STIPULATION AND ORDER TO HOLD VOLUNTARY DISPUTE RESOLUTION PROGRAM SESSION AFTER THE VDRP CUT-OFF

[L.R. 143]

JOHN A. MENDEZ, District Judge.

IT IS HEREBY STIPULATED AND AGREED to by and between the parties to the above-referenced action, through their respective counsel, that Plaintiffs MIGUELINA GARCIA, GERARDO GARCIA and CARLOS GARCIA, Defendant TERRA FIRMA FARMS, INC. and EFRAIN SYLVA CRUZ and Defendant D. CAMPOS, INC. will hold the Voluntary Dispute Resolution Program ("VDRP") session on November 7, 2014 at 9:00 a.m. with the Neutral mediator Scott M. Plamondon of Weintraub Tobin Law Corporation, 400 Capitol Mall, Suite 1100, Sacramento, California 95814. Good cause for the foregoing stipulation exists based on the following:

1. Pursuant to Local Rule 271(j)(1), the VDRP session shall be held as soon as reasonably possible, but no more than ninety-one (91) days after the Neutral is selected, unless otherwise ordered by the Court.

2. Neutral mediator Scott M Plamondon was selected on July 8, 2014.

3. Due to the conflicting schedules of the counsel for all parties and/or the Neutral, a joint telephone conference with the Neutral was not held until September 16, 2014. During this conference, the counsel for all parties and the Neutral agreed to hold the VDRP session on November 7, 2014. This was the earliest date that all parties, their counsel and the Neutral could attend the VDRP session.

IT IS SO STIPULATED

IT IS SO ORDERED.