The opinion of the court was delivered by: Honorable Maria-elena James
STIPULATION TO CONTINUE MEDIATION DEADLINE Trial Date: April 14, 2014
Pursuant to Northern District ADR Local Rule 6-5, the parties, by and through their respective 2 counsel, hereby stipulate and request that the deadline to complete mediation in this matter be extended 3 from June 10, 2013 to September 30, 2013. 4
On March 7, 2013, the Court issued its case management order, scheduling trial for April 14, 2014 and referring this matter to mediation. Pursuant to Northern District ADR Local Rule 6-4(b), 6 mediation is to be completed by June 10, 2013. 7
On April 8, 2013, all parties except HEATHER HOWARD, exchanged initial disclosures.
HEATHER HOWARD served her initial disclosures on April 16, 2013. 9
On April 18, 2013, the Court issued it order appointing mediator Noah G. Blechman.
The parties recently commenced discovery and believe it is important and necessary to complete 11 multiple depositions, including the depositions of plaintiffs, police personnel, jail personnel and medical 12 staff prior to submitting the matter to mediation. 13
All counsel discussed the mediation deadline and agreed to request a continuance of the June 10, 2013 deadline to September 30, 2013 to accommodate the need to undertake significant discovery to 15 make the mediation session productive. The parties also notified Mr. Blechman of their intent to seek a 16 continuance of the mediation deadline. 17
Dated: April 26, 2013 BERTRAND, FOX & ELLIOT By: /s/ Richard W. Osman Thomas F. Bertrand Richard W. Osman Attorneys for Defendants CITY OF NOVATO, CHIEF JOSEPH KREINS, OFFICER THOMAS MACKENZIE, OFFICER MICHAEL DUNN and OFFICER STEPHANIE COMMISTO Dated: April 26, 2013 BRENT, FIOL & NOLAN LLP By: /s/ David L. Fiol David L. Fiol Attorneys for Plaintiffs LYNNETTE FRARY AND JAMIE BALL Dated: April 26, 2013 BONNER & BONNER By: /s/ Charles A. Bonner Charles A. Bonner Attorneys for Plaintiff HEATHER HOWARD Dated: April 26, 2013 OFFICE OF THE COUNTY COUNSEL By: /s/ Steven M. Perl Steven M. Perl Attorneys for Defendants COUNTY OF MARIN, SHERIFF ROBERT T. DOYLE, and DEPUTY RACHEL HAMMER
Upon the foregoing Stipulation, and for good cause shown, IT IS ORDERED that the deadline to 3 complete mediation in the present matter is continued from June 10, 2013 to September 30, 2013 4 5
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