Andrade v. Costco Wholesale Corporation

STIPULATION TO FURTHER AMEND PRETRIAL DEADLINES; ORDER
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ILG Legal Office, P.C.
Stephen Noel Ilg (SBN 275599)
Nicolas Jupillat (SBN 335559)
156 South Spruce Avenue, Ste 206A
South San Francisco, CA 94080
Tel: (415) 580-2574
Fax: (415) 735-3454
Email: silg@ilglegal.com
Email: njupillat@ilglegal.com
Attorneys for Plaintiff
ISABELLA ANDRADE
Additional attorneys on next page
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
ISABELLA ANDRADE, on behalf of herself,
Plaintiff,
v.
COSTCO WHOLESALE CORPORATION, a
Washington corporation, and DOES 1 through
100, inclusive,
Defendants.
Case No. 3:23-cv-6125-TSH
(San Mateo Superior Court, Case No. 23-CIV-
05090)
STIPULATION TO FURTHER AMEND
PRETRIAL DEADLINES; ORDER
Date Action Filed: October 25, 2023
Trial Date: February 23, 2026
Case 3:23-cv-06125-TSH Document 44 Filed 01/07/26 Page 1 of 5

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STIPULATION TO FURTHER AMEND PRETRIAL DEADLINES; ORDER
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SEYFARTH SHAW LLP
Justin Curley (SBN 233287)
jcurley@seyfarth.com
Pamela Vartabedian (SBN 251133)
pvartabedian@seyfarth.com
560 Mission Street, Suite 3100
San Francisco, California 94105-2930
Telephone: (415) 732-1157
Facsimile: (415) 397-8549
SEYFARTH SHAW LLP
Bradley D. Doucette (SBN 322611)
bdoucette@seyfarth.com
2029 Century Park East, Suite 3500
Los Angeles, California 90067-3021
Telephone: (310) 277-7200
Facsimile: (310) 201-5219
Attorneys for Defendant
COSTCO WHOLESALE CORPORATION
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STIPULATION TO FURTHER AMEND PRETRIAL DEADLINES; ORDER
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TO THE HONORABLE COURT:
Pursuant to Civil Local Rules 6-2 and 7-12, it is hereby stipulated, pursuant to the Court’s
approval, by and between Plaintiff Isabella Andrade (“Plaintiff”) and Defendant Costco Wholesale
Corporation (“Defendant”) (collectively the “Parties”) through their respective counsel as follows:
WHEREAS, pursuant to the Court’s February 22, 2024 Case Management Order (Dkt. No. 18)
the Parties have continuously met and conferred with respect to the preparation and content of the joint
pretrial conference statement and related pretrial documents and have started to exchange initial drafts.
In need of additional time, the Parties also submitted a Stipulation to continue the Pretrial Document
Deadline to January 8, 2026 (Dkt. No. 41) which the Court graciously approved (Dkt. No. 42.).
WHEREAS, the Parties have worked diligently and collaboratively to prepare the requisite
pretrial documents despite holiday closures and related delays but are in need of some additional time to
complete them in light of the breadth of issues for trial. Further, counsel for both parties have had
periods of unavailability..
WHEREAS, the Parties have met and conferred regarding motions in limine and do not intend
on filing any motions in limine.
WHEREAS, the Parties have met and conferred regarding witnesses and exhibits and do not
presently have issues regarding witnesses or exhibits requiring the Court’s immediate attention. The
parties have agreed to create a single list and are currently combining their respective lists and
continuing to work on other pretrial filings.
WHEREAS, the Initial Case Management Conference is set for Thursday, January 15, 2026 in
person at 10:00 a.m. Per the Court’s Case Management Order (Dkt. No. 18) “The purpose of the initial
pretrial conference is for the Court to rule on any issues raised in the pretrial conference statement,
motions in limine, and to discuss the trial of the case.” As such, the Parties do not believe there any
issues requiring the Court’s attention at this time.
WHEREAS, after meeting and conferring, the Parties agree that a brief two-week extension of
the Pretrial Document deadline to January 22, 2026 would be in the best interest of both Parties and
ensure more effective completion of the pretrial documents in light of the holidays and other
circumstances. The Parties agree that a similar three-week extension of the Initial Case Management
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Conference to February 5, 2025 at 10:00 a.m., or some time convenient to the Court, would be helpful to
allow the Parties to complete these pretrial documents. This is only the second extension request by
either Party for any trial-related deadline and it will not affect any other pre-trial dates set by this Court.
IT IS SO STIPULATED.
DATED: January 7, 2026 Respectfully submitted,
ILG LEGAL OFFICE, P.C.
By: /s/ Stephen Noel Ilg (as authorized 1/7/2025)
Stephen Noel Ilg
Nicolas Jupillat
Attorneys for Plaintiff
ISABELLA ANDRADE
DATED: January 7, 2026 Respectfully submitted,
SEYFARTH SHAW LLP
By: /s/ Bradley D. Doucette
Pamela Vartabedian
Bradley D. Doucette
Attorneys for Defendant
COSTCO WHOLESALE CORPORATION
Case 3:23-cv-06125-TSH Document 44 Filed 01/07/26 Page 4 of 5

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ORDER
PURSUANT TO THE PARTIES’ STIPULATION, IT IS SO ORDERED:
The Court finds good cause of the Parties’ request and hereby orders that all pretrial documents
be filed no later than January 22, 2026.
The Initial Pretrial Conference set for January 15, 2026 at 10:00 a.m. is vacated and continued
to February 5, 2026 at 10:00 a.m. Lead counsel for the Parties are expected to appear in person for the
Initial Pretrial Conference.
Dated: January 7, 2026 ___ _______________________
U.S. District Court Magistrate Judge
Case 3:23-cv-06125-TSH Document 44 Filed 01/07/26 Page 5 of 5