Oda v. UNITED STATES OF AMERICA

Filing 12

STIPULATION AND ORDER EXTENDING DATE TO COMPLETE MEDIATION re 11 Proposed Order filed by UNITED STATES OF AMERICA. Signed by Judge Paul S. Grewal on January 20, 2012. (psglc1, COURT STAFF) (Filed on 1/20/2012)

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MELINDA HAAG (SBN 132612)
United States Attorney
JOANN M. SWANSON (CSBN 88143)
Chief, Civil Division
MICHAEL T. PYLE (CSBN 172954 )
JAMES A. SCHARF
Assistant United States Attorneys
150 Almaden Blvd., Suite 900
San Jose, California 95113
Telephone:
[phone]
Facsimile:
[phone]
Email:
[e-mail]
Attorneys for Federal Defendant

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN JOSE DIVISION
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CELESTE ODA,
Plaintiff,

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v.
UNITED STATES OF AMERICA,
Defendant.

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No. C 11-04514 PSG
STIPULATION AND [PROPOSED]
ORDER EXTENDING DATE TO
COMPLETE MEDIATION

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Whereas, the November 21, 2011, Case Management Order, Document 9, requires the parties
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to complete all fact discovery by May 11, 2012, mediate the case by May 18, 2012, disclose
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expert reports by June 8, 2012, and complete expert depositions by August 3, 2012.
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Whereas, defendant has scheduled an Independent Medication Examination of plaintiff for
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April 2, 2012.
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Whereas, plaintiff may assert a claim for future neck surgery and intends to consult with a
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Kaiser surgeon regarding her need for surgery.
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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO COMPLETE
MEDIATION
Case No. C 11-04514 PSG

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Whereas, the parties believe that scheduling a mediation shortly after expert reports are
exchanged maximizes the chances for settlement at the mediation.

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Whereas, scheduling the mediation in late June would not affect any of the other case

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management dates, including the trial date, and still leaves time for the parties to depose the

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experts in the event that the June mediation is unsuccessful.

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Whereas, the parties and the court-appointed mediator are all available to participate in a
mediation on June 27, 2012.
Therefore, the parties request that the Court extend the time to complete the mediation to and
including June 27, 2012.

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Dated: January 12, 2012
Respectfully submitted,

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MELINDA HAAG
United States Attorney

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By:
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___________/S/_____________
JAMES A. SCHARF
Assistant United States Attorney
Attorney for Defendant

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___________/S/_____________
JOHN S. GERHARDT
Attorney for Plaintiff

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Pursuant to the parties’ stipulation, and good cause appearing, it is hereby ordered:
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The date to complete the mediation extended to June 27, 2012.
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Dated: January 20 2012
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_____________________________
Hon. Paul S. Grewal
United States District Court Magistrate Judge

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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO COMPLETE
MEDIATION
Case No. C 11-04514 PSG