Bautista v. AON Benfield, Inc. et al

Filing 27

STIPULATION AND ORDER extending deadline for completion of mediation to and including 4/23/2010; Signed by Judge Mariliyn Hall Patel on 3/11/2010. (awb, COURT STAFF) (Filed on 3/11/2010)

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DAVID J. BECHT, SBN 104208 [e-mail] MICHAEL SACHS, SBN 235048 [e-mail] MYTHILY SIVARAJAH, SBN 252494 [e-mail] ADAMS | NYE | TRAPANI | BECHT LLP 222 Kearny Street, Seventh Floor San Francisco, California 94108-4521 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff MARIFI BAUTISTA MICHELLE B. HEVERLY, Bar No. 178660 [e-mail] ERICA H. KELLEY, Bar No. 221702 [e-mail] LITTLER MENDELSON A Professional Corporation 50 W. San Fernando, 15th Floor San Jose, CA 95113-2303 Telephone: [phone] Facsimile: [phone] Attorneys for Defendants AON BENFIELD INC. AND AON SERVICE CORPORATION UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

MARIFI BAUTISTA, Plaintiff, vs. AON BENFIELD, INC., AON SERVICE CORPORATION, AON CORPORATION, and DOES 1 through 100, inclusive, Defendants.

No. C 09-03270 MHP JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINE FOR MEDIATION

TO THE ABOVE-ENTITLED COURT: The parties, through their respective counsel, hereby advise this Court, and stipulate, as follows:
JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINE FOR MEDIATION

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In accordance with Local Rule 6-2, Plaintiff Marifi Bautista ("Plaintiff") and Defendants Aon Benfield Inc. and Aon Service Corporation ("Defendants") hereby stipulate and jointly move this Court for a brief extension of the mediation completion deadline set by this Court. The Parties request that the mediation completion deadline previously set for March 31, 2010 be extended through April 23, 2010. As grounds for this motion the Parties state the following: 1. This is a claim for Employment Discrimination, Violation of the Equal Pay Act;

Retaliation; Failure to Prevent Discrimination and Wrongful Termination related to Plaintiff's employment with Defendants. 2. The first Case Management Conference in this case took place on November 23, 2009.

At that Case Management Conference the Court ordered that private mediation in this case had to be completed by March 31, 2010 and that prior to this mediation the parties were limited to three depositions each and fifteen interrogatories and requests for production. 3. Discovery is actively underway. Plaintiff and Defendants have propounded written

discovery to each other and will begin scheduling depositions shortly. 4. Defendants' counsel, Erica Kelley, has a trial scheduled in Contra Costa County

beginning on March 18, 2010, which is anticipated to be three to four weeks in length.. 5. Given Defense counsel's unavailability at the end of March and early April, the Parties

do not believe they will be able to complete a meaningful mediation before the Court's deadline. 6. 7. The parties have a mediation scheduled with Michael J. Loeb for April 23, 2010. The Parties therefore request that the Court grant the Parties a brief extension to this

deadline, with the new deadline by which mediation must be completed as April 23, 2010. 8. 9. This is the first request for an extension to any deadline in this case. The only other date scheduled by the Court in this case is a further Case Management

Conference on April 26, 2010. This date will not need to be changed as the parties will have completed the mediation prior to this date. 10. extension.
JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINE FOR MEDIATION

Since both Parties stipulate to and join this motion, no party is prejudiced by this

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Accordingly, the Parties respectfully request that the Court grant the Parties' Stipulation and Joint Motion to extend the mediation deadline.

DATED: March 10, 2010

ADAMS | NYE | TRAPANI | BECHT LLP

By:

//s// Michael Sachs MICHAEL SACHS Attorneys for Plaintiff MARIFI BAUTISTA

DATED: March 10, 2010

LITTLER MENDELSON A Professional Corporation By: //s// Erica H. Kelley MICHELLE B. HEVERLY ERICA H. KELLEY Attorneys for Defendants AON BENFIELD INC. AND AON SERVICE CORPORATION

ORDER PURSUANT TO STIPULATION, IT IS SO ORDERED.

3/11 _________________, 2010

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JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINE FOR MEDIATION

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_______________________________________ RED The Honorable Marilyn H.RDE SO O Patel IT IS United States District Judge

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