The opinion of the court was delivered by: The Honorable Maxine M. Chesney United States District Court Judge
PLAINTIFFS' REQUEST TO APPEAR TELEPHONICALLY; [PROPOSED] ORDER THEREON
Judge: The Honorable Maxine M. Chesney
Plaintiffs herein respectfully request that they be permitted to appear telephonically at the Case Management Conference currently on calendar for November 12, 2010.
1. As stated in the Joint Case Management Conference Statement filed concurrently with the Court on November 5, 2010:
a. Plaintiffs and Defendants have served a FRCP Rule 26(a)(1) disclosure, describing known potential witnesses and categories of records, and their locations. Plaintiffs have responded to Defendants' request for disclosed documents. Defendants have submitted the calculations needed for Plaintiff to complete the audit.
b. Defendants have now compiled and submitted to Plaintiff's counsel the travel allowance calculations, which were the subject of this action, following the procedure outlined in the Bargaining Agreement.
c. The parties have agreed to court-supervised mediation, and the Court has so ordered. Because the travel calculations are an important factor in establishing the amount of damages Plaintiffs to which Plaintiffs may be entitled, and those calculations have only recently been completed and submitted to Plaintiffs for analysis, the parties have not yet scheduled mediation.
2. In order to minimize additional attorneys' fees and costs, and in the interest of conserving costs as well as the Court's time and resources, Plaintiffs respectfully request that they be permitted to appear telephonically at the November 12, 2010 Case Management Conference.
I declare under penalty of perjury that I am the attorney for the Plaintiffs in the above entitled action, and that the foregoing is true of my own knowledge.
Executed this 5th day of November, 2010, at San Francisco, California.
SALTZMAN & JOHNSON LAW CORPORATION Muriel B. Kaplan ...