Charles v. Best Buy Co., Inc.

Filing 27

ORDER APPROVING STIPULATION. The deadline to complete mediation is continued to April 30, 2013, and the discovery cutoff is continued to July 19, 2013. Signed by Judge Maxine M. Chesney on February 25, 2013. (mmclc1, COURT STAFF) (Filed on 2/25/2013)

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1 2 3 4 5 6 7 8 SEYFARTH SHAW LLP Michael J. Burns (SBN 172614) mburns@seyfarth.com Eden Anderson (SBN 233464) eanderson@seyfarth.com 560 Mission Street, 31st Floor San Francisco, California 94105 Telephone: (415) 397-2823 Facsimile: (415) 397-8549 Attorneys for Defendant BEST BUY STORES, L.P. (erroneously sued as "BEST BUY CO., INC.") 10 LAW OFFICES OF SHARON COHEN Sharon Cohen (SBN 209608) 1385 Ridgewood Drive, Suite 110 Chico, California 95973 Telephone: (530) 345-6343 11 Attorney for Plaintiff 9 12 UNITED STATES DISTRICT COURT 13 NORTHERN DISTRICT OF CALIFORNIA 14 15 SHAUN CHARLES, 16 Plaintiff, 17 v. 18 19 BEST BUY CO., INC., and DOES 1 to 50, inclusive, Case No. C 12-02934 MMC STIPULATION TO CONTINUE MEDIATION DEADLINE BY 30 DAYS AND DISCOVERY CUTOFF DEADLINE BY 60 DAYS; [PROPOSED] ORDER THEREON Defendants. 20 21 22 23 24 Plaintiff Shaun Charles and Defendant Best Buy Stores, L.P., collectively “the Parties”, by and through their counsel, stipulate and agree as follows: 1. WHEREAS, this action was filed with the Alameda County Superior Court on 25 April 27, 2012 and removed to the United States District Court for the Northern District of 26 California on June 6, 2012. 27 28 STIPULATION TO CONTINUE MEDIATION DEADLINE BY 30 DAYS AND DISCOVERY CUTOFF DEADLINE BY 60 DAYS; [PROPOSED] ORDER THEREON CASE NO. C 12-02934 MMC 1 2 3 2. WHEREAS, on September 12, 2012, the Court issued an Order Selecting ADR Process, setting March 29, 2013 as the deadline for the Parties to complete private mediation. 3. WHEREAS, an initial Case Management Conference was held on September 21, 4 2012. The Court set May 24, 2013 as the discovery cutoff, August 2, 2013 as the deadline for 5 filing dispositive motions, and November 4, 2013 as the trial date. 6 7 8 9 4. WHEREAS, Defendant served written discovery in October 2012 and received, after granting an extension of time to respond, responses thereto in December 2012. 5. WHEREAS, after a period of illness, Plaintiff’s counsel’s mother passed away in January 2013, leading to some delay in discovery. While Plaintiff has served Requests for 10 Production of Documents and received responses thereto, Plaintiff served Special Interrogatories 11 on February 5, 2013. 12 13 14 15 16 6. WHEREAS, written discovery and some depositions are needed to help facilitate mediation. 7. WHEREAS, the Parties have selected Dan Quinn Esq. to serve as mediator and have reserved April 26, 2013 for a full day of mediation with Mr. Quinn. 8. WHEREAS, an April 26, 2013 mediation date leaves less than a month before the 17 May 24, 2013 discovery cutoff, and the Parties would prefer to conserve resources and not engage 18 in all necessary discovery prior to mediation. 19 NOW THEREFORE, all Parties hereto stipulate and agree, and request, that the Court 20 enter an Order continuing the mediation deadline by 30 days and the discovery cutoff deadline by 21 60 days. The mediation deadline shall be ______________. The discovery cutoff shall be 22 _________________. 23 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 24 25 26 27 28 2 STIPULATION TO CONTINUE MEDIATION DEADLINE BY 30 DAYS AND DISCOVERY CUTOFF DEADLINE BY 60 DAYS; [PROPOSED] ORDER THEREON CASE NO. C 12-02934 MMC 1 DATED: February 21, 2013 Respectfully submitted, 2 SEYFARTH SHAW LLP 3 4 By: /s/ Eden Anderson Michael J. Burns Eden Anderson Attorneys for Defendant BEST BUY STORES, L.P. (erroneously sued as "BEST BUY CO., INC.") 5 6 7 LAW OFFICES OF SHARON COHEN Sharon Cohen (SBN 209608) 1385 Ridgewood Drive, Suite 110 Chico, California 95973 Telephone: (530) 345-6343 8 9 10 Attorney for Plaintiff 11 12 DATED: February 21, 2013 LAW OFFICES OF SHARON COHEN 13 14 By:/s/ Sharon Cohen Sharon Cohen Attorney for Plaintiff 15 16 17 18 19 PURSUANT TO STIPULATION, IT IS SO ORDERED. Specifically, the deadline to complete mediation is continued to April 30, 2013, and the discovery cutoff is continued to July 19, 2013. DATED: _________________________________ United States District Judge Dated: February 25, 2013 14751987v.1 20 21 22 23 24 25 26 27 28 3 STIPULATION TO CONTINUE MEDIATION DEADLINE BY 30 DAYS AND DISCOVERY CUTOFF DEADLINE BY 60 DAYS; [PROPOSED] ORDER THEREON CASE NO. C 12-02934 MMC

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