Filed: Sep. 06, 2019
Latest Update: Sep. 06, 2019
Summary: CORRECTED STIPULATION AND JOINT REQUEST TO CONTINUE STAY UNTIL OCTOBER 21, 2019 AND [ PROPOSED ] ORDER ANTHONY W. ISHII , District Judge . TO THE HONORABLE DISTRICT COURT JUDGE, MAGISTRATE JUDGE, ALL PARTIES, AND THEIR ATTORNEYS OF RECOR Plaintiff U.S. Equal Employment Opportunity Commission ("Plaintiff") and Defendant PAQ, Inc., d/b/a Rancho San Miguel Markets ("Defendant") (collectively, "the Parties"), through their respective counsel of record, submit the following Stipulation and
Summary: CORRECTED STIPULATION AND JOINT REQUEST TO CONTINUE STAY UNTIL OCTOBER 21, 2019 AND [ PROPOSED ] ORDER ANTHONY W. ISHII , District Judge . TO THE HONORABLE DISTRICT COURT JUDGE, MAGISTRATE JUDGE, ALL PARTIES, AND THEIR ATTORNEYS OF RECOR Plaintiff U.S. Equal Employment Opportunity Commission ("Plaintiff") and Defendant PAQ, Inc., d/b/a Rancho San Miguel Markets ("Defendant") (collectively, "the Parties"), through their respective counsel of record, submit the following Stipulation and ..
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CORRECTED STIPULATION AND JOINT REQUEST TO CONTINUE STAY UNTIL OCTOBER 21, 2019 AND [PROPOSED] ORDER
ANTHONY W. ISHII, District Judge.
TO THE HONORABLE DISTRICT COURT JUDGE, MAGISTRATE JUDGE, ALL PARTIES, AND THEIR ATTORNEYS OF RECOR
Plaintiff U.S. Equal Employment Opportunity Commission ("Plaintiff") and Defendant PAQ, Inc., d/b/a Rancho San Miguel Markets ("Defendant") (collectively, "the Parties"), through their respective counsel of record, submit the following Stipulation and Joint Request to Continue Stay Until October 21, 2019. The Parties are currently negotiating the terms of the Proposed Consent Decree for this Court's consideration and approval. Plaintiff provided Defendant with a proposed consent decree in advance of mediation and although the Parties agreed to a monetary settlement, considerable disagreements remained regarding the scope of the consent decree. Following the June 24, 2019 mediation, Defendant provided a new proposed consent decree to Plaintiff on July 22, 2019. The Parties discussed Defendant's proposed consent decree in detail and on September 3, 2019, Plaintiff provided Defendant with a redlined version of Defendant's proposed consent decree. Because Defense counsel has a two-week trial set to begin September 23, 2019, the Parties realistically expect that the proposed consent decree will not be ready for this Court's review and approval until late October or early November 2019.
Accordingly, to conserve resources and focus their attention on finalizing the terms of the Proposed Consent Decree, the Parties respectfully request that the Court stay this matter at least until October 21, 2019, to allow the Parties to continue negotiations and file the Proposed Consent Decree.
IT IS SO STIPULATED
Respectfully submitted,
Dated: September 5, 2019.
/s/ Andrea E. Ringer
Andrea E. Ringer
Trial Attorney
U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION
Dated: September 5, 2019. /s/ Vladimir J. Kozina
Vladimir J. Kozina
Attorney for Defendant PAQ, INC. d/b/a
RANCHO SAN MIGUEL MARKETS
[PROPOSED] ORDER
Upon good cause appearing, IT IS SO ORDERED that due to the settlement agreement and ongoing settlement negotiations between Plaintiff U.S. Equal Employment Opportunity Commission and Defendant PAQ, Inc., d/b/a Rancho San Miguel Markets, the Court hereby continues the stay of this litigation and directs the parties to file a Proposed Consent Decree or a status update no later than October 21, 2019.
IT IS SO ORDERED.
