Vivers v. Federal Aviation Administration et al

Filing 38

STIPULATION AND ORDER Continuing Status Conference. Status Report due by 11/7/2014. Status Conference set for 11/14/2014 10:00 AM in Courtroom 1, 17th Floor, San Francisco before Hon. Samuel Conti. Signed by Judge Samuel Conti on 06/12/2014. (tmi, COURT STAFF) (Filed on 6/12/2014)

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MELINDA HAAG (CABN 132612)
United States Attorney
ALEX G. TSE (CABN 152348)
Chief, Civil Division
MICHELLE LO (NY Bar No. 4325163)
Assistant United States Attorney

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450 Golden Gate Avenue, Box 36055
San Francisco, California 94102
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for the United States of America
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W. Christian Krankemann (CABN 220438)
Jon A.C. Vonder Haar (CABN 192665)
Krankemann Law Offices

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375 E Street, Suite 120
Santa Rosa, California 95404
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
Attorneys for Plaintiff

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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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CATHERINE VIVERS,
Plaintiff,

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Case No. 13-03444 SC
Related Case No. 13-03148 SC

v.
UNITED STATES OF AMERICA,
Defendant.

STIPULATION AND [PROPOSED]
ORDER TO CONTINUE STATUS
CONFERENCE AND JOINT STATUS
REPORT DEADLINE
IT IS SO ORDERED AS MODIFIED

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE
C 13-03444 SC
Related Case No. 13-03148 SC
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Plaintiff, Catherine Vivers, and Defendant, the United States of America, by and through their

2 undersigned attorneys, hereby stipulate as follows:
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1.

At the initial case management conference held on March 7, 2014, the Court directed the

4 parties to file a stipulation and proposed order for mediation once they agreed on a potential mediator.
5 The parties held phone conferences with the ADR Program Legal Staff on April 7, 2014, and June 10,
6 2014. Due to a procedural misunderstanding, however, the parties did not file their stipulation and
7 proposed order for mediation until today, June 10, 2014. See ECF No. 35.
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2.

At the March 7, 2014, initial case management conference, the Court also set a further

9 status conference for Friday, June 20, 2014, at 10 a.m., and ordered the parties to file an updated status
10 report by June 13, 2014. ECF No. 31.
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3.

Because the parties have not had an opportunity to engage in the ADR process to date,

12 they have requested a period of 90 days in which to schedule mediation and conduct limited discovery to
13 facilitate meaningful discussions. In light of these circumstances, the parties respectfully request that
14 the Court continue the status conference scheduled for June 20, 2014, to September 26, 2014, or such
15 later date as the Court’s calendar permits.
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4.

The parties will work in good faith to mediate the case prior to a further status conference

17 on September 26, 2014, or such later date as the Court may set.
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5.

Accordingly, the parties hereby agree and stipulate to a continuance of the status

19 conference scheduled to September 26, 2014, and the related joint status report deadline to September
20 19, 2014, or such later date as the Court may set, and request that the Court order the same.
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SO STIPULATED.

22 DATED: June 10, 2014

Respectfully submitted,

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MELINDA HAAG
United States Attorney

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/s/ Michelle Lo
MICHELLE LO
Assistant United States Attorney
Attorneys for the United States of
America

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE
C 13-03444 SC
Related Case No. 13-03148 SC
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1 DATED: June 10, 2014

KRANKEMANN LAW OFFICES

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/s/ Jon A.C. Vonder Haar
JON A.C. VONDER HAAR
Attorneys for Plaintiff

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*I, Michelle Lo, attest that I have obtained concurrence in the filing of this document from Plaintiff’s
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counsel, Jon Vonder Haar.
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/s/ Michelle Lo
Michelle Lo

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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November 14,
The further status conference scheduled for June 20, 2014, at 10 a.m. is continued to September 26,

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2014, at 10 a.m. The parties shall file a joint status report at least seven days prior to the conference.
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UNIT
ED

The Honorable Samuel D
Conti
ERE
United States DistrictD
O ORD Judge
IT IS S
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amuel C

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Judge S

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13 DATED: 06/12/2014

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D IS T IC T O
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STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE
C 13-03444 SC
Related Case No. 13-03148 SC
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C

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