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Sandra Ramos v. City and County of San Francisco

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA


April 27, 2012

SANDRA RAMOS,
PLAINTIFF,
v.
CITY AND COUNTY OF SAN FRANCISCO,
DEFENDANT.

The opinion of the court was delivered by: The Honorable William H. Alsup United States District Court Judge

DENNIS J. HERRERA, State Bar #139669 City Attorney ELIZABETH S. SALVESON, State Bar #83788 Chief Labor Attorney 3 ANDREW GSCHWIND, State Bar #231700 Deputy City Attorney 4 Fox Plaza 1390 Market Street, Fifth Floor 5 San Francisco, California 94102-5408 Telephone: (415) 554-3973 6 Facsimile: (415) 554-4248 7 Attorneys for Defendant CITY AND COUNTY OF SAN FRANCISCO 8 9 Alan F. Cohen194075 LAW OFFICES OF ALAN F. COHEN 10 101 Montgomery St., Suite 2050 San Francisco, CA 94104 11 Telephone: 415-984-1943 Facsimile: 415-984-1953 12 Attorney for Plaintiff 13 SANDRA RAMOS

STIPULATION AND [PROPOSED] ORDER EXTENDING DEADLINE TO COMPLETE MEDIATION UNTIL AFTER RULING ON SUMMARY JUDGMENT MOTION

The parties, Plaintiff Sandra Ramos, and Defendant City and County of San Francisco, by and 25 through their attorneys of record, hereby stipulate and request that the Court extend the deadline to 26 complete mediation in this action to thirty (30) days after the Court rules on Defendant's anticipated 27 motion for summary judgment. Pursuant to the Court's February 2, 2012 Order appointing mediator Zela Claiborne of JAMS, 2 the parties have until May 3, 20112 to complete mediation. The parties request that this deadline be 3 continued to thirty (30) days after the Court rules on Defendant's anticipated motion for summary 4 judgment. Currently, the deadline for filing dispositive motions in this case is November 1, 2012. (A 5 final Pretrial Conference is scheduled on December 10, 2012 and trial is scheduled to begin December 6 17, 2012.) 7

This is the first stipulation and proposed order to continue the mediation deadline. The parties 8 request this continuance for the following two reasons. 9 First, Defendant City intends on filing a motion for summary judgment, and the City does not 10 foresee any possibility of offering Plaintiff more than a comparatively small sum in settlement prior to 11 determination of Defendant's anticipated dispositive motion. Based on this representation and 12 discussions with defense counsel, Plaintiff does not believe that mediation should go forward at the 13 present time.

Also, the parties' have only recently begun depositions and further deposition discovery is 15 necessary for the mediation to be meaningful. 16

[PROPOSED] ORDER

Good cause appearing from the Parties' stipula The Court hereby orders the deadline to complete tion, the Court hereby orde mediation be extended rs that the deadline to June 8, 2012.

for completing mediation is extended to thirty for completing mediation is extended extend to June to Ju8, 2012. anticipated motion for summary judgment.

SO ORDERED.

Dated:


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