Raman v. City and County of San Francisco et al

Filing 122

STIPULATION AND ORDER TO EXTEND ENE DEADLINE re 121 Stipulation filed by City and County of San Francisco. Signed by Judge Phyllis J. Hamilton on 8/17/10. (nah, COURT STAFF) (Filed on 8/17/2010)

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DENNIS J. HERRERA, State Bar #139669 City Attorney ELIZABETH S. SALVESON, State Bar #83788 Chief Labor Attorney JONATHAN C. ROLNICK, State Bar #151814 LAUREN M. MONSON, State Bar #242819 Deputy City Attorney Fox Plaza 1390 Market Street, 5th Floor San Francisco, California 94102-5408 Telephone: [phone] Facsimile: [phone] E-Mail: [e-mail] Attorneys for Defendant CITY AND COUNTY OF SAN FRANCISCO

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SHANIA RAMAN, Plaintiff, vs. THE CITY AND COUNTY OF SAN FRANCISCO, a municipality and political subdivision of the State of California, and BRYAN THOMASSON, an individual, Defendant(s). Case No. C10-0752PJH STIPULATION TO EXTEND ENE DEADLINE AND PROPOSED ORDER Trial Date: October 24, 2011

PLEASE TAKE NOTICE that Defendant City and County of San Francisco ("Defendant") respectfully files this request for an extension of the deadline to complete an early neutral evaluation ("ENE") in this matter. Defendant, in stipulation with Plaintiff and Defendant Thomasson, request that the ENE deadline be continued 120 days to December 28, 2010. A case management conference was held on May 27, 2010. On June 1, 2010 the court issued the Case Management and Pretrial Order, referring the case to ADR for ENE to be completed within 90 days. The 90 days expires on August 30, 2010.
Stip. to Extend ENE Deadline and Proposed Order CASE NO. C10-0752PJH

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ENE evaluator, George Harris, was appointed by the ADR clerk on July 19. (See Docket No. 129.) The evaluator contacted the parties on August 3 and scheduled a phone conference for August 6. On August 6 the phone conference was not able to take place due to unavailability of Plaintiffs' counsel. The phone conference was subsequently rescheduled to August 13. Given the parties' and evaluator's schedules, the parties are unable to complete ENE prior to August 30. Moreover, at this point there has been limited discovery in this case. Other than initial disclosures, the only discovery includes requests for production noticed by Defendant City and several subpoenas for records noticed by Defendant Thomasson. A response to either is yet to be received. The parties believe additional discovery is necessary to make the ENE a productive process. In addition, Defendant City's counsel is unavailable and out of the country the first three weeks of October, the ENE evaluator is unavailable the last week of October and first three weeks of November due to an arbitration in Singapore, and Defendant City's counsel is scheduled for a two week trial November 29. For the above reasons, Defendant City, Defendant Thomasson and Plaintiff request a 120 day extension of the ENE deadline to December 28, 2010. All parties are in agreement with this request and their stipulation is below: /// /// /// /// /// /// /// /// /// /// /// ///
Stip. to Extend ENE Deadline and Proposed Order CASE NO. C10-0752PJH

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IT IS STIPULATED BY THE PARTIES AS FOLLOWS: 1) 2) The parties desire to engage in further discovery before completing the ENE. According to the above, the parties stipulate to extend the ENE deadline 120 days to

December 28, 2010. 3) This agreement between the parties will require no other modification of the scheduling

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The parties request that the Court enter an order consistent with this stipulation.

Dated: August 13, 2010 By: /s/ Lauren M. Monson LAUREN M. MONSON Attorneys for Defendant CITY AND COUNTY FOR SAN FRANCISCO

Dated: August 13, 2010 By: /s/ Geoffrey Gordon-Creed Geoffrey Gordon-Creed Attorney for Defendant BRYAN THOMASSON

Dated: August 13, 2010 By: /s/ Evgenii Sverdlov EVGENII SVERDLOV, ESQ. Attorney for Plaintiff SHANIA RAMAN

PURSUANT TO STIPULATION, IT IS SO ORDERED: Dated: 8/17/10
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Stip. to Extend ENE Deadline and Proposed Order CASE NO. C10-0752PJH

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