Gebhardt v. Chu et al

Filing 40

ORDER EXTENDING MEDIATION DEADLINE. Signed by Judge Maria-Elena James on 4/18/2011. (cdnS, COURT STAFF) (Filed on 4/18/2011)

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BRYAN SCHWARTZ, Bar No. 209903
HILLARY BENHAM-BAKER, Bar No. 265019
BRYAN SCHWARTZ LAW
180 Grand Avenue, Ste. 1550
Oakland, CA 94612
Telephone: [phone]
E-mail:
[e-mail]
E-mail:
[e-mail]
Attorneys for Plaintiff
NANCY E. PRITIKIN, Bar No. 102392
SHANNON M. GIBSON, Bar No. 256634
LITTLER MENDELSON
A Professional Corporation
650 California Street, 20th Floor
San Francisco, CA 94108.2693
Telephone:
415.433.1940
E-mail:
[e-mail]
E-mail:
[e-mail]
Attorneys for Defendant
NORTHROP GRUMMAN SYSTEMS CORP.
MELINDA. HAAG, Bar No. 132612
United States Attorney
JOANNE SWANSON, Bar No. 88143
Chief, Civil Division
ABRAHAM A. SIMMONS, Bar No. 146400
Assistant United States Attorney
450 Golden Gate Avenue, 9th Floor
San Francisco, CA 94102-3495
Telephone: [phone]
Facsimile:
415.436.6748
Email:
[e-mail]
Attorneys for Federal Defendant

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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GARNETT A. GEBHARDT,
Plaintiff,
v.
STEVEN CHU, SECRETARY, UNITED
STATES DEPARTMENT OF ENERGY,
and NORTHROP GRUMMAN CORP.,

Case No. CV-10-2807 (MEJ)
STIPULATION AND PROPOSED ORDER
EXTENDING DEADLINE FOR
MEDIATION
Judge:
Complaint Filed:

Hon. Maria-Elena James
June 25, 2010

Defendants.
STIPULATION AND PROPOSED ORDER
EXTENDING DEADLINE FOR
MEDIATION

Case No. CV 10 2807 (MEJ)

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All parties, by and through their attorneys of record, hereby stipulate as follows:

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WHEREAS, this Court entered an Order on February 4, 2011, referring the Parties to

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court-sponsored mediation, and issued a Notice on February 15, 2011, appointing Linda McSweyn

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as Mediator;
WHEREAS, the Parties are required to complete mediation on or before May 5, 2011,

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pursuant to ADR L.R. 6-4;

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WHEREAS, the Parties have collectively participated in two telephonic conference

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calls, and several others independently, with the Mediator to resolve pending discovery issues and to

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discuss a timeline for moving the case forward as expeditiously as possible;
WHEREAS, the Parties have diligently pursued, but not yet completed, the exchange

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of written discovery and the depositions of key witnesses;

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WHEREAS, the Parties agree that conducting any mediation prior to the completion

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of said discovery and depositions would impair the chances of a productive mediation and possible

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settlement;
WHEREAS, the Parties jointly request that the Court extend the deadline by which

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mediation is to be completed;

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WHEREAS, the Parties agree that extending the deadline for mediation would serve

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the interests of judicial economy and not cause any prejudice or interfere with any other court-

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imposed deadlines; and

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WHEREAS, the Parties have scheduled mediation for the week of July 18, 2011;

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THEREFORE IT IS HEREBY STIPULATED by and between the Parties, through

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their respective counsel, that:

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1.

The deadline for the Parties to complete mediation shall be extended from

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May 5, 2011 until July 29, 2011.

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///

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///

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///

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///
STIPULATION AND PROPOSED ORDER
EXTENDING DEADLINE FOR
MEDIATION

1.

Case No. CV 10 2807 (MEJ)

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Dated: April 15, 2011

BRYAN SCHWARTZ LAW

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/s/ Bryan Schwartz
Bryan Schwartz, Bar No. 209903
Attorney for Plaintiff

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Dated: April 15, 2011

LITTLER MENDELSON
A Professional Corporation

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/s/ Shannon M. Gibson
Shannon M. Gibson, Bar No. 256634
Attorneys for Defendant
Northrop Grumman Systems Corp.

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Dated: April 15, 2011

MELINDA HAAG
United States Attorney

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/s/ Abraham A. Simmons
Abraham A. Simmons, Bar No. 146400
Assistant United States Attorney
Attorneys for Federal Defendant

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ORDER
GOOD CAUSE APPEARING, IT IS HEREBY ORDERED that the Parties’ Stipulation,
above, is approved and adopted as the Order of this Court, as follows:
1.

The deadline by which the Parties must complete mediation shall be extended from

May 5, 2011, until July 29, 2011.
IT IS SO ORDERED.
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Dated: April ___ , 2011

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Maria-Elena James
CHIEF UNITED STATES MAGISTRATE JUDGE

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Firmwide:101139045.1 050231.1004

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STIPULATION AND PROPOSED ORDER
EXTENDING DEADLINE FOR
MEDIATION

2.

Case No. CV 10 2807 (MEJ)