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David Mara, Esq. (230498)
1 Matthew Crawford, Esq. (310230)
MARA LAW FIRM PC
2 2650 Camino Del Rio North Suite 205
San Diego, California 92108
3 Telephone: (619) 234-2833
Facsimile: (619) 234-4048
4
Hunter Pyle, Esq. (191225)
5 John J. Darin, Esq. (323730)
HUNTER PYLE LAW
6 1300 Broadway, Eleventh Floor
Oakland, California 94612
7 Telephone (510) 444-4400
8 Attorneys for Plaintiff ARNOLD GARCIA,
on behalf of himself, all others similarly
9 situated, and on behalf of the general public.
10
Lonnie D. Giamela, Esq. (228435)
11 Victoria H. Shin, Esq. (306347)
FISHER & PHILLIPS LLP
12 444 S Flower St., Suite 1590
Los Angeles, CA 90071
13 Telephone: (213) 330-4454
Facsimile: (213) 330-4501
14
Attorneys for Defendants MCCOLLISTER’S
15 TRANSPORTATION SYSTEMS, INC.,
MCCOLLISTER’S GLOBAL SERVICES, INC., and
16 MCCOLLISTER’S AUTO TRANSPORT, LLC
17 SUPERIOR COURT OF THE STATE OF CALIFORNIA
18 FOR THE COUNTY OF ALAMEDA
19
ARNOLD GARCIA, on behalf of himself, Case No.: RG21112345
20 all others similarly situated, and on behalf
of the general public, STIPULATION AND [PROPOSED] ORDER
21 TO CONTINUE CASE MANAGEMENT
Plaintiff, CONFERENCE
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v. Date: October 11, 2022
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Time: 3:00 p.m.
24 MCCOLLISTER’S TRANSPORTATION Dept.: 23
SYSTEMS, INC.; MCCOLLISTER’S
25 GLOBAL SERVICES, INC.;
MCCOLLISTER’S AUTO TRANSPORT,
26 LLC; and DOES 1-100,
27
Defendants.
28 1
STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE
Case No.: RG21112345
1 IT IS HEREBY STIPULATED by all parties to the above-captioned matter as follows:
2 1. The Parties attended mediation with respected wage and hour mediator Mark Rudy on
3 August 16, 2022.
4 2. The Parties agreed to suspend the mediation for the time being while Defendants gather
5 additional information and documents to allow the Parties to further evaluate the claims
6 alleged.
7 3. On September 22, 2022, Defendants provided Plaintiff with the remaining additional
8 information and documents. Plaintiff is still in the process of evaluating the information and
9 documents.
10 4. Once Plaintiff has finished his analysis, the Parties anticipate continuing negotiations through
11 the mediator in attempt to resolve this matter in its entirety.
12 5. In order to preserve time and resources for both the Court and the Parties, the Parties
13 respectfully request a continuance of the October 11, 2022 case management conference to
14 allow the Parties additional time to review the additional information and documents and
15 attempt to reach a settlement.
16 6. Now therefore, the Parties, by and though their respective undersigned counsel, hereby
17 STIPULATE, AGREE, and JOINTLY REQUEST that the Court continue the case
18 management conference in this matter currently scheduled for October 11, 2022, by
19 approximately thirty-five (35) days to November 15, 2022, at 3:00 p.m., or any other date
20 convenient for the Court.
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STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE
Case No.: RG21112345
1 IT IS SO STIPULATED AND AGREED:
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4 DATED: October 4, 2022 MARA LAW FIRM, PC
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6 By:
David Mara, Esq.
7 Matthew Crawford, Esq.
8 Attorneys for Plaintiff
9 DATED: October 4, 2022 FISHER & PHILLIPS LLP
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By //s// Victoria H. Shin
11 Lonnie D. Giamela, Esq.
Victoria H. Shin, Esq.
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STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE
Case No.: RG21112345
1 [PROPOSED] ORDER
2 After considering the parties’ Stipulation to Continue the Case Management Conference and
3 good cause appearing, the Court hereby orders as follows:
4 The case management conference that is currently scheduled for October 11, 2022, is hereby
5 continued to 11/15/2022 at 3 pm. CMC statements due 5 days before conf.
____________________________________________________ at
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8 IT IS SO ORDERED.
