Filed: Aug. 16, 2018
Latest Update: Aug. 16, 2018
Summary: JOINT STIPULATION FOR STAY PENDING MEDIATION JON S. TIGAR , District Judge . Plaintiffs Trustees of the Teamsters Benefit Trust and Defendants Leonard Transport, LLC, Pacific Coast Transport, LLC, Kathie Faupel, and Michael Leonard (together, the "Parties"), by and through their respective counsel, hereby stipulate and agree as follows, subject to Court approval. WHEREAS, the Parties have agreed to submit this dispute to mediation before mediator Robert Hirsch, of the Law Offices of Robert
Summary: JOINT STIPULATION FOR STAY PENDING MEDIATION JON S. TIGAR , District Judge . Plaintiffs Trustees of the Teamsters Benefit Trust and Defendants Leonard Transport, LLC, Pacific Coast Transport, LLC, Kathie Faupel, and Michael Leonard (together, the "Parties"), by and through their respective counsel, hereby stipulate and agree as follows, subject to Court approval. WHEREAS, the Parties have agreed to submit this dispute to mediation before mediator Robert Hirsch, of the Law Offices of Robert ..
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JOINT STIPULATION FOR STAY PENDING MEDIATION
JON S. TIGAR, District Judge.
Plaintiffs Trustees of the Teamsters Benefit Trust and Defendants Leonard Transport, LLC, Pacific Coast Transport, LLC, Kathie Faupel, and Michael Leonard (together, the "Parties"), by and through their respective counsel, hereby stipulate and agree as follows, subject to Court approval.
WHEREAS, the Parties have agreed to submit this dispute to mediation before mediator Robert Hirsch, of the Law Offices of Robert Hirsch, in San Francisco. The Parties have scheduled a mediation session on August 20, 2018, and collectively are optimistic about the ability to resolve the case.
WHEREAS, the Parties believe that in order to maximize the likelihood of settlement, it is necessary for the parties to focus on the production and review of documents being produced as part of the mediation, and on researching and preparing comprehensive mediation briefs.
WHEREAS, the Parties believe that in order to maximize the likelihood of a successful mediation, the Parties should focus on tasks related to the mediation, instead of engaging in further law and motion practice, such as a renewed Rule 12(b)(6) motion and potential motions to compel.
WHEREAS, the Parties have met and conferred and agree that a stay up to December 15, 2018, may result in the ultimate resolution of the dispute. The Parties believe that extending the stay for a brief period following the mediation date will allow time for any necessary post-mediation discussions.
WHEREAS, the Parties agree that given the requested stay, the current case management schedule should be vacated and reset.
WHEREAS, if the Parties are unable to resolve the matter, the Parties agree to submit a proposed revised case management schedule to the Court no later than December 21, 2018.
IT IS HEREBY STIPULATED AND AGREED, by and through the parties' respective counsel, as follows:
1. The action is hereby stayed until December 15, 2018;
2. The current case management schedule is vacated; and
3. No later than December 21, 2018, the Parties shall file a proposed revised case management schedule or notice of settlement.
L.R. 5-1(i)(3) Statement
I, Stephanie Platenkamp, attest that all signatories listed herein, and on whose behalf this filing is submitted, concur in this filing's content and have authorized this filing.
__________/S/_______________
Stephanie Platenkamp, Esq.
