2:23-cv-02085
E.D. Cal.
Nov 27, 2023

ADRIANA MAGDALENA RAMOS, individually and on behalf of all others similarly situated v. ROADSAFE TRAFFIC SYSTEMS, INC.; and DOES 1 through 20, inclusive

Case No. 2:23-CV-02085-KJM-CKD

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA - SACRAMENTO

November 27, 2023

CHIEF UNITED STATES DISTRICT JUDGE

Action Filed: 2/8/2023; Removal Filed: 9/22/23; Trial Date: None Set

SAMUEL A. WONG, SBN 217104
swong@aegislawfirm.com
KASHIF HAQUE, SBN 218672
khaque@aegislawfirm.com
JESSICA L. CAMPBELL, SBN 280626
jcampbell@aegislawfirm.com
ALEX J. VALLE, SBN 334263
avalle@aegislawfirm.com
AEGIS LAW FIRM, PC
9811 Irvine Center Drive, Suite 100
Irvine, CA 92618
Telephone: (949) 379-6250
Facsimile: (949) 379-6251

Attorneys for Plaintiff ADRIANA MAGDALENA RAMOS

MICHAEL J. NADER, SBN 200425
michael.nader@ogletree.com
ALEXANDRA ASTERLIN, SBN 221286
alexandra.asterlin@ogletree.com
PAUL M. SMITH, SBN 306644
paul.smith@ogletree.com
OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.
500 Capitol Mall, Suite 2500
Sacramento, CA 95814
Telephone: 916-840-3150
Facsimile: 916-840-3159

Attorneys for Defendant ROADSAFE TRAFFIC SYSTEMS, INC.

JOINT STIPULATION TO STAY ALL PROCEEDINGS PENDING MEDIATION AND ORDER

TO THE CLERK OF THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA, DEFENDANT ROADSAFE TRAFFIC SYSTEMS, INC., AND TO ITS COUNSEL OF RECORD:

WHEREAS Plaintiff ADRIANA MAGDALENA RAMOS (“Plaintiff“) filed this civil class action for damages against Defendant ROADSAFE TRAFFIC SYSTEMS, INC. (“Defendant“) (collectively, the “Parties“) on February 8, 2023;

WHEREAS Defendant removed this civil class action to federal court on September 22, 2023;

WHEREAS Plaintiff filed and the Parties have fully briefed Plaintiff‘s Motion to Remand this civil class action to state court, which is set to be heard on December 8, 2023.

WHEREAS Defendant filed and the Parties have fully briefed a Motion to Dismiss Plaintiff‘s First Amended Class Action Complaint, which is set to be heard on December 8, 2023.

WHEREAS the Parties to this Action agreed to mediate this matter with experienced mediator, the Hon. Carl J. West (Ret.), on January 23, 2024 (the “Mediation Date“), the earliest date on which the mediator is available.

WHEREAS the Parties desire to devote their resources to focus on potentially resolving this matter in full at the mediation, and therefore, the Parties jointly request the Court to stay all proceedings until after the Mediation Date. Courts have “broad discretion” to stay proceedings. Clinton v. Jones, 520 U.S. 681, 706 (1997). “[T]he power to stay proceedings is incidental to the power inherent in every court to control the disposition of the causes on its docket with economy of time and effort for itself, for counsel, and for litigants.” Landis v. North Am. Co., 299 U.S. 248, 254 (1936); see also Fed. R. Civ. P. 1. The Parties agree that a stay will help secure the just and efficient resolution of this proceeding.

NOW THEREFORE IT IS HEREBY STIPULATED THAT:

  1. All proceedings in this matter (including the hearings on Defendant‘s Motion to Dismiss and Plaintiff‘s Motion to Remand) be stayed in full until after the Mediation Date, to provide the Parties with adequate time to resolve all issues on or shortly after the Mediation Date. The Parties jointly request that the Court schedule a status conference at least thirty (30) days after the Mediation Date of January 23, 2024.
  2. The Parties jointly request the Court to preserve their respective rights in this action, including any arguments in support of or defenses against Defendant‘s right to challenge the pleadings and Plaintiff‘s right to file a remand motion.
  3. All discovery shall be stayed during the period of the stay. The Parties have entered into a detailed, written agreement on the dates and content of the informal, pre-mediation exchange of data and documents necessary to conduct mediation.

IT IS SO STIPULATED.

DATED: November 21, 2023

AEGIS LAW FIRM, PC

By: /s/ Alex J. Valle
Samuel A. Wong
Kashif Haque
Jessica L. Campbell
Alex J. Valle

Attorneys for Plaintiff
ADRIANA MAGDALENA RAMOS

DATED: November 21, 2023

OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.

By: /s/ Paul M. Smith
Michael J. Nader
Alexandra Asterlin
Paul M. Smith

Attorneys for Defendant
ROADSAFE TRAFFIC SYSTEMS, INC.

ORDER

THIS COURT, having read and considered the Joint Stipulation to Stay All Proceedings Pending Mediation by, between and among Plaintiff ADRIANA MAGDALENA RAMOS and Defendant ROADSAFE TRAFFIC SYSTEMS, INC, and finding good cause therefor, orders as follows:

  1. This action is stayed in its entirety, subject to the conditions set forth in the Parties’ stipulation, until the Court convenes a status conference by videoconference on March 14, 2024 at 2:30 p.m. before the undersigned.
  2. All other dates currently pending and/or scheduled in this action are vacated and continued until after the status conference.

IT IS SO ORDERED.

DATED: November 27, 2023.

CHIEF UNITED STATES DISTRICT JUDGE