Strawn v. Shenandoah Charters et al

Filing 22

STIPULATION AND ORDER TO EXTEND MEDIATION AND DISCOVERY DEADLINES re 21 Stipulation filed by Clay Collins, Todd J. Collins. Signed by Judge Phyllis J. Hamilton on 11/4/11. (nah, COURT STAFF) (Filed on 11/4/2011)

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MARKER E. LOVELL, JR. (208659)
CHELSEA D. YUAN (240559)
GIBSON ROBB & LINDH LLP
201 Mission Street, Suite 2700
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
Attorneys for Defendants
CLAY COLLINS AND TODD COLLINS

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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NICOLE STRAWN

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Plaintiff,
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v.
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SHENANDOAH CHARTERS, CLAY
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COLLINS, TODD J. COLLINS, and DOES )
1-10, in personam, and FV
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SHENANDOAH, and her engines, tackle, )
apparel, etc., in rem,
)
)
Defendants.
)
____________________________________)

Case No. CV-10-4015 PJH
STIPULATION AND [PROPOSED]
ORDER TO EXTEND MEDIATION AND
DISCOVERY DEADLINES

Complaint filed:
Trial Date:

September 8, 2010
May 21, 2012

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Defendants CLAY COLLINS and TODD COLLINS, by and through their counsel of

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record, Gibson Robb & Lindh LLP, and Plaintiff NICOLE STRAWN, by and through her

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counsel of record, Brodsky Micklow Bull & Weiss LLP, hereby enter into the below stipulation

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to continue the mediation and discovery deadlines in this matter.

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This stipulation is made in consideration of the fact that the parties have been actively

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engaged in discovery including extensive written discovery, but need additional time to complete

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depositions. Counsel for both parties are working together to coordinate the depositions of

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Plaintiff and Defendants, which will likely require travel to Eureka and Redding, California.

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Until these depositions are complete, the parties will not have the foundational information

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STIPULATION AND [PROPOSED] ORDER TO EXTEND MEDIATION AND DISCOVERY DEADLINES
Case No. CV-10-4015 PJH; Our File No. 8003.05

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necessary to fully evaluate the case for mediation. The parties have agreed to mediate the case

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with Chris Lavdiotis on January 12, 2012.

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Based on the foregoing, the parties submit that there is good cause to continue the

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mediation completion deadline and all discovery dates by at least 90 days. This would move the

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mediation completion date from October 18, 2011, to mid-January 2012. This would move the

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non-expert discovery cutoff from November 18, 2011, to mid-February 2012. This would move

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the date to disclose experts (retained and non-retained) from November 18, 2011, to mid-

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February 2012. This would move the expert discovery cutoff deadline of January 11, 2012, to

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early April 2012. This would not affect the trial date of May 21, 2012. The parties hereby

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stipulate that the Court’s Case Management and Pretrial Order may be amended as set forth

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below.

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Dated: November 2, 2011

BRODSKY MICKLOW BULL & WEISS LLP

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By: S/ EDWARD M. BULL, III
Edward M. Bull, III
Amy Jo Bull, Esq.
Attorneys for Plaintiff
NICOLE STRAWN

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Dated: November 2, 2011

GIBSON ROBB & LINDH LLP

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By: S/ MARKER E. LOVELL, JR.
Marker E. Lovell, Jr.
Attorneys for Defendants
CLAY COLLINS AND TODD COLLINS

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CERTIFICATE OF SIGNATURE

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I attest that the content of this document is acceptable to attorney, Edward M. Bull III, and that he
authorized me to sign the document on his behalf.

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STIPULATION AND [PROPOSED] ORDER TO EXTEND MEDIATION AND DISCOVERY DEADLINES
Case No. CV-10-4015 PJH; Our File No. 8003.05

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ORDER
IT IS SO ORDERED.

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Based on the foregoing stipulation, the mediation completion date of October 18, 2011, is
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off calendar. The new mediation completion date is January 20, 2012.
The non-expert discovery cutoff date of November 18, 2011, is off calendar. The new
non-expert discovery cutoff date is February 17, 2012.
The date to disclose experts (retained and non-retained) of November 18, 2011, is off
calendar. The new date to disclose experts (retained and non-retained) is February 17, 2012.

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remain unchanged.

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J

ER

yllis J.
udge Ph

H

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RT

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________________________________
Hon. Phyllis J.DERED
Hamilton
O OR
SStates District Judge
T IS
IUnited

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UNIT
ED

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November 4
Dated: ______________, 2011

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S DISTRICT
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R NIA

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All other dates in the Court’s Case Management and Pretrial Order dated May 2, 2011,

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Hamilto

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expert discovery cutoff deadline is April 6, 2012.

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The expert discovery cutoff deadline of January 11, 2012, is now off calendar. The new

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F
D IS T IC T O
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STIPULATION AND [PROPOSED] ORDER TO EXTEND MEDIATION AND DISCOVERY DEADLINES
Case No. CV-10-4015 PJH; Our File No. 8003.05

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PROOF OF SERVICE BY MAIL

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STATE OF CALIFORNIA, CITY AND COUNTY OF SAN FRANCISCO

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I am employed in the City and County of San Francisco by the law firm of GIBSON
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ROBB & LINDH LLP, 201 Mission Street, Suite 2700, San Francisco, California 94105. I am

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over the age of 18 years and not a party to the within action. I am readily familiar with the

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practice of GIBSON ROBB & LINDH LLP with respect to the collection and processing of

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pleadings, discovery documents, motions and all other documents which must be served upon

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opposing parties or other counsel in litigation. The below-described document(s) will be

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deposited in the ordinary course of the business of GIBSON ROBB & LINDH LLP with the

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United States Postal Service on the same date as I sign this document. On November 2, 2011, I

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served the within STIPULATION AND [PROPOSED] ORDER TO EXTEND MEDIATION

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AND DISCOVERY DEADLINES DEFENDANTS CLAY COLLINS AND TODD

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COLLINS TO PLAINTIFF’S COMPLAINT in said action by placing a true copy thereof

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enclosed in a sealed envelope with first class postage thereon fully prepaid addressed as follows:
Amy Jo Bull, Esq.
BRODSKY MICKLOW BULL & WEISS
LLP
384 Embarcadero West, Suite 200
Oakland, CA 94607
Attorneys for Plaintiff
NICOLE STRAWN

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Following the ordinary business practices of GIBSON ROBB & LINDH LLP, I placed
the aforesaid envelope in the place for collection and mailing on the date specified.

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Pursuant to the Local Rules of the United States District Court, I certify that all originals

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and service copies (including exhibits) of the papers referred to herein were produced and
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STIPULATION AND [PROPOSED] ORDER TO EXTEND MEDIATION AND DISCOVERY DEADLINES
Case No. CV-10-4015 PJH; Our File No. 8003.05

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