Delsman v. General Electric Company

Filing 23

STIPULATION AND CASE MANAGEMENT SCHEDULING ORDER: Discovery due by 9/15/2010. Jury Trial set for 2/7/2011 08:30 AM. Motions due by 11/1/2010. Pretrial Conference set for 1/25/2011 01:00 PM.. Signed by Judge ARMSTRONG on 3/2/10. (lrc, COURT STAFF) (Filed on 3/3/2010)

Download PDF
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ABRAHAM N. GOLDMAN & ASSO C I A T E S LTD. ABRAHAM N. GOLDMAN, SBN 102080 ABRAHAM N. GOLDMAN & ASSOCIATES LTD Post Office Box 120 12896 Rices Crossing Road Oregon House, CA 95962-0120 Telephone: (530) 692-2267 Facsimile: (530) 692-2543 E-mail: agoldman@succeed.net Attorneys for Plaintiff ROB DELSMAN CONSTANCE E. NORTON, CA Bar No9. 146365 LITTLER MENDELSON, P.C. 650 California Street, 20th Floor San Francisco, CA 94108-2693 Telephone: (415) 433-1940 Email: cnorton@littler.com Attorneys for Defendant GENERAL ELECTRIC COMPANY UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA ROB DELSMAN, Plaintiff, v. GENERAL ELECTRIC COMPANY, Defendant. Case No. 09-cv-02414 SBA STIPULATED ORDER VACATING PRETRIAL DEADLINES & TRIAL DATE Courtroom: 1, 4th Floor Judge: Honorable Saundra B. Armstrong Trial Date: September 27, 2010 COMPLAINT FILED: June 1, 2009 TO THE HONORABLE COURT AND THE CLERK OF THE COURT: TAKE NOTICE THAT THE undersigned counsel of record for plaintiff and defendant hereby stipulate and request that the Court enter the following order forthwith: The parties jointly and respectfully request that: (1) Fact discovery cut-off and expert disclosure be continued from April 15, 2010 to September 15, 2010; (2) Expert discovery cut-off date be continued from May 28, 2010 to October 15, 2010; STIPULATED [PROPOSED] ORDER VACATING PRE-TRIAL DEADLINES & TRIAL DATE Case No. 09-cv-2414 SBA 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ABRAHAM N. GOLDMAN & ASSOCIATES, Ltd.. (3) The dispositive motion hearing cut-off date be continued from June 8, 2010 to November 1, 2010; (4) That the Court vacates and resets mandatory settlement conference of July 22, 2010, pretrial conference date of September 14, 2010 and trial date of September 27, 2010; This request is supported by the following: 1. proposed; 2. 3. 4. 5. Mediation was held in this case on October 28, 2009; Prior to the Mediation, discovery had not been vigorously pursued to allow for better On Wednesday, November 25, 2009, the day before Thanksgiving, plaintiff's eldest During the same timeframe of Mr. Delsman's mourning and grief, plaintiff's counsel, Discovery has been delayed due to reasons which are good cause for the continuance chances at early settlement at mediation; son, Rob Delsman, III, unexpectedly died; Abraham Goldman has had a significant amount of his time unavoidably taken from his law practice due to the discovery that his two minor children, a 15-year-old daughter and a 14-year-old son, had been sexually molested some years prior by a baby-sitter who was regularly employed during Mrs. Goldman's treatment and recovery from breast cancer. The discovery of these events resulted in a tremendous amount of Mr. Goldman's time being spent with his family, his children's well being, care and treatment, special therapeutic programs, and cooperation with the County Victim Witness Programs, Sheriff and District Attorney, fighting uncooperative insurers, and applications to the California Victim's Compensation fund; 6. The combination of these events significantly hindered plaintiff's ability to respond to defendant's discovery, and to initiate plaintiff's discovery, thus forming the foundation for this requested continuance. 7. Neither party has thus far unduly delayed the progress of this case. Both parties have litigated this matter in good faith by exchanging initial disclosure and by participating in the Court's mediation program. 8. For the above-listed reasons, the parties respectfully request that the dates set forth above be reset as stipulated by the parties, and the Court reset the settlement conference, pretrial and trial dates as meets the Court's availability. // Respectfully submitted, STIPULATED [PROPOSED] ORDER VACATING PRE-TRIAL DEADLINES & TRIAL DATE Case No. 09-cv-02414 SBA 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ABRAHAM N. GOLDMAN & ASSOCIATES, Ltd.. Dated: February 25, 2010 ABRAHAM N. GOLDMAN & ASSOCIATES LTD. /s/ Abraham N. Goldman ABRAHAM N. GOLDMAN Attorney for Plaintiff ROB DELSMAN Dated: February 25, 2010 LITTLER MENDELSON P.C. /s/ Constance E. Norton CONSTANCE E. NORTON J. MARK OGDEN Attorneys for Defendant GENERAL ELECTRIC COMPANY Based upon the stipulation of the parties, and good cause appearing, it is SO ORDERED. All of the deadlines listed in the Court Order for Pretrial Preparation (Docket No. 19) are hereby vacated. New dates are as follows: (1) Fact discovery cut-off and expert disclosure: September 15, 2010; (2) Expert discovery cut-off: October 15, 2010; (3) Dispositive motion cut-off date: November 1, 2010; (4) Settlement Conference: Between 11/1/10 and 1/3/11; (5) Pretrial Conference: 1/25/11 at 1:00 p.m.; (6) Trial Date: 2/7/11 at 8:30 a.m. Dated: 3/2/10 _____________________________________ SAUNDRA B. ARMSTRONG United States District Judge STIPULATED [PROPOSED] ORDER VACATING PRE-TRIAL DEADLINES & TRIAL DATE Case No. 09-cv-02414 SBA

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?