Filed: Oct. 28, 2014
Latest Update: Oct. 28, 2014
Summary: STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINES TO ALLOW FOR MEDIATION SUSAN ILLSTON, District Judge. IT IS HEREBY STIPULATED by and between Plaintiff MARIO JAKOSALEM ("Plaintiff") and Defendant AIR SERV CORPORATION ("Defendant") ( collectively the "Parties"), by and through their attorneys of record: WHEREAS, on August 8, 2014 this Court held an initial Case Management Conference; WHEREAS, at the initial Case Management Conference, the following dates were set by the Court: •
Summary: STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINES TO ALLOW FOR MEDIATION SUSAN ILLSTON, District Judge. IT IS HEREBY STIPULATED by and between Plaintiff MARIO JAKOSALEM ("Plaintiff") and Defendant AIR SERV CORPORATION ("Defendant") ( collectively the "Parties"), by and through their attorneys of record: WHEREAS, on August 8, 2014 this Court held an initial Case Management Conference; WHEREAS, at the initial Case Management Conference, the following dates were set by the Court: • D..
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STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINES TO ALLOW FOR MEDIATION
SUSAN ILLSTON, District Judge.
IT IS HEREBY STIPULATED by and between Plaintiff MARIO JAKOSALEM ("Plaintiff") and Defendant AIR SERV CORPORATION ("Defendant") (collectively the "Parties"), by and through their attorneys of record:
WHEREAS, on August 8, 2014 this Court held an initial Case Management Conference;
WHEREAS, at the initial Case Management Conference, the following dates were set by the Court:
• December 8, 2014 — Deadline for Plaintiff to file Motion for Class Certification;
• January 12, 2015 — Deadline for Defendant to file Opposition to Plaintiff's Motion for Class Certification;
• January 26, 2015 — Deadline for Plaintiff to file a reply memorandum in support of Motion for Class Certification; and
• February 13, 2015 at 9:00 a.m. — Hearing on Motion for Class Certification.
WHEREAS, the Parties have agreed to attend a mediation before Mark Rudy on January 23, 2015 at 9:00 a.m. This was Mr. Rudy's first available date for mediation.
WHEREAS, in light of the timing of the mediation, the Parties agree that conducting significant formal discovery and briefing the motion for class certification would be counter-productive and would not encourage resolution of the matter. Accordingly, the Parties have agreed to continue the relevant deadlines subject to Court approval. The parties have exchanged documents and other information and will take any necessary depositions before the January 23, 2015 mediation date.
NOW THEREFORE, IT IS HEREBY STIPULATED by and among the undersigned Parties, through their counsel of record, as follows:
1. All currently scheduled dates, including the date for hearing on Plaintiff's motion for class certification, are vacated pending the Parties January 2015 mediation.
2. The Parties (Plaintiff or Defendant individually or the Parties jointly) will notify the Court within three days of reaching impasse so that new dates for class certification and trial (and all related dates) can be set. If the case does not resolve, the Parties anticipate being ready for certification by July 2015.
3. This Stipulation may be signed in counterparts.
[PROPOSED] ORDER
It is so ordered.
