Cox v. Electronic Data Systems Corporation

Filing 34

STIPULATION AND ORDER EXTENDING TIME FOR COMPLETING MEDIATION. Signed by Judge Alsup on February 10, 2009. (whalc1, COURT STAFF) (Filed on 2/10/2009)

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Case 3:08-cv-03927-WHA Document 33 Filed 02/06/2009 Page 1 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 LIT T LE R ME N D E LS O N A PR O F E S S I O N A L C O R P O R A T I O N 650 C a l i fo r n ia Stre e t 20th F l o or Sa n F ra n c i s co , C A 94108. 2 69 3 415. 43 3 . 19 4 0 ROBERT L. ZALETEL, Bar No. 096262 LITTLER MENDELSON A Professional Corporation 650 California Street, 20th Floor San Francisco, CA 94108.2693 Telephone: 415.433.1940 LEE HUTTON, Ohio Bar No. 0006794 LITTLER MENDELSON A Professional Corporation 1100 Superior Avenue, 20th Floor Cleveland, OH 44114 Telephone: 216.696.7600 (Admitted Pro Hac Vice) Attorneys for Defendant ELECTRONIC DATA SYSTEMS L.L.C., formerly known as ELECTRONIC DATA SYSTEMS CORPORATION UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA DONNIE COX, Plaintiff, v. ELECTRONIC DATA SYSTEMS CORPORATION; and DOES 1 through 10, inclusive, Defendants. Case No. CV 08 3927 WHA STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR COMPLETING MEDIATION WHEREAS, this is a wrongful discharge case brought by a former employee of Defendant; and WHEREAS, on January 28, 2009, this matter was referred to Jo Anne Dellaverson for mediation; and WHEREAS, on February 2, 2009, the parties held a pre-mediation conference call with the Court-appointed mediator, Jo Anne Dellaverson, to discuss dates for the mediation; and STIP. & [PROPOSED] ORDER EXTENDING TIME FOR COMPLETING MEDIATION CASE NO. CV 08 3927 WHA Case 3:08-cv-03927-WHA Document 33 Filed 02/06/2009 Page 2 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 WHEREAS, Plaintiff's Complaint contains claims for wrongful discharge, interference with prospective business advantage, conversion, and other claims under various statutes; and WHEREAS, both Parties believe that they need to conduct several depositions and receive responses to written discovery (some of which is pending) before a meaningful mediation can take place; and WHEREAS, the Parties have scheduled several key depositions to take place between March 25 and 27; but need time to arrange additional depositions of out-of-state witnesses; WHEREAS, the Parties believe that the current April 8, 2009 deadline for completing mediation will not give sufficient time to conduct adequate discovery to allow for a meaningful mediation; and WHEREAS, the Parties have tentatively scheduled mediation with Ms. Dellaverson for May 8, 2009 (subject to the Court extending the time to complete mediation). THEREFORE, the Parties request that the Court extend the time for completing mediation from April 8, 2009, to May 8, 2009. IT IS SO STIPULATED. DATED: February 6, 2009 /s/ Dean Royer DEAN ROYER Attorney for Plaintiff DONNIE COX /s/ Robert L. Zaletel ROBERT L. ZALETEL Attorney for Defendant ELECTRONIC DATA SYSTEMS, L.L.C. PROPOSED ORDER For good cause appearing, the Parties shall have through May 8, 2009 to complete mediation in this case. UNIT ED S DISTRICT TE C TA 18 19 20 DATED: February 6, 2009 21 22 23 24 25 26 27 DATED: February 10, 2009 28 LIT T LE R ME N D E LS O N A PR O F E S S I O N A L C O R P O R A T I O N 650 C a l i fo r n ia Stre e t 20th F l o or Sa n F ra n c i s co , C A 94108. 2 69 3 415. 43 3 . 19 4 0 RT U O IT IS SO ORDERED. S N F D IS T IC T O R A STIP. & [PROPOSED] ORDER EXTENDING TIME FOR COMPLETING MEDIATION ER C LI 2. CASE NO. CV 08 3927 WHA FO THE HONORABLE WILLIAMuH. ALSUP Als p Judge W illiam R NIA OO IT IS S RDERE D NO RT H Case 3:08-cv-03927-WHA Document 33 Filed 02/06/2009 Page 3 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 LIT T LE R ME N D E LS O N A PR O F E S S I O N A L C O R P O R A T I O N 650 C a l i fo r n ia Stre e t 20th F l o or Sa n F ra n c i s co , C A 94108. 2 69 3 415. 43 3 . 19 4 0 PROOF OF SERVICE I am a resident of the State of California, over the age of eighteen years, and not a party to the within action. My business address is 650 California Street, 20th Floor, San Francisco, California 94108.2693. On February 6 2009, I served the within document(s): STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR COMPLETING MEDIATION by facsimile transmission at or about ______________ on that date. This document was transmitted by using a facsimile machine that complies with California Rules of Court Rule 2003(3), telephone number 415.399.8490. The transmission was reported as complete and without error. A copy of the transmission report, properly issued by the transmitting machine, is attached. The names and facsimile numbers of the person(s) served are as set forth below. by placing a true copy of the document(s) listed above for collection and mailing following the firm's ordinary business practice in a sealed envelope with postage thereon fully prepaid for deposit in the United States mail at San Francisco, California addressed as set forth below. Jo Anne Dellaverson Law Offices of Jo Anne Dellaverson 81 Throckmorton Avenue Suite 203 Mill Valley, CA 94941 jad@dellaverson.com Alice M. Fiel ADR Case Administrator U.S. District Court Northern District of California 450 Golden Gate Avenue San Francisco, CA 94102 Alice_Fiel@cand.uscourts.gov I am readily familiar with the firm's practice of collection and processing correspondence for mailing and for shipping via overnight delivery service. Under that practice it would be deposited with the U.S. Postal Service or if an overnight delivery service shipment, deposited in an overnight delivery service pick-up box or office on the same day with postage or fees thereon fully prepaid in the ordinary course of business. I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on February 6, 2009, at San Francisco, California. /s/ Gabriela Martin Gabriela Martin Firmwide:88379273.1 056073.1009 PROOF OF SERVICE CASE NO. CV 08 3927 WHA

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