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JOINT STATUS REPORT AND REQUEST TO CONTINUE STATUS CONFERENCE 

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RICHARD E. QUINTILONE II (SBN 200995)

GEORGE A. ALOUPAS (SBN 313112) 

QUINTILONE & ASSOCIATES

22974 EL TORO ROAD, SUITE 100 

LAKE FOREST, CA 92630 

TELEPHONE: (949) 458-9675 

FACSIMILE: (949) 458-9679 

E-MAIL: REQ@QUINTLAW.COM; GAA@QUINTLAW.COM 

Attorneys for Plaintiff, JENNIFER ANDERSON on behalf of herself and on behalf of a Class of all 

other persons similarly situated 

ROBERT D. EASSA, State Bar No. 107970 

reassa@duanemorris.com 

DELIA A. ISVORANU, State Bar No. 226750 

disvoranu@duanemorris.com 

DUANE MORRIS, LLP 

Spear Tower One Market Plaza, Ste. 2200 

San Francisco, CA 94105-1127 

Telephone: 415.957.3093 

Facsimile: 415.520.0814 

Attorneys for Defendant, CHEVRON U.S.A. INC. 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA – SAN FRANCISCO DIVISION 

JENNIFER ANDERSON, on behalf of herself 

and on behalf of a Class of all other persons 

similarly situated 

 Plaintiff, 

vs. 

CHEVRON U.S.A., INC., a Delaware 

Corporation; and DOES 1 through 100, 

inclusive, 

 Defendants. 

Case No.: 3:17-cv-00103-EMC 

CLASS ACTION 

Assigned For All Purposes To: 

Hon. Edward M. Chen 

JOINT STATUS REPORT AND REQUEST 

TO CONTINUE STATUS CONFERENCE 

Current Status Conference 

Date: August 16, 2018 

Time: 10:30 a.m. 

Location: Courtroom 5, 17th Floor 

Complaint Filed: September 7, 2016 

Removed: January 9, 2017 
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JOINT STATUS REPORT AND REQUEST TO CONTINUE STATUS CONFERENCE 

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JOINT STATUS REPORT 

Plaintiff, Jennifer Anderson (“Plaintiff”), on behalf of herself and other similarly situated 

employees of Defendant Chevron U.S.A. Inc. (“Defendant”) (collectively, “the Parties”), by and 

through their respective counsel of record, hereby provide the following update on the litigation. 

The parties completed the first session of mediation on October 16, 2017 in San Francisco 

with Michael Dickstein, Esq., and made substantial progress towards arriving at a resolution. The 

parties left their initial mediation session – after allowing time for further internal analysis – with an 

agreement to reengage after 30 days through continued negotiations facilitated by Mr. Dickstein. 

Counsel for the parties and the Vincent Clack, Orlando Sampayo and Albert Vega Jr., et al. v. 

Chevron Corporations, et al., Los Angeles Superior Court Case No. BC649514, (the “Clack” case).1 

Counsel agreed to mediate the case jointly and have been working diligently on resolving the matter 

making continued moves after the October 16, 2017 mediation through the mediator. 

Plaintiffs continue to confer and correspond with each other and with Mr. Dickstein and are 

working to determine if a Settlement of both matters is possible and to address the necessary 

procedure for seeking approval of a global resolution. 

RECITALS 

Plaintiff, Jennifer Anderson (“Plaintiff”), on behalf of herself and other similarly situated 

employees of Defendant Chevron U.S.A. Inc. (“Defendant”) (collectively, “the Parties”), by and 

through their respective counsel of record, hereby stipulate to, and jointly request, the Court to enter 

the concurrently provided [Proposed] Order approving the Parties’ Joint Stipulation to Continue their 

upcoming Status Conference currently set for August 16, 2018 and other related dates. This 

Stipulation is based on the following: 

1. Plaintiff filed her Class Action Complaint on September 7, 2016 in Contra Costa 

County Superior Court (Case No. MSC16-01724). On November 16, 2016, Plaintiff filed her First 

Amended Class Action Complaint (“FAC”), which is the operative pleading, asserting the following 

 

1 Clack is currently pending in Los Angeles County Superior Court before Hon. Carolyn B. Kuhl and was filed on 

February 6, 2017 with a proposed class limited to Operators who worked in the refineries and their claims for failure to 

provide rest periods and derivative claims. Clack was currently stayed by the Superior Court pending resolution of this 

(Anderson) action. 
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JOINT STATUS REPORT AND REQUEST TO CONTINUE STATUS CONFERENCE 

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causes of action against Defendant: (1) Failure to pay wages pursuant to the FLSA [29 U.S.C. §§ 

206, 207]; (2) Failure to pay overtime compensation; (3) Failure to provide meal periods; (4) Failure 

to provide rest periods; (5) Failure to provide accurate itemized wage statements; (6) Failure to pay 

wages for hours worked; (7) Failure to pay wages due and payable twice monthly; (8) Failure to 

comply with written request to inspect or copy records; (9) Failure to reimburse business expenses; 

(10) Failure to pay wages upon termination of employment; (11) Unlawful competition and unlawful 

business practices; and (12) Violations of the Private Attorneys’ General Act (“PAGA”). (See Dkt. 