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10 Dated: __________________________________________
Honorable Brad Seligman
11 Judge of the Superior Court
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STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE
Case No.: RG21112345
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David Mara, Esq. (230498) 1 Matthew Crawford, Esq. (310230) MARA LAW FIRM PC 2 2650 Camino Del Rio North Suite 205 San Diego, California 92108 3 Telephone: (619) 234-2833 Facsimile: (619) 234-4048 4 Hunter Pyle, Esq. (191225) 5 John J. Darin, Esq. (323730) HUNTER PYLE LAW 6 1300 Broadway, Eleventh Floor Oakland, California 94612 7 Telephone (510) 444-4400 8 Attorneys for Plaintiff ARNOLD GARCIA, on behalf of himself, all others similarly 9 situated, and on behalf of the general public. 10 Lonnie D. Giamela, Esq. (228435) 11 Victoria H. Shin, Esq. (306347) FISHER & PHILLIPS LLP 12 444 S Flower St., Suite 1590 Los Angeles, CA 90071 13 Telephone: (213) 330-4454 Facsimile: (213) 330-4501 14 Attorneys for Defendants MCCOLLISTER’S 15 TRANSPORTATION SYSTEMS, INC., MCCOLLISTER’S GLOBAL SERVICES, INC., and 16 MCCOLLISTER’S AUTO TRANSPORT, LLC 17 SUPERIOR COURT OF THE STATE OF CALIFORNIA 18 FOR THE COUNTY OF ALAMEDA 19 ARNOLD GARCIA, on behalf of himself, Case No.: RG21112345 20 all others similarly situated, and on behalf of the general public, STIPULATION AND [PROPOSED] ORDER 21 TO CONTINUE CASE MANAGEMENT Plaintiff, CONFERENCE 22 v. Date: October 11, 2022 23 Time: 3:00 p.m. 24 MCCOLLISTER’S TRANSPORTATION Dept.: 23 SYSTEMS, INC.; MCCOLLISTER’S 25 GLOBAL SERVICES, INC.; MCCOLLISTER’S AUTO TRANSPORT, 26 LLC; and DOES 1-100, 27 Defendants. 28 1 STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE Case No.: RG21112345 1 IT IS HEREBY STIPULATED by all parties to the above-captioned matter as follows: 2 1. The Parties attended mediation with respected wage and hour mediator Mark Rudy on 3 August 16, 2022. 4 2. The Parties agreed to suspend the mediation for the time being while Defendants gather 5 additional information and documents to allow the Parties to further evaluate the claims 6 alleged. 7 3. On September 22, 2022, Defendants provided Plaintiff with the remaining additional 8 information and documents. Plaintiff is still in the process of evaluating the information and 9 documents. 10 4. Once Plaintiff has finished his analysis, the Parties anticipate continuing negotiations through 11 the mediator in attempt to resolve this matter in its entirety. 12 5. In order to preserve time and resources for both the Court and the Parties, the Parties 13 respectfully request a continuance of the October 11, 2022 case management conference to 14 allow the Parties additional time to review the additional information and documents and 15 attempt to reach a settlement. 16 6. Now therefore, the Parties, by and though their respective undersigned counsel, hereby 17 STIPULATE, AGREE, and JOINTLY REQUEST that the Court continue the case 18 management conference in this matter currently scheduled for October 11, 2022, by 19 approximately thirty-five (35) days to November 15, 2022, at 3:00 p.m., or any other date 20 convenient for the Court. 21 \\ 22 \\ 23 \\ 24 \\ 25 \\ 26 \\ 27 \\ 28 2 STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE Case No.: RG21112345 1 IT IS SO STIPULATED AND AGREED: 2 3 4 DATED: October 4, 2022 MARA LAW FIRM, PC 5 6 By: David Mara, Esq. 7 Matthew Crawford, Esq. 8 Attorneys for Plaintiff 9 DATED: October 4, 2022 FISHER & PHILLIPS LLP 10 By //s// Victoria H. Shin 11 Lonnie D. Giamela, Esq. Victoria H. Shin, Esq. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE Case No.: RG21112345 1 [PROPOSED] ORDER 2 After considering the parties’ Stipulation to Continue the Case Management Conference and 3 good cause appearing, the Court hereby orders as follows: 4 The case management conference that is currently scheduled for October 11, 2022, is hereby 5 continued to 11/15/2022 at 3 pm. CMC statements due 5 days before conf. ____________________________________________________ at 6 _________________. 7 8 IT IS SO ORDERED. 9 10 Dated: __________________________________________ Honorable Brad Seligman 11 Judge of the Superior Court 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4 STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE Case No.: RG21112345