Opinion
CASE NO. C 06-0963 (CW)
11-08-2012
Steven M. Tindall (State Bar No. 187862) Rosha Jones (State Bar No. 279143) RUKIN HYLAND DORIA & TINDALL LLP Kelly M. Dermody (State Bar No. 171716) Daniel M. Hutchinson (State Bar No. 239458) Anne B. Shaver (State Bar No. 255928) LIEFF, CABRASER, HEIMANN & BERNSTEIN, LP Counsel for Plaintiffs and the National and California Classes
Steven M. Tindall (State Bar No. 187862)
Rosha Jones (State Bar No. 279143)
RUKIN HYLAND DORIA & TINDALL LLP
Kelly M. Dermody (State Bar No. 171716)
Daniel M. Hutchinson (State Bar No. 239458)
Anne B. Shaver (State Bar No. 255928)
LIEFF, CABRASER, HEIMANN & BERNSTEIN, LP
Counsel for Plaintiffs and the National and California
Classes
JOINT STIPULATION AND ORDER TO
STAY COURT DEADLINES
STIPULATION
Plaintiffs Gopi Vedachalam and Kangana Beri ("Plaintiffs"), on behalf of themselves and the PlaintiffNational and California Classes, and Defendants Tata Consultancy Services, Ltd. and Tata Sons, Ltd. (together, "Defendants") hereby stipulate and agree as follows:
WHEREAS, the parties conducted a private mediation before Susan Haldeman on October 16 and 17, 2012, as well as additional telephonic conferences with Ms. Haldeman;
WHEREAS, the parties are continuing their mediation discussions in an effort to resolve this matter;
WHEREAS, to facilitate those discussions, the parties respectfully request that this Court stay all Court deadlines for 90 days, though the parties intend to use their best efforts to complete their negotiation within the next 45 days and inform the Court of their progress at that time;
IT IS HEREBY STIPULATED AND AGREED that this litigation be stayed until
Respectfully submitted,
RUKIN HYLAND DORIA & TINDALL LLP
By: ____________
Steven M. Tindall
Rosha Jones (State Bar No.279143)
LIEFF, CABRASER, HEIMANN & BERNSTEIN, LLP
By: ____________
Kelly M. Dermody (State Bar No. 171716)
Daniel M. Hutchinson (State Bar No. 239458)
Anne Shaver (State Bar No. 255928)
Counsel for Plaintiffs and the National and
California Classes
LOEB & LOEB, LLP
By: ____________
Michelle La Mar (State Bar No. 163038)
John Daryanani (State Bar No.205149)
10100 Santa Monica Boulevard, Suite 2200
KELLEY DRYE & WARREN, LLP
By: ____________
William A. Escobar (Admitted Pro Hac Vice)
Robert I. Steiner (Admitted Pro Hac Vice)
Kevin J. Smith (Admitted Pro Hac Vice)
Attorneys for Defendants TATA CONSULTANCY
SERVICES, LTD., and TATA SONS, LTD.
In light of the parties' stipulation regarding their ongoing attempts to resolve this matter, the Court concludes that, in the interests of judicial efficiency, all litigation and all deadlines in the matter should be stayed, and are hereby stayed, for 90 days.
The parties are to provide the Court with an update of their status by February 4, 2013. IT IS SO ORDERED. All existing deadlines are extended by 90 days, except the pretrial and trial dates.
By: ____________
HON. CLAUDIA WILKEN
United States District Court Judge