#1, Exhibit A for FAC). 

2. Defendant removed the action to this Court on January 9, 2017 (Dkt. No. 1), asserting 

that the Court has subject matter jurisdiction arising under a federal question pursuant to 28 U.S.C. § 

1331, specifically with regard to Plaintiff’s First Cause of Action for Failure to Pay Wages pursuant 

to the FLSA, 29 U.S.C. §§ 206, and 207. Plaintiff has not yet challenged this jurisdiction or sought 

remand. 

3. On May 5, 2017, the Court conducted its Initial Case Management Conference with 

the Parties and, in advance of the Conference, counsel conducted meet and confer discussions and 

exchanged correspondence, including regarding the possibility of early amicable resolution of 

Plaintiff’s class and collective claims through private mediation. 

Stipulation and Request for Continued Status Conference 

4. Per the May 5, 2017 Case Management Conference, the Court set a further conference 

as well as a mediation completion deadline for September 14, 2017. 

5. The Parties had trouble agreeing on a mediation date based on the conflicting 

schedules of all involved as well as the inclusion of counsel in a related case, Vincent Clack, Orlando 

Sampayo and Albert Vega Jr., et al. v. Chevron Corporations, et al., Los Angeles Superior Court 

Case No. BC649514, (the “Clack” case). 

6. Ultimately, all counsel agreed to schedule mediation in an attempt to negotiate a 

global resolution. A mediation date was arranged with Michael Dickstein Esq. on October 16, 2017

in San Francisco, California. As a result, the parties stipulated to continue the mediation completion 

deadline to November 1, 2017 and the Case Management Conference to November 9, 2017 at 10:30 
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JOINT STATUS REPORT AND REQUEST TO CONTINUE STATUS CONFERENCE 

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a.m., which the Court approved on September 5, 2017. (Dkt. No. 28). On October 30, 2017, the 

Court changed the start time of the Conference to November 9, 2017 at 1:30 p.m. (Dkt. No. 29) 

Then, on November 1, 2017, the Court changed the start time back to 10:30 a.m. (Dkt. No. 30). The 

Court also required submission of a Case Management Statement by November 2, 2017. 

7. As they had planned, the parties completed the first session of mediation on October 

16, 2017 in San Francisco with Michael Dickstein, Esq., and made substantial progress towards 

arriving at a resolution. The parties left their initial mediation session – after allowing time for 

further internal analysis – with an agreement to reengage after 30 days through continued 

negotiations facilitated by Mr. Dickstein. Counsel for the parties and the Clack plaintiffs continue to 

confer and correspond with each other and with Mr. Dickstein and are working to determine if a 

Settlement of both matters is possible and to address the necessary procedure for seeking approval of 

a global resolution. 

8. The parties have engaged in continued settlement discussions, both directly with each 

other and through the mediator. The mediator recently conveyed Plaintiff’s new demand. Defendant 

is evaluating the demand and has also engaged an expert to calculate 

9. The parties are making progress and continue to communicate with the mediator on an 

ongoing basis. However, given that the parties are attempting to resolve two separate actions, with 

over a dozen claims, and the complexity of the allegations, defenses, and alleged damages/penalties, 

the settlement process has taken longer than the parties expected. Further, Defendant’s counsel started 

trial in another matter on February 20, 2018 which is expected to last approximately four (4) weeks. 

10. The parties have all conducted a first round of written discovery and the first session 

of Plaintiff’s deposition was completed in Tennessee. In order to save costs and resources, the parties 

elected to focus of ongoing settlement discussions before engaging in further discovery. 

10. The parties therefore respectfully request the Court to continue the upcoming Status 

Conference set for August 16, 2018, at 10:30 a.m. to September 28, 2018 at 10:30 a.m., or to a date 

thereafter that is convenient to the Court. 

11. The parties are continuing to engage in active settlement discussions. 

/// 

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JOINT STATUS REPORT AND REQUEST TO CONTINUE STATUS CONFERENCE 

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Dated: August 13, 2018 QUINTILONE & ASSOCIATES

By: __________________________________________ 

RICHARD E. QUINTILONE II, 

GEORGE A. ALOUPAS 

Attorneys for Plaintiff JENNIFER ANDERSON, 

on behalf of herself and on behalf of a Class of all 

other persons similarly situated and the collective 

Dated: August 13, 2018 DUANE MORRIS, LLP

By: /s/ 

ROBERT D. EASSA, 

DELIA A. ISVORANU 

Attorneys for Defendant, CHEVRON U.S.A. INC. 

IT IS SO ORDERED as modified above. 

