Peilin Chang v. American Airlines, Inc.

Filing 27

STIPULATION AND ORDER EXTENDING TIME TO COMPLETE MEDIATION, granting 26 . The deadline to conduct private mediation is extended from 8/31/2016 to 11/18/2016. 2/2/2017 Pretrial Conference and 2/21/2017 Jury Trial to remain as presently set. Signed by Hon. Ronald M. Whyte on 8/29/2016. (ofr, COURT STAFF) (Filed on 8/29/2016)

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TIMOTHY J. RYAN, SBN 99542
REBEKKA R. MARTORANO, SBN 173600
THE RYAN LAW GROUP
400 Capitol Mall, Suite 2540
Sacramento, California 95814
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Defendant
American Airlines, Inc.

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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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PEILIN CHANG

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Plaintiff,

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v.

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AMERICAN AIRLINES, INC.,

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Defendant.

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____________________________________

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Case No. 15-cv-02604-RMW
STIPULATION AND ORDER
EXTENDING TIME TO COMPLETE
MEDIATION
Judge: Honorable Ronald M. Whyte
Courtroom: 6, 4th Floor

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The parties in the above-captioned matter hereby stipulate as follows:

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1.

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WHEREAS the current scheduling order of April 14, 2016 provides for a deadline to
complete private mediation of August 31, 2016.

2.

WHEREAS the parties have been diligently engaged in discovery, including the following:
a.

Arranging for two defense medical examinations of plaintiff: a neurological

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examination that was completed on July 11, 2016 and a neuropsychological

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examination to be conducted on August 30, 2016;

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b.

Completing depositions of plaintiff (7/11/16), plaintiff’s treating physician Dr. Rosen

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(7/29/16), employees of plaintiff’s medical practice (8/19/16 and 8/22/16), and

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bookkeepers and accountants for plaintiff’s medical practice (8/18/16, 8/19/16 and
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STIPULATION AND ORDER EXTENDING TIM E TO COM PLETE M EDIATION

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8/22/16);

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c.

Scheduling additional depositions, including the deposition of plaintiff’s neurologist,

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Dr. Helman (originally scheduled on 8/22/16 but continued to 9/20/16 at the request

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of the witness), and plaintiff’s colleague, Dr. Lubben (9/9/16);

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d.

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Conferring regarding additional depositions to be set, including the flight attendant
involved in the subject incident.

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Notwithstanding the parties’ diligent efforts, the case is not yet ripe for mediation. Plaintiff

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alleges that she has sustained significant and permanent injuries and a significant loss of

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income. These claims require further investigation before a meaningful mediation can be

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conducted.
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Therefore the parties propose that the deadline to conduct private mediation be extended by
approximately 80 days, from August 31, 2016 to November 18, 2016.

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IT IS SO STIPULATED.

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Dated: August 26, 2016

BROWNSTEIN THOMAS, LLP

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By:

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/s/ Stephen Gorog
STEPHEN GOROG
Attorneys for plaintiff Peilin Chang

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Dated: August 26, 2016

THE RYAN LAW GROUP

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By:

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/s/ Rebekka Martorano
REBEKKA R. MARTORANO
Attorneys for Defendant American Airlines,
Inc.

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STIPULATION AND ORDER EXTENDING TIM E TO COM PLETE M EDIATION

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ORDER

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Based on the stipulation of the parties and good cause appearing, IT IS HEREBY ORDERED

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that the deadline to conduct private mediation is extended from August 31, 2016 to November 18,

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2016. 2/2/2017 Pretrial Conference and 2/21/2017 Jury Trial to remain as presently set.

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IT IS SO ORDERED.

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Dated:______________________
8/29/2016

______________________________
Judge, United States District Court

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STIPULATION AND ORDER EXTENDING TIM E TO COM PLETE M EDIATION