United States District Court, Northern District of California
November 3, 2008
RE: TONITA DOSS
TRANSOCEAN SHIPMANAGMENT GMBA ET AL.
This letter is submitted jointly by Mr. Cory Birnberg, counsel for plaintiff Tonita Doss, and Ms. Jeanine Tede, counsel for defendant Hyundai Merchant Marine Co. Ltd. The parties request that the case management conference currently scheduled for November 12, 2008 be continued for the following reasons.
This matter involves alleged personal injuries to longshoreman Tonita Doss, and is governed by the Longshore Harbor Workers Compensation Act and general maritime law. Plaintiff initially filed suit against Lungi Shipping, Inc. and John T. Essberger GMBH (collectively, "the shipowner interests") but subsequently dismissed them without prejudice. As a result of facts ascertained during discovery and further legal analysis, Mr. Birnberg has deemed it necessary to bring the shipowner interests back into the litigation as defendants.
In conformance with the stipulation re dismissal between plaintiff and the shipowner interests, on October 20, 2008, Mr. Birnberg provided the required 30 days written notice to counsel for the shipowner interests of his intent to rejoin them as defendants.
Hon. Mag. Judge Larsen October 27, 2008
The parties are of the opinion that the case management conference would be more productive if all parties to the action are present, and respectfully request a continuance of at least sixty (60) days to mid-January, 2009.
IT IS SO ORDERED.
The Case Management Conference has been continued to January 14, 2009 at 10:30 a.m.
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