Opinion
DENNIS M. BROWN, MARLENE S. MURACO, ANNE SWEENEY JORDAN, LITTLER MENDELSON, P.C., San Jose, California, Attorneys for Defendant AIRGAS ON-SITE SAFETY SERVICES, INC.
SHAUN SETAREH, ADRIENNE HERRERA, SETAREH LAW GROUP, Beverly Hills, CA, Attorneys for Plaintiffs DIANE BROWN; KIERRE TOWNSEND.
TRACY WEI COSTANTINO, JEFFREY S. RANEN, LEWIS BRISBOIS BISGAARD & SMITH LLP, Los Angeles, CA, Attorneys for Defendant GULF SOUTH SAFETY CONSULTANTS, LLC.
Tracy Wei Costantino, LEWIS BRISBOIS BISGAARD & SMITH LLP, Attorneys for Defendants GULF SOUTH SAFETY CONSULTANTS, LLC.
JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE STAY PENDING SETTLEMENT
JON S. TIGAR, District Judge.
Plaintiffs DIANE BROWN and KIERRE TOWNSEND ("Plaintiffs"), Defendant AIRGAS ON-SITE SAFETY SERVICES, INC. ("AOSS") and Defendant GULF SOUTH SAFETY CONSULTANTS, LLC ("Gulf South") (collectively referred to herein as the "Parties"), by and through their respective counsel of record, hereby stipulate and agree as follows:
1. WHEREAS, the Court issued an Order on May 14, 2014, staying formal discovery and all deadlines in this case until the Parties attended private mediation in August 2014 (Dkt. No. 21);
2. WHEREAS, the Court's Order continued the Case Management Conference previously scheduled for May 28, 2014 until September 11, 2014, at which time the stay will dissolve (Dkt. No. 21);
3. WHEREAS, on August 12, 2014, the Parties attended private mediation with mediator Mark S. Rudy in San Francisco, California, in an attempt to resolve both this current case, as well as two related, companion cases with overlapping classes involving the Parties and currently pending before the Honorable Elihu Behrle in Dept. 323 of the Los Angeles County Superior Court, entitled Louise Robinson, et al., vs. Airgas On-Site Safety Services, Inc. (" Robinson "), and Benjamin Anderson, Francisco Maiava, et al. v. Airgas On-Site Safety Services, Inc., Gulf South Safety Consultants, LLC and Responsable Staffing, LLC (" Anderson ").
4. WHEREAS, following that mediation, on August 26, 2014, the Parties agreed to the terms of a global settlement encompassing both this matter, as well as the Robinson and Anderson matters;
5. WHEREAS, the Parties have agreed to a continued stay of this matter to encompass all pending deadlines, including the upcoming Case Management Conference on September 11, 2014, to allow the Parties to continue to finalize the terms of the settlement documents including a formal settlement agreement;
THEREFORE, the Parties respectfully request this Court continue to stay all deadlines in this case, including the deadline for submitting an updated Joint Case Management Conference Statement, as well as the upcoming Further Case Management Conference currently scheduled for September 11, 2014, until after the Parties have finalized the terms of their settlement.
IT IS SO STIPULATED.
ORDER
Based upon the joint stipulation of the Parties in the above-captioned case, and good cause appearing, a continued stay of this case, in its entirety, is ordered to allow the Parties to finalize the terms of their settlement. The Parties shall file an updated Joint Case Management Conference Statement with the Court on or before October 2, 2014 advising the Court of the status of their settlement agreement and plan for formal approval of the class settlement. A further Case Management Conference is set for October 29, 2014 at 2:00 p.m.
IT IS SO ORDERED.