Gary Daniel James Kennedy v. James Ruben Bedgood et al

Filing 29

STIPULATION AND ORDER re 28 STIPULATION WITH PROPOSED ORDER to Continue Mediation Deadline and Further CMC filed by Gary Daniel James Kennedy. Case Management Statement due by 6/30/2016. Further Case Management Conference reset for 7/7/2016 10:30 AM in Courtroom 5, 17th Floor, San Francisco. Signed by Judge Edward M. Chen on 2/16/16. (bpf, COURT STAFF) (Filed on 2/16/2016)

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JOHN L. BURRIS, Esq. (SBN 69888)
DeWITT M. LACY, Esq. (SBN 258789)
LATEEF H. GRAY, Esq. (SBN 250055)
THE LAW OFFICES OF JOHN L. BURRIS
Airport Corporate Center
7677 Oakport St., Suite 1120
Oakland, CA 94621
T: [phone]
F: [phone]
[e-mail]
[e-mail]
[e-mail]

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Attorneys for Plaintiff
GARY DANIEL JAMES KENNEDY

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7677 Oakport Street, Suite 1120
Oakland, California 94621
Telephone: [phone]

The Law Offices of John L. Burris

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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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GARY DANIEL JAMES KENNEDY,
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Plaintiff,
vs.

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Case No.: 3:15-cv-01404-EMC
STIPULATON AND [PROPOSED]
ORDER CONTINUING DEADLINE FOR
MEDIATION AND FURTHER CASE
MANAGEMENT CONFERENCE

JAMES RUBEN BEDGOOD, et al
Defendants.

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TO THE COURT AND TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

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IT IS HEREBY STIPULATED AND AGREED by and between Plaintiff GARY

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DANIEL JAMES KENNEDY and Defendants JAMES RUBEN BEDGOOD, et al, through

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their counsel of record as follows:

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WHEREAS the parties are respectfully requesting that the Court continue the

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deadline for mediation and the further case management conference for several months until
STIPULATON AND [PROPOSED] ORDER CONTINUING DEADLINE FOR MEDIATION

3:15-cv-01404-EMC
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the parties have had sufficient time to conduct further discovery and go forward with

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mediation;

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WHEREAS currently, this matter has a deadline to mediate by February 29, 2016
(per ECF 27);
WHEREAS this matter currently has a further case management conference set for

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March 10, 2016. The parties also request that the further case management conference be

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continued to a date to follow mediation.
WHEREAS Plaintiff is not in the condition to fully participate in mediation;

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WHEREAS the immediate family of Plaintiff intends to begin the process of

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7677 Oakport Street, Suite 1120
Oakland, California 94621
Telephone: [phone]

The Law Offices of John L. Burris

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obtaining conservatorship over Plaintiff;
WHEREAS good cause exists to continue the mediation deadline and further case
management conference;
In the interests of judicial economy and justice, all would benefit from a continuance

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of the mediation deadline to a date in June of 2016 and the further case management

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conference to follow in July of 2016.

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Dated: February 12, 2016

LAW OFFICES OF JOHN L. BURRIS

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By___/s/ Lateef H. Gray______________
LATEEF H. GRAY
Attorney for Plaintiff

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Dated: February 12, 2016

McNAMERA, NEY, BEATTY,
SLATTERY, BORGES, & AMBACHER,
LLP

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By___*/s/____________________________
JAMES V. FITZGERALD III/ NOAH
G. BLECHMAN/ ELIZABETH M.
DOOLEY
Attorneys for Defendants
*Mr. Blechman has given his permission
for this document to be filed
electronically.

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STIPULATON AND [PROPOSED] ORDER CONTINUING DEADLINE FOR MEDIATION

3:15-cv-01404-EMC
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[PROPOSED] ORDER

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Pursuant to the foregoing stipulation between the parties, the Court orders the

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mediation deadline continued to June _____, 2016. The further case management conference

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July 7
set for March 10, 2016 at 10:30 a.m. is hereby continued to _________________, 2016 at

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10:30 a.m.
__________. The parties are to file an updated Case Management Statement one week prior

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to the conference.

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___________________________________
HONORABLE EDWARD henCHEN
C M.
ard M.
dge Edw
Ju

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Dated: February ____, 2016

UNIT
ED

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7677 Oakport Street, Suite 1120
Oakland, California 94621
Telephone: [phone]

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ERED
O ORD D
IT IS S
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AS MO

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The Law Offices of John L. Burris

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IT IS SO ORDERED.

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STIPULATON AND [PROPOSED] ORDER CONTINUING DEADLINE FOR MEDIATION

3:15-cv-01404-EMC
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