition to the remaining discovery, which will not be complete before the
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September 4, 2012 deadline to complete mediation, the parties need additional time
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to analyze the discovery responses and deposition testimony to develop settlement
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positions in order for mediation to be successful. The parties have tentatively
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reserved October 3, 2012 for a mediation before Susan Haldeman, Esq. in San
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Francisco, this date being subject to the parties’ obtaining in advance the discovery
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necessary to promote a fruitful mediation.
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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
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NOW, THEREFORE, subject to the Court’s approval, the parties, through
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their counsel of record, stipulate and agree that the current September 4, 2012
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mediation deadline shall be continued to November 5, 2012, and that the Case
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Management Conference currently scheduled for September 17, 2012, shall be
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continued to November 16, 2012.
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Management Conference telephonically, as previously indicated.
The parties intend to appear for this Case
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Dated:
August 30, 2012
CROWELL & MORING LLP
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By: /s/ S. Shane Sagheb_______
S. Shane Sagheb
ssagheb@crowell.com
Attorney for Defendant
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Dated:
August 30, 2012
GREEN BRYANT & FRENCH, LLP
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By: /s/ Joel R. Bryant_______
Joel R. Bryant, Esq.
Jbryant@gbflawyers.com
Attorney for Plaintiffs
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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
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ORDER
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, 2012; and
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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
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S
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______________________________________
Honorable Thelton E. Henderson
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n
rso
. Hende
helton E
Judge T
NO
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RT
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H
ER
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R NIA
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The September 4, 2012 mediation completion deadline is continued to
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THEREFORE, IT IS ORDERED THAT:
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PURSUANT TO STIPULATION, AND GOOD CAUSE APPEARING
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D IS T IC T O
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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
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