STIPULATION AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT CONFERENCE
The undersigned parties, by and through their counsel of record, herewith stipulate to the following:
1. A case management conference in this matter is currently scheduled to occur on May 20, 2010, commencing at 10:00 a.m.
2. The undersigned counsel for the City has a trial scheduled to commence in the Santa Clara County Superior Court on June 7, and is currently engaged in final preparations 5 for that trial.
3. Plaintiff Sky Chefs, Inc. wants to depose a City employee the day before or after the case management conference, so that Plaintiff's out-of-state counsel can accomplish both the conference and the deposition during the same trip. This arrangement is acceptable to the City, but the City's counsel needs to review documents to determine if any of them are going to be produced before the deposition and otherwise prepare for the deposition which, along with the case management conference itself, will take the City's counsel's time away from the aforementioned trial preparation efforts.
4. The parties jointly request that the case management conference be continued to July 1, July 15, or whatever other date more than thirty days hereafter is convenient to the court ATTESTMENT OF CONCURRENCE PER GENERAL ORDER 45 FOR FILING:
I attest that concurrence in the filing of this document by the signatories, Steven B. Dippell and Norman A. Quandt, has been obtained, and that a record of the concurrence shall be maintained at the Office of the City Attorney.
Having read and considered the stipulation set forth above, and finding good cause for the actions requested therein, it is ordered that:
1. The case management conference currently scheduled for May 20, 2010, is continued to _____________________________, and the parties' joint case management July 1, 2010 at 10:00 a.m.
conference statement is due ______________________.
5/12/10 Dated: ______________________ By: ______________________________ Hon. Richard Seeborg
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