U

NITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

IT IS SO ORDERED

AS MODIFIED

Judge Edward M. Chen
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PROOF OF SERVICE 

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PROOF OF SERVICE 

I, the undersigned, declare as follows: 

I am a citizen of the United States, over the age of 18 years, and not a party to the within action. I am an 

employee of or agent for Quintilone & Associates, whose business address is 22974 El Toro Rd., Suite 100, 

Lake Forest, CA 92630-4961. 

On August 13, 2018, I served the foregoing document(s): 

JOINT STIPULATION TO CONTINUE STATUS CONFERENCE 

 on the following parties in this action addressed as follows: 

SEE ATTACHED SERVICE LIST 

______ (BY MAIL) I caused a true copy of each document, placed in a sealed envelope with postage fully 

paid, to be placed in the United States mail at Lake Forest, California. I am "readily familiar" 

with this firm's business practice for collection and processing of mail, that in the ordinary course 

of business said document(s) would be deposited with the U.S. Postal Service on that same day. I 

understand that the service shall be presumed invalid if the postal cancellation date or postage 

meter date on the envelope is more than one day after the date of deposit for mailing contained on 

this affidavit. 

______ (BY OVERNIGHT DELIVERY) I caused a true copy of each document, placed in a sealed 

envelope with delivery fees provided for, to be deposited in a box regularly maintained by Federal 

Express or Overnight Express. I am readily familiar with this firm's practice for collection and 

processing of documents for overnight delivery and know that in the ordinary course of 

Quintilone & Associates’ business practice the document(s) described above will be deposited in a 

box or other facility regularly maintained by Federal Express or Overnight Express or delivered to 

a courier or driver authorized by Federal Express or Overnight Express to receive documents on 

the same date it is placed at Quintilone & Associates for collection.

______ (BY FACSIMILE) By use of facsimile machine number 949.458.9679, I served a copy of the 

within document(s) on the above interested parties at the facsimile numbers listed above. The 

transmission was reported as complete and without error. The transmission report was properly 

issued by the transmitting facsimile machine. 

__X___ (BY E-MAIL) I caused a true and correct copy of each document to be delivered by Electronic 

Mail. 

Executed on August 13, 2018, at Lake Forest, California 

____X____ (FEDERAL) I declare that I am employed in the office of a member of the bar of this court at 

whose direction the service was made. 

________ (STATE) I declare under penalty of perjury under the laws of the State of California that the 

above is true and correct. 

 

___________________________ 

 RICHARD E. QUINTILONE II
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PROOF OF SERVICE 

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SERVICE LIST 

ROBERT D. EASSA, State Bar No. 107970 

reassa@duanemorris.com 

DELIA A. ISVORANU, State Bar No. 226750 

disvoranu@duanemorris.com 

DUANE MORRIS, LLP 

Spear Tower One Market Plaza, Ste. 2200 

San Francisco, CA 94105-1127 

Telephone: 415.957.3093 

Facsimile: 415.520.0814 

Attorneys for Defendant, CHEVRON U.S.A. INC. 

Roger R. Carter (SBN 140196) 

Bianca A. Sofonio (SBN 179520) 

THE CARTER LAW FIRM 

23 Corporate Plaza, Suite 150 

Newport Beach, Ca 92660 

Telephone No. (949) 629-2565 

Email: rcarter@carterlawfirm.net; bianca@carterlawfirm.net 

Marc H. Phelps (SBN 237036) 

THE PHELPS LAW GROUP 

23 Corporate Plaza, Suite 150 

Newport Beach, Ca 92660 

Telephone No. (949) 629-2533 

Email: marc@phelpslawgroup.com 

Attorneys for Plaintiff JENNIFER ANDERSON, on behalf of herself and on behalf of a 

Class of all other persons similarly situated and the collective 

RANDY RENICK (CA Bar No. 179652) 

(Email: rrr@hadsellstormer.com) 

CORNELIA DAI (CA Bar No. 207435) 

(Email: cdai@hadsellstormer.com) 

SPRINGSONG COOPER (CA Bar No. 307845) 

(Email: scooper@hadsellstormer.com) 

HADSELL STORMER & RENICK, LLP 

128 North Fair Oaks Avenue, Suite 204 

Pasadena, California 91103-3645 

Telephone: (626) 585-9600 

Fax: (626) 577-7079 
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PROOF OF SERVICE 

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JAY SMITH (CA Bar No. 166105) 

(Email: js@gslaw.org) 

JOSHUA F. YOUNG (CA Bar No. 232995) 

(Email: jyoung@gslaw.org) 

GILBERT & SACKMAN 

A LAW CORPORATION 

3699 Wilshire Boulevard, Suite 1200 

Los Angeles, California 90010 

Telephone: (323) 938-3000 

Fax: (323) 937-9139 

Attorneys for Plaintiffs Vincent Clack, Orlando Sampayo, Albert Vega Jr., and Sam 

Marinelli 

Q&A Case No.: 16.01263