White v. City and County of San Francisco et al

Filing 27

STIPULATION AND ORDER TO EXTEND TIME FOR COMPLETION OF MEDIATION AND TO CONTINUE DATE OF CASE MANAGEMENT CONFERENCE re 26 Stipulation filed by James B. White. Signed by Judge Phyllis J. Hamilton on 1/4/10. (nah, COURT STAFF) (Filed on 1/4/2010)

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JOHN L. BURRIS, Esq./ State Bar # 69888
LAW OFFICES OF JOHN L. BURRIS 7677 Oakport Street, Suite 1120 Oakland, CA 94621 Telephone: [phone] Facsimile: [phone]

GAYLA B. LIBET, Esq./ State Bar # 109173
LAW OFFICES OF GAYLA B. LIBET 486 41st Street, Suite 3 Oakland, CA 94609 Telephone and Facsimile: [phone]

Attorneys for Plaintiff JAMES WHITE DENNIS J. HERRERA/ State Bar # 139669 City Attorney JOANNE HOEPER/ State Bar # 114961 Chief Trial Deputy CELIA W. LEE/ State Bar # 172981
Deputy City Attorney Office of San Francisco City Attorney 1390 Market Street, Sixth Floor San Francisco, CA 94102-5408 Telephone: [phone] Facsimile: [phone]

Attorneys for Defendants CITY AND COUNTY OF SAN FRANCISCO; HEATHER FONG; DERRICK J. LEW; DAVID CORREA; and AJAY SINGH UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA

JAMES B. WHITE, Plaintiff, vs. CITY AND COUNTY OF SAN FRANCISCO, a municipal corporation; et al. Defendants.

Case No. C 08-05419 PJH STIPULATION AND (PROPOSED) ORDER TO EXTEND TIME FOR COMPLETION OF MEDIATION AND TO CONTINUE DATE OF CASE MANAGEMENT CONFERENCE

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STIPULATION AND PROPOSED ORDER TO EXTEND TIME FOR COMPLETION OF MEDIATION AND TO CONTINUE DATE OF CASE MANAGEMENT CONFERENCE

Case No. C 08-05419 PJH

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STIPULATION

ALL PARTIES TO THIS ACTION STIPULATE AND AGREE, BY AND THROUGH THEIR RESPECTIVE COUNSEL, AS FOLLOWS:

1. Defense counsel was ill for an extended time, and then was tied up with extensive work to be done in many cases. Thus, defense counsel has served written discovery by mail on plaintiff's counsel on December 30, 2009. Plaintiff's counsel is in the process of meeting and conferring with defense counsel regarding discovery issues, namely: Defendants' responses to written discovery which plaintiff finds inadequate and incomplete. Plaintiff's counsel will write a letter detailing what is requested to be produced and responded to, and the relevant case law. Further, defense counsel has drafted a Stipulated Protective Order which all counsel are finalizing so that it may be E-filed shortly, and aid in the discovery process. Counsel have not yet conducted key depositions in this case. Therefore, the above-referenced discovery and discovery issues need to be addressed and completed before any meaningful mediation can occur.

2. The Mediator in this matter, Christopher Johns, Esq., has engaged in a telephone conference with counsel, and we all have agreed to the need to request an extension of time for completion of mediation, and agreed to a new date for the Mediation: March 1, 2010, at 9:00 a.m. Therefore, it would be advantageous to re-schedule the next Case Management Conference from the presently scheduled date of January 7, 2010 to a date in March 2010, following the completion of the Mediation; and,

3. Therefore, good cause appearing, and counsel and Mediator have conferred and agreed, the parties request that this Court continue the Case Management Conference presently scheduled for March 25, 2010 at 2:00 p.m. Thursday, January 7, 2010 at 2:30 p.m. to a Thursday in mid or late March 2010 at 2:30 p.m., and to extend time for completion of Mediation from December 31, 2009 to March 1, 2010.

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STIPULATION AND PROPOSED ORDER TO EXTEND TIME FOR COMPLETION OF MEDIATION AND TO CONTINUE DATE OF CASE MANAGEMENT CONFERENCE

Case No. C 08-05419 PJH

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Respectfully submitted, LAW OFFICES OF GAYLA B. LIBET

Dated: December 30, 2009

By: /S/ GAYLA B. LIBET, Esq. Attorneys for Plaintiff

LAW OFFICES OF JOHN L. BURRIS

Dated: December 30, 2009

By:___/S/____________________________ JOHN L. BURRIS, Esq. Attorneys for Plaintiff

DENNIS J. HERRERA, City Attorney JOANNE HOEPER, Chief Trial Deputy CELIA W. LEE, Deputy City Attorney

Dated: December 30, 2009

By: /S/ CELIA W. LEE, Esq. Attorneys for Defendants

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STIPULATION AND PROPOSED ORDER TO EXTEND TIME FOR COMPLETION OF MEDIATION AND TO CONTINUE DATE OF CASE MANAGEMENT CONFERENCE

Case No. C 08-05419 PJH

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ATTORNEY ATTESTATION

I hereby attest that I have on file all holograph signatures for any signatures indicated

by a conformed signature, indicated as "/s/ " within this E-filed document.

By:/S/ GAYLA B. LIBET, Esq.

ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.

UNIT ED

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S

S DISTRICT TE C TA

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F D IS T IC T O R

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HONORABLE PHYLLISiltJ. HAMILTON n Ham o hy s J. Judge P United States Districtlli Court Judge
FO
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Dated: 1/4/10

IT IS S

ERED O ORD

RT U O

STIPULATION AND PROPOSED ORDER TO EXTEND TIME FOR COMPLETION OF MEDIATION AND TO CONTINUE DATE OF CASE MANAGEMENT CONFERENCE

RT

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