Andrade v. Costco Wholesale Corporation

STIPULATION TO AMEND PRETRIAL DEADLINES; [PROPOSED] 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
SEYFARTH SHAW LLP
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
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 AMEND PRETRIAL
DEADLINES; [PROPOSED] ORDER
Date Action Filed: October 25, 2023
Trial Date: February 23, 2026
Case 3:23-cv-06125-TSH Document 42 Filed 12/16/25 Page 1 of 4

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STIPULATION TO AMEND PRETRIAL DEADLINES; [PROPOSED] ORDER
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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 undersigned counsel as
follows:
WHEREAS, pursuant to the Court’s February 22, 2024 Case Management Order (Dkt. No. 18)
the Parties exchanged Pretrial Disclosures on December 10, 2025. Per the Court’s Order, the Parties also
met and conferred with respect to the preparation and content of the joint pretrial conference statement
and started to exchange initial drafts.
WHEREAS, the current deadline to file Pretrial Documents is December 25, 2025 (i.e.
Christmas Day).
WHEREAS, the Parties have worked collaboratively and, after initial meet and confer efforts,
anticipate that many of the Pretrial Documents will be stipulated to, requiring minimal intervention from
the Court.
WHEREAS, the Parties recognize that the present Pretrial Document deadline falls on a major
national holiday and shortly after the week-long Hannukah holiday. Due to these holidays, the offices
for both Parties’ counsel are operating minimally with counsel and staff out of the office to celebrate the
holidays. Furthermore, this period of time is particularly busy for Defendant Costco given the nature of
its large retail business, so it is particularly challenging for Defendant’s counsel to coordinate witnesses
and necessary pretrial preparations with its client during this time.
WHEREAS, after meeting and conferring, the Parties agree that a brief two-week extension of
the Pretrial Document deadline to January 8, 2025 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. This is the first 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.
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STIPULATION TO AMEND PRETRIAL DEADLINES; [PROPOSED] ORDER
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DATED: December 16, 2025 Respectfully submitted,
ILG LEGAL OFFICE, P.C.
By: /s/ Stephen Noel Ilg (as authorized 12/16/2025)___
Stephen Noel Ilg
Nicolas Jupillat
Attorneys for Plaintiff
ISABELLA ANDRADE
DATED: December 16, 2025 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 42 Filed 12/16/25 Page 3 of 4

STIPULATION TO AMEND PRETRIAL DEADLINES; [PROPOSED] ORDER
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[PROPOSED] 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 8, 2026.
Dated: December 16, 2025 ___ _______________________
U.S. District Court Magistrate Judge
Case 3:23-cv-06125-TSH Document 42 Filed 12/16/25 Page 4 of 4