The opinion of the court was delivered by: The Honorable Claudia Wilken United States District Judge
STIPULATION AND ORDER EXTENDING DEADLINE FOR EARLY NEUTRAL EVALUATION CONFERENCE CONDUCTING
The parties hereto, by and through their undersigned counsel, and subject to the approval of the Court, do hereby STIPULATE AND AGREE as follows:
1. WHEREAS, Plaintiff David Monedero ("Plaintiff") and Defendant Cellco Partnership d/b/a Verizon Wireless ("Defendant") are scheduled to attend an Early Neutral Evaluation ("ENE") conference on February 24, 2009 before evaluator Dirk M. Schenkkan;
2. WHEREAS, Plaintiff and Defendant are currently engaged in informal settlement discussions and share a reasonable belief that they will reach a resolution of this matter either prior to or shortly after the scheduled ENE conference;
3. WHEREAS, Plaintiff and Defendant agree that extending the deadline for conducting the ENE conference will allow the parties to focus on settlement during the time that would otherwise be spent preparing for the ENE session, including conducting multiple depositions;
4. WHEREAS, an extension will reduce the potentially unnecessary expenditure of time and resources by the parties and the evaluator;
5. WHEREAS, the extension sought will not affect the other deadlines in this case set forth in the Court's Case Management Order dated October 23, 2008;
6. IT IS HEREBY STIPULATED by and between Plaintiff and Defendant through their respective counsel of record, subject to the approval of the Court, that the deadline for conducting an ENE conference is extended by thirty (30) days to March 24, 2009.
Jones Day Catherine S. Nasser Attorneys for Defendant CELLCO PARTNERSHIP d/b/a VERIZON WIRELESS
Law Offices of O'Donnell & Smith James J. O'Donnell Attorney for Plaintiff DAVID MONEDERO
I hereby attest that the content of this document is acceptable to all persons whose signatures are indicated by a "conformed" ...