June 3, 2013
SAM CHILES, Plaintiff,
THE PERMANENTE MEDICAL GROUP, INC., and Does 1 through 50, Defendants.
Steven R. Anthony (SBN 37778), Jane L. Trigero, Of Counsel (SBN 103575), KNOX RICKSEN LLP, Oakland, CA, Attorneys for Defendant THE PERMANENTE MEDICAL GROUP, INC.
Angela L. Morgan (SBN 208585), LOGAN LAW GROUP, San Ramon, California, Attorney for Plaintiff SAM CHILES.
JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE MEDIATION COMPLETION DEADLINE
MARIA-ELENA JAMES, District Judge.
Plaintiff SAM CHILES and Defendant THE PERMANENTE MEDICAL GROUP, INC., by and through undersigned counsel, hereby stipulate to continue the date set to complete mediation from July 4, 2013 to October 1, 2013.
Pursuant to the Court's Case Management Order of April 5, 2013, the Plaintiff's deposition was to be completed before mediation. Due to the scheduling conflicts of the parties the deposition could not be scheduled until June 20, 2013. Defense counsel's vacation and trial/arbitration calendar is completely booked and the first available date for a mediation session is September 25, 2013, which is a date that is agreeable with all counsel and the court-appointed mediator. For these reasons, and good cause appearing, the parties request that the Court vacate July 4, 2013 as the date set to complete mediation and order that mediation be completed by October 1, 2013.
IT IS SO STIPULATED
Pursuant to the stipulation of the Parties, and good cause appearing; IT IS SO ORDERED that:
The mediation completion deadline, previously set for July 4, 2013, is continued to October 1, 2013.