Moss v. SAN FRANCISCO GENERAL HOSPITAL AND TRAUMA CENTER et al

Filing 40

STIPULATION AND ORDER re 39 STIPULATION WITH PROPOSED ORDER to Extend Deadline to Mediate Under General Order 56 filed by Nicole Moss, City and County of San Francisco, ***Deadlines terminated. 39 STIPULATION WITH PROPOSED ORDER to Extend Deadline to Mediate Under General Order 56 filed by Nicole Moss, City and County of San Francisco. Signed by Magistrate Judge Kandis A. Westmore on 6/27/17. (sisS, COURT STAFF) (Filed on 6/27/2017)

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CELIA McGUINNESS, ESQ. (SBN 159420)
DERBY, McGUINNESS, & GOLDSMITH, L.P.
200 Lakeside Drive, Suite A
Oakland, CA 94612
Telephone: [phone]
Facsimile: [phone]
[e-mail]
PAUL L. REIN, Esq. (SBN 43053)
LAW OFFICES OF PAUL L. REIN
200 Lakeside Drive, Suite A
Oakland, CA 94612
Telephone: [phone]
Facsimile:
510/832-4787
[e-mail]
MICHAEL E. GATTO, Esq. (SBN 196474)
VAN BLOIS & ASSOCIATES
7677 Oakport Street, Suite 565
Oakland, CA 94621
Phone: [phone]
Fax: [phone]
[e-mail]
Attorneys for Plaintiff
NICOLE MOSS
* Defendants and their counsel listed after the caption.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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NICOLE MOSS,

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Plaintiff,

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v.

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SAN FRANCISCO GENERAL
HOSPITAL AND TRAUMA CENTER;
CITY AND COUNTY OF SAN
FRANCISCO DEPARTMENT OF
PUBLIC HEALTH; CITY AND COUNTY
OF SAN FRANCISCO; and DOES 1-20,
INCLUSIVE,

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CASE NO. 3:16-cv-00072 KAW
Civil Rights
STIPULATION AND [PROPOSED]
ORDER TO EXTEND DEADLINE TO
MEDIATE UNDER GENERAL ORDER 56

Defendants.

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//
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STIP TO EXTEND GO 56 DEADLINES
CASE NO. 3:16-cv-00072 KAW

C:\Users\IMBRIA~1\AppData\Local\Temp\notesF8C1A4\2017 06 26 stip to continue deadline to mediate.docx

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DENNIS J. HERRERA, State Bar #139669
City Attorney
CHERYL ADAMS, State Bar #164194
Chief Trial Deputy
THOMAS S. LAKRITZ, State Bar #161234
Deputy City Attorney
Fox Plaza
1390 Market Street, 6th Floor
San Francisco, California 94102-5408
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Defendant
CITY AND COUNTY OF SAN FRANCISCO

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STIPULATION

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Plaintiff NICOLE MOSS (“Plaintiff”) and Defendant CITY AND COUNTY OF SAN

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FRANCISCO hereby jointly stipulate and request through their attorneys of record to extend the

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deadline to mediate the case to August 18, 2017. This stipulation is based on the following good

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cause:

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1.

The parties have worked cooperatively to move through General Order 56.

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2.

The parties have engaged in significant pre-mediation discussion via telephone

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conference and e-mail, facilitated by ADR Director Howard Herman.

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3.

The parties previously agreed to mediate the case on May 9, 2017.

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4.

On May 1, 2017, counsel for the Estate of Nicole Moss informed the other parties

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that it was necessary to postpone the mediation to gain a better understanding regarding the status of

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the Estate and participate in a meaningful mediation.

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5.

Due to the number of party representatives and attorneys involved in the two matters

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being mediated together, the parties were unable to find a mutually agreeable date for mediation

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within the Court’s deadline to complete mediation.

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6.

The parties have conferred with Howard Hermann regarding a new date for

mediation and selected August 17, 2017.
Therefore, in an effort to keep costs down and to facilitate efficient resolution of the case
through mediation and the General Order 56 process, the parties stipulate and request that the Court
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STIP TO EXTEND GO 56 DEADLINES
CASE NO. 3:16-cv-00072 KAW

C:\Users\IMBRIA~1\AppData\Local\Temp\notesF8C1A4\2017 06 26 stip to continue deadline to mediate.docx

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order the deadline for mediation to take place under General Order 56 be extended to August 18,

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2017.

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Date: June 26,2017

DERBY, McGUINNESS, & GOLDSMITH, L.P.

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By:
/s/ Celia McGuinness
CELIA McGUINNESS, ESQ.
Attorneys for Plaintiff
NICOLE MOSS

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Date: June 26, 2017

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DENNIS J. HERRERA
City Attorney
CHERYL ADAMS
Chief Trial Deputy
THOMAS S. LAKRITZ
Deputy City Attorney

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By:
/s/ Thomas S. Lakritz
THOMAS S. LAKRITZ, ESQ.
Attorneys for Defendant
CITY AND COUNTY OF SAN FRANCISCO

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STIP TO EXTEND GO 56 DEADLINES
CASE NO. 3:16-cv-00072 KAW

C:\Users\IMBRIA~1\AppData\Local\Temp\notesF8C1A4\2017 06 26 stip to continue deadline to mediate.docx

ORDER

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Pursuant to the stipulation of the parties, and for good cause shown, IT IS SO ORDERED.

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The deadline for the parties to mediate under General Order 56 is hereby continued to August 18,

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2017.

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6/27
Dated: _________, 2017

U.S. Magistrate Judge Kandis A. Westmore

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STIP TO EXTEND GO 56 DEADLINES
CASE NO. 3:16-cv-00072 KAW

C:\Users\IMBRIA~1\AppData\Local\Temp\notesF8C1A4\2017 06 26 stip to continue deadline to mediate.docx

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FILER’S ATTESTATION

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Pursuant to Local Rule 5-1, I hereby attest that on June 26, 2017, I, Celia McGuinness,

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attorney with Derby, McGuinness, & Goldsmith, L.P., received the concurrence of Thomas S.

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Lakritz in the filing of this document.

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/s/ Celia McGuinness
Celia McGuinness

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STIP TO EXTEND GO 56 DEADLINES
CASE NO. 3:16-cv-00072 KAW

C:\Users\IMBRIA~1\AppData\Local\Temp\notesF8C1A4\2017 06 26 stip to continue deadline to mediate.docx