The opinion of the court was delivered by: Hon. Bernard Zimmerman
STIPULATION AND ORDER TO CONTINUE THE DEADLINES FOR NON-EXPERT DISCOVERY AND DISPOSITIVE MOTIONS
Pursuant to Civil L.R. 7-12, the parties, through their undersigned counsel, stipulate as follows:
1. By Order of the court, dated August 28, 2008, the Parties to this action were required to complete Non-expert Discovery by October 1, 2008. Furthermore, that same order set the deadline for hearing Dispositive Motions as November 25, 2008. Due to scheduling conflicts and attempts to resolve this matter without the need for further litigation, the Parties require additional time to complete discovery in this matter. The parties have participated in an Early Neutral Evaluation, conducted by John Beers, Esq. Pursuant to the ENE, it is believed by the parties, counsel and evaluator that the case has a much improved chance of settling; however, the key deadlines (and necessarily the trial date) need to be continued in order to eliminate the need for unnecessary attorneys' fees and costs which would detract from the potential for a settlement.
2. The Parties Stipulate and Agree that an extension of the deadline for Non-Expert Discovery to December 31, 2008 and an extension of the deadline for Dispositive Motions to February 27, 2009 will permit them the appropriate time to attempt complete discovery and obtain a resolution by way of a settlement of this matter without the need for trial.
3. Accordingly, the Parties jointly request the Court enter an Order setting the following deadlines and a new trial date:
Completion of Non-expert Discover by December 31, 2008
Last day for hearing Dispositive Motions, February 27, 2009
New trial date: Soonest date available after May 1, 2009
DAVIS WRIGHT TREMAINE LLP By: Aaron Roblan Attorneys for Defendants MARCO BARRAGAN and MATHESON POSTAL SERVICES, INC.
TENAX LAW GROUP By: /s/ Christopher Arras TENAX LAW GROUP, PC Christopher Arras Attorneys for the Plaintiff JORGE ANGULO
PURSUANT TO STIPULATION, IT IS SO ORDERED:
Last day to hear Dispositive Motions: ...