The opinion of the court was delivered by: Honorable Oliver W. Wanger
STACY A. CAMPOS, SBN 154658 PACIFIC GAS AND ELECTRIC COMPANY LAW DEPARTMENT P.O. Box 7442 San Francisco, CA 94120 KATE DYER, SBN 171891 NICOLE HOWELL NEUBERT, SBN 246078 CLARENCE & DYER LLP 899 Ellis Street San Francisco, CA 94109 Telephone: (415) 749-1800 Facsimile: (415) 749-1694 Email: firstname.lastname@example.org email@example.com Attorneys for Defendant PACIFIC GAS AND ELECTRIC COMPANY LINDSAY R. NICHOLAS, SBN 273063 Leonard Carder, LLP 1188 Franklin St., Suite 201 San Francisco, CA 94109 (415) 771-6400 Fax: (415) 771-7010 E-Mail: firstname.lastname@example.org Attorneys for Defendant INTERNATIONAL BROTHERHOOD OF ELECTRICAL WORKERS, LOCAL UNION 1245 TODD B. BARSOTTI, SBN 148862 Barsotti & Baker, LLP 6592 North First Street Fresno, CA 93710 Phone: (559) 226-2100 Fax: (559) 226-7636 E-Mail: email@example.com Attorneys for Plaintiff Gary Henley
STIPULATION AND ORDER MODIFYING SCHEDULING ORDER
Trial Date: January 18, 2012 Time: 9:00 a.m. Courtroom 3, 7th Floor
Pursuant to Civil Local Rules 143 and 137(b), the parties hereby jointly and respectfully submit a stipulation and proposed order requesting that the Court revise the Scheduling Conference Order such that, while certain discovery dates are modified, the motions deadlines and hearing dates, as well as the Pre-trial Conference and Jury Trial dates remain unchanged.
The parties seek a modification of these dates in order to accommodate a private mediation session with Thomas Simonian, Esq at JAMS mediation on July 11, 2011. The current pre-trial dates, and proposed modifications, are as follows:
Event Current Date Proposed Date Close of non-expert discovery June 1, 2011 August 5, 2011 Expert disclosures due July 15, 2011 August 12, 2011 Expert discovery cut-off August 29, 2011 September 5, 2011 Settlement conference September 13, 2011 same
Dispositive pre-trial motions due September 29, 2011 same
Dispositive pre-trial motions hearing October 31, 2011 same
Joint pre-trial statement due December 5, 2011 same
Pre-trial conference December 5, 2011 same
Jury Trial January 18, 2012 same
The parties believe that the modified schedule will allow the parties an opportunity to participate in a meaningful mediation session while potentially avoiding unnecessary discovery costs.
Good cause having been shown, the pre-trial dates in this matter are ...