Connett et al v. Chatham Towing Company, Inc. et al

Filing 61

ORDER granting the parties motion for an extension of time to conduct mediation. Signed by Magistrate Judge G. R. Smith on 9/8/14. (wwp)

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JLI1S, PAINTER, RATTERREE &ADAMS LIP

MAURY BOWEN
DIRECT DAL: 912231 .2732
W4VW.EPRA-LAW. COM

September 4, 2014

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VA HAND DEL.! VERY

Honorable G.R. Smith
Magistrate, U.S. District Court
Southern District of Georgia
Savannah Division
125 Bull Street
Savannah, GA 31401

RE:

Jonathan Connett, etal. vs. Chatham Towing Company, Inc. and
Colonial Group Inc Civil Action Number: 4:13-C V-00048-BAE-GRS
In the United States District Court, Southern District of Georgia
.,

Dear Judge Smith,
We are submitting this letter on behalf of all parties in this matter with their express
permission.
On August 16, 2014, this Honorable Court entered an Order Staying Proceedings
Pending Mediation (Doc. 59) allowing the parties to participate in mediation within thirty
days of the Court's Order. The Court's Order also stated that if settlement was not
accomplished in mediation, the parties shall have 30 days from the date of the
mediation to file civil motions, (including Daubert motions but excluding motions in
I/mine).
Upon receiving the Court's Order the parties worked diligently to schedule a conference
call and agree upon a mediator qualified in the field of maritime law. Within seven
working days of the Court's Order, the parties agreed upon E. Paul Gibson and made
contact with Mr. Gibson's office that same day (August 26, 2014) in order to schedule a
mediation within the thirty-day period allowed by the Court.
Unfortunately, Mr. Gibson is unavailable during the month of September due to his
plans to travel abroad as well as prior mediation commitments. The first available date
that the parties could schedule a mediation with Mr. Gibson is October 1, 2014.

1336662.1
2400-182

ATTORNEYS AT LAW
OFFICE: 2 EAST BRYAN STREET, TENTH FLOOR, SAVANNAH, GEORGIA 31401
MAILING ADDRESS: POST OFFICE BOX 9946, SAVANNAH, GEORGIA 31412
TELEPHONE: [phone] - FACSIMILE: 912-233-2281

The purpose of this letter is to seek leave of the Court to participate in mediation on
October 1, 2014, which is fourteen days after the thirty day period set by the Court
expires and to also seek leave of the Court that the parties (consistent with the Court's
above order.) have until November 1 file the above motions.
We are happy to file a formal motion and proposed order if desired by the Court.

RespectfIly submitted,

y
ry

for.. Defendants and with
express permission on behaff of all
parties

MB/jmnk
cc:

Sherri Flanders (via email to sherri flanders(dgas.uscourts.qov)
Robert B. Hopkins, Esq. (via e-mail rbhopkinsCäduanemorris.com )
Robert J. Kaufman, Esq. (via e-mail rflçkauflaw.net )

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