UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA
April 4, 2012
FOSTER DANNY ALEXANDER,
KAISER FOUNDATION HOSPITALS; AND DOES 1 THROUGH 50, INCLUSIVE,
STIPULATION TO EXTEND ADR DEADLINE
Case Filed: May 16, 2011
Due to the trial calendar of defense counsel, the parties have been unable to schedule and complete necessary depositions prior to the court ordered ADR deadline of April 4, 2012.
To date, Defendants have taken and completed Plaintiff's deposition. Additionally, after the parties resolve certain outstanding issues with regard to Plaintiff's first set of written discovery, 2 Plaintiff intends to schedule a few targeted depositions to assist with the overall settlement analysis 3 of this matter. Given the time necessary to complete this initial discovery, the parties anticipate that 4 a mediation could be completed by late June (Plaintiff's counsel have a trial schedule for early June), 5 and are actively working to do so. 6
Accordingly, the parties hereby request to extend the current ADR deadline from April 4, 2012 to June 29, 2012. 8 The trial is scheduled on March 11, 2013. The parties do not anticipate that requested 9 extension will impact the trial date 10 So Stipulated.
Employment Law Oakland, California 94610 3000 Lakeshore Avenue
Dated: April 3, 2012 FOSTER EMPLOYMENT LAW /s/ Madelyn Jordan-Davis Michael W. Foster, Esq. KAISER FOUNDATION HOSPITALS FOSTER Richard A. Hoyer, Esq. David C. Lipps, Esq. Attorneys for Plaintiff Dated: April 3, 2012 HOYER & ASSOCIATES DANNY ALEXANDER Madelyn G. Jordan-Davis, Esq. Attorneys for Defendant
IT IS HEREBY ORDERED that the mediation deadline be continued in accordance with the
parties' stipulation herein.
IT IS SO ORDERED.
Judge of the U.S. District Court
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