Vallimont v. Chevron Research and Technology Co. et al

Filing 30

ORDER GRANTING 29 Stipulation Continuing deadline to file motion to compel. Signed by Judge Jeffrey S. White on 3/9/09. (jjo, COURT STAFF) (Filed on 3/9/2009)

Case 3:08-cv-01227-JSW

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BETH A. HUBER (SBN 184702) THE HUBER LAW FIRM 1104 LINCOLN AVE San Rafael, CA 94901 Telephone: [phone] Facsimile: [phone] DAVID SHANE (SBN 109890) SHANE & TAITZ 1000 Drakes Landing Road, Suite 200 Greenbrea, CA 94904-3027 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff STEPHEN VALLIMONT ROBERT D. EASSA (SBN 107970) DELIA A. ISVORANU (SBN 226750) FILICE BROWN EASSA & McLEOD LLP 1999 Harrison Street, Suite 1800 Oakland, California 94612-0850 Telephone: [phone] Facsimile: [phone] Attorneys for Defendants CHEVRON ENERGY TECHNOLOGY COMPANY AND JIM EVERARD UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA STEPHEN VALLIMONT, Plaintiff, v. CHEVRON RESEARCH & TECHNOLOGY and JIM EVERARD, Defendants. ______________________________________/ The parties, Plaintiff STEPHEN VALLIMONT ("Plaintiff") and Defendant CHEVRON RESEARCH & TECHNOLOGY ("Defendant"), do by and through their respective counsel,
STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINE TO FILE MOTION TO COMPEL; MEDIATION 1

Case No. C 08-01227 JSW STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINE TO FILE MOTION TO COMPEL; MEDIATION Trial Date: June 15, 2009

Case 3:08-cv-01227-JSW

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stipulate and agree the deadline for any motions to compel would be continued to March 17, 2009 based on Local Rule 26-2; (iii) the deadline to complete mediation would be continued to April 17, 2009. The parties make this request for good cause, including because (1) the parties have met and conferred and Defendant has agreed to supplement its responses to Plaintiff's first set of written discovery with said supplementation to occur on or about March 10, 2009; (2) the parties prefer to consolidate all outstanding discovery issues to the Court in one letter motion instead of filing multiple letter motions with the Court; and (3) the parties are just completing witness depositions in this matter with at least one to be taken at an unknown time due to health concerns of the witness and (4) Plaintiff and Defendant are meeting and conferring on Plaintiff's second set of written discovery. Dated: March 9, 2009 By: HUBER LAW FIRM _____/s/___________________________ Beth Huber Attorneys for Plaintiff, STEPHEN VALLIMONT FILICE BROWN EASSA & McLEOD By: _____/s/____________________________ Robert D. Eassa Delia A. Isvoranu Attorneys for Defendants, CHEVRON RESEARCH & TECHNOLOGY and JIM EVERARD

Dated: March 9, 2009

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STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINE TO FILE MOTION TO COMPEL; MEDIATION 2

Case 3:08-cv-01227-JSW

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[PROPOSED] ORDER After reviewing the parties' stipulation and good cause appearing therefore, discovery disputes IT IS HEREBY ORDERED that the deadline to file a motion to compel is continued to March 17, 2009 and the deadline to complete mediation is continued to April 17, 2009. 9 DATED: March ______, 2009 ____________________________________ JEFFREY S. WHITE, Judge United States District Court

STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINE TO FILE MOTION TO COMPEL; MEDIATION 3