Navarrette et al v. United States Of America

Filing 71

ORDER GRANTING 70 Joint Motion to Extend Deadline for Completion of Mediation. Signed by Judge Jeffrey S. White on 2/3/09. (jjo, COURT STAFF) (Filed on 2/3/2009)

Case 3:04-cv-00760-JSW

Document 70

Filed 02/02/2009

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BARBARA BOZMAN-MOSS (CSBN 129275) Bozman-Moss & Watson 700 College Avenue Santa Rosa, California 95404-4107 Tel: [phone] Fax: [phone] E-mail: [e-mail] Attorney for Plaintiffs JOSEPH P. RUSSONIELLO (CSBN 44332) United States Attorney JOANN M. SWANSON (CSBN 88143) Chief, Civil Division ELLEN M. FITZGERALD (NY 2408805) Assistant United States Attorney 450 Golden Gate Avenue, Box 36055 San Francisco, CA 94102-3495 Tel: [phone] Fax: [phone] E-mail: [e-mail] Attorneys for Defendant

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION RICHARDO ANGEL NAVARRETTE and KELLY KASLAR, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. STIPULATION AND JOINT MOTION TO EXTEND DEADLINE FOR COMPLETION OF MEDIATION; [PROPOSED] ORDER CASE NO. C 04-0760 JSW

Subject to this Court's approval, plaintiff, Ricardo Angel Navarrette, and defendant, the United States of America, by and through their undersigned counsel, hereby stipulate and agree to continue the deadline for completion of court-connected mediation to March 6, 2009. This Federal Tort Claims Act case is currently set for bench trial beginning on April 27, 2009. The pre-trial
STIPULATION AND JOINT MOTION TO EXTEND DEADLINE FOR COMPLETION OF MEDIATION C 04-0760 JSW

Case 3:04-cv-00760-JSW

Document 70

Filed 02/02/2009

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conference will take place on April 6, 2009. This request will cause no change to the pre-trial conference date or the trial date. The parties have completed factual discovery. The additional time is necessary to allow the parties to complete expert witness depositions. As currently scheduled, the last expert deposition in this matter is scheduled for February 27, 2009. In the absence of all expert testimony, the parties agree they lack sufficient information to engage in a meaningful mediation session. The parties conferred with the mediator, Christopher Johns, and scheduled a mediation session for March 6, 2009. The parties therefore jointly request that the Court extend the deadline for the completion of court-connected mediation from February 27, 2009 until March 6, 2009. IT IS SO STIPULATED. Dated: February 2, 2009 Respectfully submitted, JOSEPH RUSSONIELLO United States Attorney By: __________/s/____________ ELLEN M. FITZGERALD Assistant United States Attorney Attorney for Defendant BOZMAN-MOSS & WATSON By:____________/s/______________ BARBARA BOZMAN-MOSS Attorney for Plaintiff APPROVED AND SO ORDERED. The Court hereby extends the deadline for court-connected mediation until March 6, 2009. All other dates remain the same. February 3 Dated: ________________, 2009 ___________________________ HON. JEFFREY S. WHITE United States District Judge

STIPULATION AND JOINT MOTION TO EXTEND DEADLINE FOR COMPLETION OF MEDIATION C 04-0760 JSW