IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
November 21, 2012
JAMES JUDKINS AN INDIVIDUAL PLAINTIFF,
GEOVERA HOLDINGS, INC., A DELAWARE CORPORATION, AND DOES 1-20,
SMITH PATTEN SPENCER F. SMITH, ESQ. (SBN:236587) DOW W. PATTEN, ESQ. (SBN: 135931) 353 Sacramento St., Suite 1120 San Francisco, California 94111 Telephone (415) 402-0084 Facsimile (415) 520-0104 Attorneys for Plaintiff JAMES JUDKINS
STIPULATION AND [PROPOSED] ORDER RE: EXTENSION OF DISCOVERY COMPLETION DATE THE PARTIES BY THEIR UNDERSIGNED COUNSEL HEREBY STIPULATE AND AGREE AS FOLLOWS:
1. The Parties have agreed to enter into a second round of mediation, in the hopes of settling the above referenced matter outside of Court.
2. The Parties have agreed to enter into mediation with retired Judge Richard Silver on January 29, 2012.
3. The Parties are simultaneously engaged in discovery and while written discovery is almost complete, deposition dates for various employees and former employees of Defendant have yet to be scheduled.
4. Both parties request that the time to complete discovery be extended by 90 days, thereby moving the discovery completion date to Monday, March 5, 2013.
5. The Court's extension of the time to complete discovery shall in no way inhibit either Parties' litigation rights.
IT IS SO AGREED.
GOOD CASE APPEARING, IT IS SO ORDERED,
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