STIPULATION AND [PROPOSED] ORDER CONTINUING INITIAL CASE MANAGEMENT CONFERENCE AND RELATED DEADLINES
STIPULATION 1. On May 12, 2010, counsel for Plaintiff Fernando Reyes ("Plaintiff") and Defendant United Parcel Service, Inc. ("UPS") held their meet and confer conference regarding initial disclosures, alternative dispute resolution ("ADR") options, the joint case management statement, and the Rule 26(f) discovery plan.
that he is not available for the Initial Case Management Conference currently scheduled for June
2. During the meet and confer conference, lead counsel for Plaintiff indicated 4, 2010 at 10:30 a.m. The earliest date following June 4, 2010 on which lead counsel for both parties are available, and on which the Court holds initial case management conferences, is June 18, 2010. In order to allow lead counsel for both parties to attend the initial case management conference, the parties stipulate to continuing the initial case management conference from June 4, 2010 at 10:30 a.m. to June 18, 2010 at 10:30 a.m.
dates preceding the initial case management conference:
3. Based on this agreement, the parties also stipulate to continue the following (a) The parties shall file their ADR Certifications and either (1) a Stipulation to ADR Process or (2) a Notice of Need for ADR Phone Conference on or before May 28, 2010. The parties were not able to agree on an ADR option during their meet and confer conference on May 12, 2010, and the additional time will allow the parties to attempt to reach an agreement.
including the parties' Rule 26(f) discovery plan, on or before June 11, 2010.
(b) The parties shall file their Joint Case Management Statement,
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