UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA
March 10, 2010
MARIFI BAUTISTA, PLAINTIFF,
AON BENFIELD, INC., AON SERVICE CORPORATION, AON CORPORATION, AND DOES 1 THROUGH 100, INCLUSIVE, DEFENDANTS.
The opinion of the court was delivered by: The Honorable Marilyn H. Patel United States District Judge
JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINE FOR MEDIATION TO THE ABOVE-ENTITLED COURT:
The parties, through their respective counsel, hereby advise this Court, and stipulate, as 28 follows:
In accordance with Local Rule 6-2, Plaintiff Marifi Bautista ("Plaintiff") and Defendants Aon Benfield Inc. and Aon Service Corporation ("Defendants") hereby stipulate and jointly move this Court for a brief extension of the mediation completion deadline set by this Court. The Parties request that the mediation completion deadline previously set for March 31, 2010 be extended through April 23, 2010.
As grounds for this motion the Parties state the following:
1. This is a claim for Employment Discrimination, Violation of the Equal Pay Act; Retaliation; Failure to Prevent Discrimination and Wrongful Termination related to Plaintiff's employment with Defendants.
2. The first Case Management Conference in this case took place on November 23, 2009.
At that Case Management Conference the Court ordered that private mediation in this case had to be completed by March 31, 2010 and that prior to this mediation the parties were limited to three depositions each and fifteen interrogatories and requests for production.
discovery to each other and will begin scheduling depositions shortly.
beginning on March 18, 2010, which is anticipated to be three to four weeks in length.. do not believe they will be able to complete a meaningful mediation before the Court's deadline.
deadline, with the new deadline by which mediation must be completed as April 23, 2010.
3. Discovery is actively underway. Plaintiff and Defendants have propounded written
4. Defendants' counsel, Erica Kelley, has a trial scheduled in Contra Costa County
5. Given Defense counsel's unavailability at the end of March and early April, the Parties
6. The parties have a mediation scheduled with Michael J. Loeb for April 23, 2010.
7. The Parties therefore request that the Court grant the Parties a brief extension to this
8. This is the first request for an extension to any deadline in this case.
9. The only other date scheduled by the Court in this case is a further Case Management
Conference on April 26, 2010. This date will not need to be changed as the parties will have 26 completed the mediation prior to this date. 27 28 extension.
10. Since both Parties stipulate to and join this motion, no party is prejudiced by this Accordingly, the Parties respectfully request that the Court grant the Parties' Stipulation and Joint Motion to extend the mediation deadline.
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